Privacy Notice for Connecticut Residents

Effective Date 1st June 2024

This Privacy Notice for Connecticut Residents (this “Privacy Notice”) is intended to supplement Prinova’s Privacy Policy and applies only to Connecticut residents. Any terms defined in the Prinova Privacy Policy have the same meaning when used in this Privacy Notice.

Pursuant to the Connecticut Data Privacy Act (“CTDPA”), Connecticut residents have the right to be informed about the data we collect about them. This Privacy Notice applies solely to natural persons who are Connecticut residents, as defined in the CTDPA. Please note that this Privacy Notice does not apply to Connecticut residents who are acting as employees or job applicants. Any terms defined in the CTDPA have the same meaning when used in this Privacy Notice.

The CTDPA defines “Personal Data” as “any information that is linked or reasonably linkable to an identified or identifiable individual.” Personal Data does not include de-identified data or publicly available data.

Below are the categories of Personal Data that we may have collected, used, and disclosed for a business purpose, as permitted by law, in the last twelve (12) months, depending on the products or services you receive:

We obtain the categories of Personal Data listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase;
• The internet sites of Prinova and its affiliates that you visit;
• The mobile applications of Prinova and its affiliates that you use;
•  You or your employer, such as via telephone, mail, email, or at trade shows, or in connection with potential employment or business opportunities;
• Our customers, vendors, and suppliers;
• Third parties from whom we purchase contact data, such as LinkedIn.

We may use or disclose the Personal Data we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Data to respond to your inquiry. If you provide your Personal Data to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• For employment-related matters including, but not limited to, employee onboarding, payroll, and employee benefits.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Data or as otherwise set forth in the CTDPA.

We may share your Personal Data in furtherance of the purposes described above.

We may share your Personal Data with a third party for a business purpose.  When we share Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Data for a business purpose:

Category A: Identifiers.

Category B: Personal information categories.

Category C: Personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

Category L: Some Sensitive Data as defined under Connecticut law and protected classification characteristics under Connecticut or federal law.

We share your Personal Data for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers (including, but not limited to, carriers and other logistics subcontractors, attorneys, accountants, IT service providers, payroll processors, and benefits providers).
• Third parties to whom you or your agents authorize us to disclose your Personal Data in connection with products or services we provide to you.

In the preceding twelve (12) months, Prinova had not sold any of your Personal Data.

Right to Confirm Processing and Access Personal Data

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data. The right does not apply if the confirmation or access requires the Prinova to reveal a trade secret. Those rights include:

• Confirming whether we process your Personal Data.
• Accessing your Personal Data (also called a data portability request).

Right to Deletion of Personal Data

You have the right to request that we correct inaccuracies in or delete any of your Personal Data that we collected from you and retained, 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 Data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Comply with legal obligations.
• Provide a product or service that you specifically requested, perform a contract with you, including fulfilling the terms of a written warranty, and to take steps at your request before entering into a contract.
• Protect an interest essential for the consumer or another individual’s life or physical safety when the entity cannot clearly rely on another legal processing basis and to process Personal Data for the public interest in the area of public health, community health, or population health, subject to suitable safeguard measures and under a professional subject to confidentiality obligations.
• Prevent, detect, protect against, respond to security incidents, identify theft, fraud, harassment, malicious or deceptive activities, or any illegal activity, preserve the integrity of security systems, and to investigate, report, or prosecute any parties responsible for those actions.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• For any other reason permitted by the CTDPA.

Right to Correct Inaccurate Personal Data

You have the right to correct inaccuracies in your Personal Data, considering the Personal Data’s nature and the processing purposes.

Right to Opt-out of Targeted Advertising, Sale of Personal Data, or Profiling

You have the right to opt out of the processing of Personal Data for the purposes of targeted advertising, the sale of Personal Data, or profiling in further of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal

If we deny your request to access, delete, correct, or opt-out, you have the right to appeal such decision by submitting your request to appeal here.

If your appeal is denied, you have the right to submit a complaint to the Connecticut Attorney General. To file a complaint with the Connecticut Attorney General, please visit: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.

Only you may make a verifiable consumer request related to your Personal Data. If you are the parent or legal guardian of a child, you may make a verifiable consumer request related to the Personal Data of that child. You may only make a verifiable consumer request for access or data portability once within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will confirm receipt of your request within 10 business days. We endeavor to substantively respond to a verifiable consumer request with 45 days of its receipt. If we require more time (up to 45 more days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our response to you via that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Disclosures will only cover the 12-month period preceding our receipt of your request. The response provided will also explain the reason we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

The right to be free from discriminatory treatment relating to the exercise of any of your privacy rights conferred by the CTDPA. We may, however, offer a different price, rate, level, or quality of goods or services if that price or difference is reasonably related to the value provided to us by your data.

We reserve the right to amend this Policy Notice at our discretion and at any time. When we make changes to this Policy Notice, we will post the updated notice on our website and update the Policy Notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this Policy Notice, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights under Connecticut law, please do not hesitate to contact us at:

Phone:  +1 (630) 868-0300

Website:  https://prinovaglobal.com

Email: privacy@prinovaglobal.com

Address:

Prinova Group LLC

Attn: Data Privacy Officer

300 Park Boulevard Suite 500

Itasca, IL 60143