Last Revised: July 1, 2024
NeoGraf Solutions, LLC and its subsidiaries and affiliates (the “Company”, “we”, “us” and “our”) are committed to protecting the information of visitors and consumers who use our products and services. This California Privacy Disclosure (“Disclosure”) outlines how Company collects, uses, and discloses the personal information of California consumers covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). The words “you” and “your” refer to you as a visitor or registered user of the Platform (defined below); “consumer” shall mean California consumers as defined in the CCPA.
This Disclosure describes the types of information we collect from you or that you may provide when you:
- Visit our website available at: neograf.com as well as any websites and blogs directly owned by the Company where this Disclosure is linked (collectively, our “Website”); and
- Use our mobile applications and any other applications directly owned by, or operated by or on behalf of, the Company and where this Disclosure is linked (the “Applications”, and together with the Website, the “Platform”).
PRIVACY POLICY; TERMS OF USE; DISCLAIMERS
This Disclosure is incorporated by reference and should be read in conjunction with the Company’s (1) Privacy Policy and (2) Terms of Use.
PERSONAL INFORMATION WE COLLECT
To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Disclosure. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). We may collect the following categories of Personal Information from visitors and users of the Platform. Additionally, the “Disclosed” column below details what categories of Personal Information have been disclosed in the past 12 months and to which category of third parties.
| Category | Examples | Collected | Disclosed |
| Identifiers. | A first and last name, Internet Protocol address, email address, telephone number. | YES | YES –
Service Providers |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A first and last name, address, telephone number.
Some information in this category may overlap with other categories. |
YES | YES –
Service Providers. |
| Protected classification characteristics. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO | N/A |
| Commercial information. | Your company’s name and address. | YES | YES –
Service Providers |
| Sensitive Personal Information | Precise geolocation, Social Security number, driver’s license, state identification card, passport number, account log-in, financial account, debit card, credit card number with security, or access code or password, racial or ethnic origin, religious/philosophical beliefs, or union membership, genetic data and processing of biometric information, health and sexual orientation. | NO | N/A |
| Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | N/A |
| Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES | YES –
Service Providers. |
| Geolocation data. | Physical location or movements. | NO | N/A |
| Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | N/A |
| Professional or employment-related information. | Current or past job history or performance evaluations. | NO | N/A |
| Non-public education information. | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | N/A |
| Inferences drawn from other Personal Information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | N/A |
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, when you:
- subscribe to one of our e-newsletters;
- review or comment on one of our products; or
- otherwise communicate with us, such as contacting us for more information.
- Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
- Directly and indirectly from activity on the Platform. For example, from Platform usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” in the Privacy Policy.
USE OF PERSONAL INFORMATION
We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose. For information about what categories of Personal Information are disclosed by the Company and to which third parties, please see the “PERSONAL INFORMATION WE COLLECT” section above and the “HOW WE DISCLOSE YOUR INFORMATION” section of our Privacy Policy.
Duration. The length of time Company intends to retain each category of Personal Information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.
YOUR RIGHTS AS A CALIFORNIA CONSUMER
Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
Do Not Track Signals. Other than as disclosed in this Disclosure, the Website does not operate any differently when it receives Do Not Track signals from your internet web browser.
WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the CCPA, we will update you via this Disclosure and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.
Consumer Rights. If you are a California consumer, as defined by the CCPA, you may be afforded additional rights with respect to your Personal Information. Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.
- Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
- Correction. You can correct what personal data the Platform database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.
- Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Disclosure
- Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
- Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
- Non-Discrimination. If a California consumer exercises his or her rights under the CCPA, we shall not discriminate against that consumer by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
- Exercising your rights. If you are California consumer who chooses to exercise the rights listed above, you can:
- Submit a request via email at info@neograf.com; or
- Call us at 800-253-8003 to submit your request.
Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.
Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
CHANGES TO THIS DISCLOSURE
This Disclosure may be amended from time to time and we shall post the revised Disclosure on the Platform. Changes will be effective upon posting.
CONTACT US
We value your opinions and welcome your feedback. To contact us about this Disclosure or your Personal Information, please contact us at:
NeoGraf Solutions, LLC
11709 Madison Avenue
Lakewood, OH 44107 U.S.A.
ATTN: General Counsel
Email: info@neograf.com
Form: https://neograf.com/contact/
