STANLEY STEEMER INTERNATIONAL, INC.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

EFFECTIVE DATE: January 1, 2020

LAST REVIEWED: January 6, 2020

INTRODUCTION

This Privacy Notice for California Residents supplements the information contained in Stanley Steemer International, Inc.'s Privacy Policy and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

INFORMATION WE COLLECT

We collect 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 consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category: A. Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Collected: YES


Category: B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Collected: YES


Category: C. Protected classification characteristics under California or federal law.

Examples: 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).

Collected: NO


Category: D. Commercial information.

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected: YES


Category: E. Biometric information.

Examples: 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.

Collected: NO


Category: F. Internet or other similar network activity.

Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Collected: YES


Category: G. Geolocation data.

Examples: Physical location or movements.

Collected: YES


Category: H. Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: YES


Category: I. Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: NO


Category: J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: 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.

Collected: NO


Category: K. Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: YES


HOW WE COLLECT INFORMATION

Information You Manually Provide

We collect information you provide directly via the Website, our National Customer Contact Center and/or our Business Applications. The information we collect includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly, or indirectly to you. The categories of information we collect may include the following:

  • Contact Data. We collect your first and last name, postal address, email address, and telephone number.
  • Account Credentials. We collect passwords and other information for authentication and account access.
  • Payment Data. We collect data necessary to process your payment if you make a purchase, including your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
  • Order Information. We collect information about your orders and the products and services you choose.
  • Profile Data. We may collect your interests, favorites, and preferences.
  • Content. We collect the content of messages you send to us, such as feedback and product reviews you may write, or questions and information you provide to customer support.

We collect information you provide at various points throughout your interactions with us, such as the following:

  • Account Registration. To register an account with Stanley Steemer, you will be required to fill out a registration form on the Website. This form requires you to provide your contact data and account credentials. You may also provide additional profile data to help speed up and facilitate your future orders.
  • Online Orders. You can place an online order through your registered account or as a guest. If you place an online order, you will need to provide your first name and last name, email address, telephone number, service or delivery address and order information. If you pay online, you will also need to provide your payment data.
  • Other Transactions. We may offer you other opportunities to transact with us through the Website, our National Customer Contact Center and/or our Business Applications. If you conduct transactions through the Website or our National Customer Contact Center, we will collect information you provide directly about the transactions you engage in while on the Website or our National Customer Contact Center (including any data gathered through the Website and when you communicate with us through our National Customer Contact Center). This information may include payment and billing information as well as the nature, quantity and price of the goods or services you exchange, audio recording and/or transcripts of your communications with our National Customer Contact Center, and the individuals or entities with whom you communicate or transact business.
  • Email and Other Voluntary Communications. You may also choose to communicate with us through email, our Website, our National Customer Contact Center or through other means. Such communications may be in connection with our customer service efforts, your questions, or for other purposes. We collect the information in these communications, and such information may include information that personally identifies you.

You may choose to voluntarily disclose other information when using our Website or interacting with our National Customer Contact Center that we do not request, and, in such instances, you are solely responsible for such information.

Information Collected Automatically

When you visit our Website, we automatically collect information about your device and how your device interacts with our Website or our National Customer Contact Center.

The categories of information we collect may include the following:

  • Service Use Data. We collect data about the features and services you use, the emails and advertisements you view, the products and services you consider and purchase, the date and time you access the Website or contact our National Customer Contact Center, the pages you access while using the Website, and the internet address of the websites, if any, from which you linked directly to the Website or our National Customer Contact Center, and other similar information.
  • Device Connectivity and Configuration Data. We collect data about the type of device you use, the operating system and browser you use, your internet service provider, your device's regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising ID (e.g., IDFA or AAID), and other device identifiers.
  • Location Data. We may collect data about your device's location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level). For example, we may collect precise location through the Website to direct your inquiries to the appropriate Stanley Steemer franchisee.

We use cookies and other tracking technologies now and hereafter developed to automatically collect this information, including the following:

  • Log Files. A log file is a file that records events that occur in connection with your use of the Websites and Business Applications, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data.
  • Cookies. Our servers, or the servers of Stanley Steemer franchisee or other entities, may place a "cookie" on your device, store data in your device's browser or access pre-existing removable tracking features on your device in order to allow you to use our Website and to personalize your experience. A "cookie" is a small piece of data that can be sent by a web server to your device, which then may be stored by your browser on your device's hard drive. Cookies and browser storage allow us to recognize your device while you are on our Website and help customize your online experience and support security features. Cookies and browser storage are also useful in allowing more efficient log-in for users, tracking transaction histories and preserving information between sessions. The information collected from cookies and browser storage may also be used to improve the functionality of our Website, analyze your use of our Website, or to deliver advertising regarding Stanley Steemer products and/or services to you. To learn more about how we use cookies, please visit the "Your Rights and Choices" section below. Types of cookies and tags on our Website include:
    • Functionality: Used to remember your preferences and for facilitating transactions such as purchases or the scheduling of services.
    • Performance or Analytics: Used to measure site activity to improve user experience.
    • Targeting: Used to display information and offers that specifically interest you.
  • Local Storage. We use Local Storage, such as HTML5 storage, to store information related to whether the user has chosen to "Remain Logged In" as well as tokens if other services are used. We may partner with other entities to provide certain features on our Website or to display advertising based upon your web browsing activity use Local Storage such as HTML 5 storage to collect and store information. Various browsers may offer their own management tools for removing HTML5 Local Storage.
  • Web Beacons ("Tracking Pixels"). Web Beacons are pieces of code embedded in a website, video, email or advertisement that send information about your use to a server. There are various types of web beacons, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or another party to drop or read cookies on your browser. Web beacons are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate Web Beacons to allow us to track conversions, bring you advertising both on and off tour Website, and provide you with additional functionality, such as the ability to connect our Websites with your social media account(s).
  • Location-Identifying Technologies. GPS (global positioning systems) software, geo-filtering, and other location-aware technologies may locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your geographic location.
  • Voice Processing Technologies. Voice processing technologies record your interactions with our National Customer Contact Center and collect data to effectuate requests made by you. We maintain audio recording of your interactions with our National Customer Contact Center to complete your instructions or requests and to improve our delivery of products and services. In most circumstances, such audio recordings are destroyed with forty-five (45) of their creation. We may use non-audio data associated with the collection for additional purposes such as data analytics and otherwise in accordance with this Privacy Policy.
  • Device Fingerprinting. Device fingerprinting is the process of analyzing and combining sets of information elements from your device's browser, such as JavaScript objects and installed fonts, in order to create a "fingerprint" of your device and uniquely identify your device and applications.

