California Privacy Notice

Effective Date: 6/28/21

This Notice supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California.

This Notice describes how we collect, use, disclose and otherwise process Personal Information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act, CCPA.

The term “Personal Information” in this Notice, relates to information that can reasonably be linked with a particular consumer, device, or household.

We do not sell Personal Information. We do, however, share and disclose it only for the purposes stated in this notice.

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

Category	Examples	Collected
A. Identifiers.	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
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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.	YES
C. Protected classification characteristics under California or federal law.	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
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. 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
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
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)).	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
K. Inferences drawn from other Personal Information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We may use, or disclose the Personal Information 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 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 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.
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 Information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our website users/consumers is among the assets transferred.

For additional details and examples of how your information is collected, used, and shared, please review our Privacy Policy.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, we have not sold personal information.

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	Mailing List Management Provider Advertising Network Fraud Prevention Data Analytics Provider Email Service Provider Sales Tax Manager Shipping Services Provider Customer Service	None
B: California Customer Records personal information categories.	Email Service Provider Shipping Services Provider Mailing List Management Provider Customer Service	None
C: Protected classification characteristics under California or federal law.	None	None
D. Commercial information.	Data Analytics Provider Shipping Services Provider Email Service Provider Mailing List Management Provider Customer Service	None
E. Biometric information.	None	None
F. Internet or other similar network activity.	Fraud Prevention Data Analytics Provider Shipping Services Provider Email Service Provider Mailing List Management Provider Customer Service	None
G. Geolocation data.	Data Analytics Provider	None
H. Sensory data.	None	None
I. Professional or employment-related information.	None	None
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)).	None	None
K. Inferences drawn from other Personal Information.	Data Analytics Provider Mailing List Management Provider	None

Reselling Personal Information

The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. The following businesses receive personal information from us for business purposes and may resell that information. To opt-out of those sales, please visit that business's opt-out notice at the link provided below.

Epsilon: https://us.epsilon.com/marketing-data-summary-request.
Infogroup: https://www.data-axle.com/do-not-sell-my-data/.

Your Privacy Rights

Right to Know and Data Portability

Under the California Consumer Privacy Act, CCPA, California residents 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 verify your request, we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources from which the Personal Information is collected.
The specific pieces of Personal Information we collected about you (also called a data portability request).
Our business or commercial purpose for collecting or selling any Personal Information.
The categories of third parties with whom we share that Personal Information.

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.

Right to Delete

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 your request and verify your identity, 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 providers to:

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, or otherwise perform our agreement with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights to Know or Delete

To exercise the rights described above, please submit a verifiable request to us by emailing us at [email protected] with CCPA Privacy in the subject line or by calling us toll-free at 800-503-9624.

Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. If you wish to authorize another to act on your behalf, please be advised that White Flower Farm may require that you provide the authorized agent with written permission to submit a request and verify your own identity directly with us, unless the authorized agent has a power of attorney.

Our verification process works as follows. Before we may process a request, in order to protect your privacy, we will ask you to confirm a few pieces of information that we have on our records about you, for example:

Your address
Your zip code
Your customer number or recent order number
Your email address

If your request is for deletion of Personal Information, we will need to re-verify your identity before we delete your information.

You may make a verifiable consumer request up to two times within a 12-month period, without charge. Unfortunately, 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 that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected].

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.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will cover only 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.

Non-Discrimination

White Flower Farm 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Whenever we offer a financial incentive program, we will provide you notice of the program terms before you opt in to the program. That notice will look something like this.

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 such third parties’ direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: White Flower Farm, P.O. Box 50, Litchfield, CT 06759, Re: Privacy Policy

Policy Changes

If we decide to change our policy in whole or in part, we will inform you by updating the date at the top of this policy. We encourage you to check regularly to see if our Privacy Policy has changed. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.