CALIFORNIA PRIVACY POLICY
Last modified: October 6, 2023
Privacy Policy Clause: Description of Consumer Rights
  1. Your Rights. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

    1. Disclosure of Personal Information We Collect About You. You have the right to know:
      • The categories of personal information we have collected about you;
      • The categories of sources from which the personal information is collected;
      • Our business or commercial purpose for collecting or selling personal information;
      • The categories of third parties with whom we share personal information, if any; and
      • The specific pieces of personal information we have collected about you.
      • Please note that we are not required to:
      • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
      • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
      • Provide the personal information to you more than twice in a 12-month period.


    2. Disclosure of Personal Information Used for a Business Purpose. In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:
      • The categories of personal information that we disclosed about you for a business purpose.


    3. Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
      • Delete your personal information from our records; and
      • Direct any service providers to delete your personal information from their records.
      • Please note that we may not delete your personal information if it is necessary to:
      • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
      • Debug to identify and repair errors that impair existing intended functionality;
      • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
      • Comply with the California Electronic Communications Privacy Act;
      • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
      • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
      • Comply with an existing legal obligation; or
      • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.


    4. Protection Against Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
      • Deny goods or services to you;
      • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
      • Provide a different level or quality of goods or services to you; or
      • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
      • Please note that we may charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to us by your personal information.
    5. Shine the Light. California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

    6. Privacy Policy Clause: Disclosure of Personal Information Collected

  1. Information We Collect About You. We may collect and use personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. During the past 12 months, we have collected the following categories of personal information:

  2. Categories of Personal Information Collected? Categories of Third Parties Disclosure
    dentifiers (e.g., 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) Yes Our affiliates, partner, or subsidiary organizations; payment processor service provider; internet service provider; attorneys, accountants, and auditors; credit bureaus and similar organizations, law enforcement, government agencies, or government officials to fulfill legal, reporting, regulatory requirements*
    Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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. Yes Our affiliates, partner, or subsidiary organizations; payment processor service provider; internet service provider; attorneys, accountants, and auditors; credit bureaus and similar organizations, law enforcement, government agencies, or government officials to fulfill legal, reporting, regulatory requirements*
    Characteristics of protected classifications under California or federal law. Yes Our affiliates, partner, or subsidiary organizations; internet service provider; attorneys, accountants, and auditors; credit bureaus and similar organizations, law enforcement, government agencies, or government officials to fulfill legal, reporting, regulatory requirements*
    Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) Yes Our affiliates, partner, or subsidiary organizations; payment processor service provider; internet service provider; attorneys, accountants, and auditors; credit bureaus and similar organizations, law enforcement, government agencies, or government officials to fulfill legal, reporting, regulatory requirements*
    Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) Yes Our affiliates, partner, or subsidiary organizations; internet service provider; attorneys, accountants, and auditors; credit bureaus and similar organizations, law enforcement, government agencies, or government officials to fulfill legal, reporting, regulatory requirements*
    Professional or employment-related information Yes Our affiliates, partner, or subsidiary organizations; payroll processor service provider; attorneys, accountants, and auditors; credit bureaus and similar organizations, law enforcement, government agencies, or government officials to fulfill legal, reporting, regulatory requirements*
    Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes No N/A
    *We reserve the right to release information if we are required to do so by law, or if in our business judgment, such disclosure is reasonably necessary to comply with any court order, law, or legal process, in a fraud investigation, an audit, or examination.

  3. How Your Personal Information Is Collected. We collect most of this personal information directly from you in person, by telephone, fax, email, or via our website. However, we may also collect information:
    • from publicly accessible sources (e.g., property records);
    • directly from a third party, e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers;
    • from a third party with your consent (e.g., your bank);
    • from cookies on our website; and
    • via our IT systems, including:
      • automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.


  4. Why We Use Your Personal Information. We use your personal information for the following business purposes:
    • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, auditing compliance with this specification and other standards;
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
    • Debugging to identify and repair errors that impair existing intended functionality;
    • Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
    • Performing services including providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, or providing advertising or marketing services,


  5. Who We Disclose Your Personal Information to. We may disclose personal information for our business purposes to:
    • our affiliates, including companies within the Primus Pipe & Tube group;
    • service providers we use to help deliver our products to you, such as payment service providers, warehouses and delivery companies;
    • other third parties we use to help us run our business, such as website hosts;
    • credit reporting agencies;
    • our insurers and brokers; and
    • our banks

    We do not sell or share, as those terms are defined by the CCPA, your personal information to any third party.

  6. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:
  7. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

    Please note that you may only make a request to know twice within a 12-month period.

  8. Verifying Your Identity. If you choose to contact directly by email or phone, you will need to provide us with:
    • Sufficient information to allow us to reasonably verify you are the person about whom we collected personal information, which may include: [(e.g., your full name, address and customer or matter reference number))];
    • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
    • A description of what right you want to exercise and the information to which your request relates that allows us to properly understand, evaluate and respond to.

    We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

    Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

    You do not need to create an account with us to submit a request to know or delete your personal information.

  9. Response Timing and Format. We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten-day timeframe, please contact us at privacy@primuspipeandtube.com.
  10. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

    Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. 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.

    Privacy Policy Clause Notice of the Right to Opt-Out of the Disclosure of Personal Information

  11. Notice Regarding the Use of Your Personal Information for a Business Purpose. We may disclose to a third party personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

    You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information.


  12. How to Exercise Your Right to Opt-Out of the Disclosure of Personal Information to a Third Party. To opt-out of the disclosure of your personal information, contact us at privacy@primuspipeandtube.com.

CALIFORNIA DO-NOT-TRACK DISCLOSURE. Do Not Track is a privacy preference that Users can set in their web browsers. When a User turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the User. For information about Do Not Track, visit www.allaboutdnt.org. At this time, Company does not respond to Do Not Track browser settings or signals. In addition, Company may use other technology that is standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to www.primuspipeandtube.com or one of the affiliated pages hosted at the www.primuspipeandtube.com domain. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

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