CALIFORNIA CONSUMER PRIVACY POLICY

Effective Date: January 1, 2020

Notice to California Residents – Your California Privacy Rights

[Supplement to the Privacy Notice on John Middleton corporate website]

 

This California Consumer Privacy Policy supplements the privacy notice on John Middleton corporate website and mobile applications and applies solely to individuals who are California residents.

This California Consumer Privacy Policy uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018.

 

1. Notice of Collection and Use of Personal Information


We may collect the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, and similar technology; and other forms of persistent or probabilistic identifiers), internet protocol address, email address, and other similar identifiers
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
 

We may use the categories of personal information listed above for certain business or commercial purposes, as described in this table:

Purpose Categories of Personal Information
Better understanding how visitors use the John Middleton Corporate Website Identifiers and Online Activity
Enhancing the online experience of our visitors Identifiers and Online Activity
Providing you information about John Middleton Identifiers
Performing services, including analytics services or other similar services Identifiers and Online Activity
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Identifiers
Debugging to identify and repair errors that impair existing intended functionality Identifiers and Online Activity

2. Our Prior Collection, Use and Disclosure of Personal Information


We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Policy. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Category of Source of Data Collection Categories of Personal Information
From you and your device, for example, through your use of the website, when you send us an email, or otherwise visit, contact or communicate with us Identifiers; and Online Activity

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Category of Third Party Categories of Personal Information
Our affiliates such as those found at the following link: https://www.johnmiddletonco.com/ Identifiers and Online Activity
Vendors, consultants and advisors who provide services on our behalf Identifiers; and Online Activity
Data analytics providers Identifiers; and Online Activity
Acquiring/merging entity, in the event of a sale or transfer of all or a portion of our business or assets Identifiers
Government entities, including regulatory agencies and law enforcement Identifiers; and Online Activity

c. Sale of Personal Information

johnmiddletonco.com does not sell your personal information.

We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual's age.

d. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose:

  • All the categories of personal information about you described in Section 1 above.

 

3. California Consumer Privacy Rights


You have certain choices regarding our use and disclosure of your personal information, as described below.

Rights Under the California Consumer Privacy Act of 2018

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

How to Submit a Request: If you would like to make a request given your relationship with a John Middleton brand please visit the relevant brand website and submit your request through that process (Example: www.marlboro.com CCPA Brand Policy Link).

To submit an access, deletion, or opt-out request, please send us an email at JMCPrivacyStatement@consumerconnectioncenter.com with your first name and a phone number at which we may reach you or call 1-800-787-6700. Indicate that you are a California resident making a "California Consumer Privacy Act" inquiry.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request to access or delete your personal information, we may require you to provide information such as: address, birth day and month, and birth year. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion, or opt-out of sale request on your behalf, we may require you to provide the authorized agent written permission to do so, and, for access and deletion requests, we may also require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the California Consumer Privacy Act, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

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