We may incorporate tracking technologies into our emails, our Website, our Business Applications as well as into our advertisements. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you.

For further information on how we use tracking technologies for analytics and advertising and your rights and choices regarding them please see the sections entitled "Analytics, Advertising, and Retargeting" and "Your Rights and Choices" below.

Information Collected from Franchisees and Other Sources

We also may obtain information about you from other sources and may combine such information with information we have collected about you. The categories of other sources from which we may collect include the following:

  • Stanley Steemer Franchisees. Stanley Steemer Franchisees which are all independently owned and operated entities. We process information received from Stanley Steemer franchisees to provide these entities with services as well as for our own purposes in accordance with this Privacy Policy.
  • Social Networks. Social Networks when you reference our service or grant permission to Stanley Steemer to access your data on one or more of these services.
  • Business Partners. Our Business Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
  • Publicly-Available Sources. Publicly-Available Sources such as data in the public domain.

We are not responsible for the accuracy of any information provided by other sources or the data practices of other sources.

HOW WE USE YOUR INFORMATION.

Stanley Steemer collects and uses information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information may include the following:

  • 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 information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate scheduling and delivery. We may also save your information to facilitate new product orders or process return service visits.
  • operating and managing our Website, our National Customer Contact Center, and Business Applications such as providing you with products, services, and Promotions, opening, maintaining, administering and servicing users' accounts;
  • performing services requested by you, such as responding to your comments and requests, processing, servicing or enforcing transactions and sending related communications;
  • maintaining the security and integrity of our systems, and preventing and addressing fraud, unlawful access, and breach of our policies and terms;
  • sending you technical notices, updates, security alerts, information about our policy changes and administrative messages;
  • analyzing trends and usage, such as the efficiency of deliveries and store operations;
  • helping to establish and verify the identity of users;
  • improving our Website, National Customer Contact Center, Business Applications, stores, advertisements, products, Promotions and services;
  • sending you promotional newsletters, offers, advertisements and marketing communications and other information about Stanley Steemer and independently owned and operated Stanley Steemer franchisees;
  • sending and serving you advertising; and
  • fulfilling any other business or commercial purposes at your direction or with your consent.

Notwithstanding the above, we may use information that does not identify you (including aggregate information or information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled "Your Rights and Choices" below.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

  • Service Providers.
  • Vendors.
  • Affiliates.
  • Independently Owned and Operated Stanley Steemer Franchisees.
  • Business Partners.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: California Customer Records Personal Information Categories.
  • Category D: Commercial Information.
  • Category F: Internet or Similar Network Activity.
  • Category G: Geolocation Data.
  • Category H: Audio Data.
  • Category K: Inferences Drawn from Other Personal Information

Please see the “Disclosure of Information” section of our Privacy Policy for more detail regarding the categories of third parties we have shared information with.

Sales of Personal Information

Stanley Steemer does not generally sell information as the term "sell" is traditionally understood. As is common practice among business that operate websites and consolidated customer contact centers, we do share certain categories of information as set forth above about our customers with our social media, advertising and analytics partners. Therefore, to the extent that a "sale" under the CCPA is interpreted to include advertising technology activities such as those disclosed in the "Analytics, Advertising, and Retargeting" section of our Privacy Policy we will comply with the CCPA and other applicable law with respect to such activity.

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at 1-866-438-5321
  • E-mailing us at CCPARequests@stanleysteemer.com
  • Visiting our CCPA Rights Center.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice 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 information or an authorized representative, which may include: First and Last Name; Telephone Number; Location/Address of Last Service; and Date of Last Service.
  • 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 information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

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

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information 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.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
OTHER CALIFORNIA PRIVACY RIGHTS

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@steemer.com or write us at: 5800 Innovation Drive, Dublin, Ohio 43016.

CHANGES TO THIS PRIVACY POLICY

Stanley Steemer reserves the right to modify or supplement this policy at any time. If a material change to the terms of this policy is made, Stanley Steemer will post a notice prior to the change becoming effective on its homepage and a link to the new policy. Your continued use of our Website or our National Contact Center following the posting of changes constitutes your acceptance of such changes.

CONTACT US

If you have questions or comments about our Privacy Policy or this Privacy Notice for California Residents, the information practices of Stanley Steemer, or if you have a disability and would like to receive information on how to access our Privacy Policy or this Privacy Notice for California Residents in an alternative format please contact us:

Via Website: www.stanleysteemer.com/contact-us

Via Email: privacy@steemer.com

Via Regular Mail:
Stanley Steemer International, Inc.
Attn: Compliance Department
5800 Innovation Drive
Dublin, Ohio 43016