Updated: June 14, 2023
If you are a California resident, please review this CA Privacy Statement for disclosures required by the CCPA, including our Notice at Collection and information surrounding how and why we collect, use, and disclose personal information and information about your potential rights under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law. Any terms defined in the CCPA have the same meaning when used in this notice. We are a “business.”
Notice at Collection and Use of Personal Information
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 or household (“personal information”).
Depending on how you interact with us, we may collect the following categories of personal information, including:
- Identifiers – Such as 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.
- Personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute) - This includes any 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.
- Demographic Information – Including, but not limited to, age or gender. This category includes pieces of personal information that also qualify as a protected classification characteristics under applicable laws.
- Commercial Information – Including, but not limited to, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or Network Activity – Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation Data – Such as physical location or movements.
- Professional or Employment-Related Information – Such as occupation, compensation, employer, and title.
- Audio, Electronic, or Visual Information – Including call and video recordings.
- Inferences – Including information about your interests and preferences.
- Sensitive Personal Information – Such as your passport number, driver’s license, and state identification card.
Personal information does not include:
- Publicly available information as defined under the CCPA.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope.
Use and Collection of Personal Information
We may collect or use personal information for one or more of the following purposes, such as:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in relation to a purchase, warranty submission, referral form, etc., we will use that information in conjunction with that specific purpose.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by litigation requirements, 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.
We do not sell or share personal information (as those terms are defined under the CCPA).
How Long We Keep Your Information
- We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any accounting, reporting requirements or legal requirements and consistent with applicable privacy, data protection and data retention laws. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
OUR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION AND SENSITIVE PERSONAL INFORMATION
Information We Have Collected
In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed above in Information We Collect.
Sources of Personal Information
We may obtain the categories of personal information listed above from the following categories of sources, such as:
- Directly from our customers related to their purchases of products or services and related warranties.
- Indirectly from our distributors or sales agents.
- Directly and indirectly from activity on our website (www.meppi.com), social media, or marketing efforts.
- From third-parties that interact with us in connection with the products we sell or services we perform.
Purposes for Collecting Personal Information
We may collect your personal information for the business or commercial purposes described above in Use and Collection of Personal Information.
Disclosure of Personal Information
We may disclose your personal information to a third party for a business purpose in compliance with the CCPA. In the preceding twelve (12) months, we may have disclosed for a business purpose, the categories of personal information to the categories of third parties described in the chart below, including :
Category of Personal Information
Category of Third Party Information Disclosed to for a Business Purpose
Identifiers (for example your name, address, DOB, SSN, driver’s license, passport number and online identifiers)
Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number, financial information, or bank account information)
Characteristics of protected classifications under certain federal or state laws (for example gender, age, national origin, citizenship or marital status)
Commercial Information (for example records of products or services purchased, obtained or considered or purchasing histories)
Geolocation Data (such as information about your location or the location of your device)
Professional or Employment Related Information, including occupation, compensation, employer and title
Internet or Electronic Network Activity Information, including interactions with our website or use of certain online tools
Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information
In the preceding twelve (12) months, we have not sold or shared any personal information. We do not knowingly sell or share personal information of consumers under 16 years of age.
In addition, we may disclose, and in the preceding 12 months, we may have disclosed all of the categories of personal information identified above in Information We Collect, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; (ii) any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets; and (iii) other third parties as may otherwise be permitted by law.
We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified in Use and Collection of Personal Information. Additionally, we may disclose your personal information to third parties upon your request, at your direction or with your consent.
We may also disclose or make available your personal information to our service providers or contractors such as our [IT providers, or CRM provider,] other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in. or as otherwise permitted by, the CCPA.
Our Use and Disclosure of Sensitive Personal Information
As noted above, under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers with specific rights regarding their personal information, subject to applicable exemptions and limitations. Specifically, consumers may have the right to:
- Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
- Not be discriminated against because you exercise any of your rights under the CCPA
- Request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”);
- Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not);
- Opt-out of the “sharing” (as that term is defined in the CCPA) of your personal if a business shares your personal information with third parties (we do not);
- Limit the use and disclosure of sensitive personal information (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit);
- Correct inaccurate personal information (“Right to Correct”); and
- Request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you certain information about such activities (“Request to Know”).
Below, we provide more detail on your CCPA rights and how to exercise those rights.
Right to Know Requests
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, we will disclose the following to you, unless a limitation or exception applies:
- The categories of personal information we collected about you.
- The categories of sources from which personal information is collected about you.
- Our business or commercial purpose for collecting, selling, or sharing that personal information.
- The categories of third parties to whom the business discloses personal information.
- The specific pieces of personal information we have collected about you.
Right to Delete Requests
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, we will 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 conduct certain activities, including:
- 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 contract with you.
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes. 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 (Cal. Penal Code § 1546 seq.).
- 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 solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which the consumer provided the information.
- Comply with a legal obligation.
Right to Correct Requests
You have the right to request that we correct inaccurate personal information that we maintain about you. In reviewing your request, we will take steps to determine the accuracy of the personal information that is subject to your Request to Correct, and, as permitted by law, may deny your request in certain circumstances.
Right to Limit the Use and Disclosure of Sensitive Personal Information
Under certain circumstances, you may have the Right to Limit our use and disclosure of your sensitive personal information. As noted above, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
We will not discriminate against you for exercising any of your CCPA rights, unless otherwise permitted by the CCPA.
Exercising Consumer Rights
To exercise the consumer rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 1 (866) 390-6487.
- Writing us at the address noted below.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information twice within a twelve-month period.
We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request. Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, phone number and email address, and we may require you to discuss the request with us over the phone. This measure is in place to help ensure that personal information is not disclosed to any person who does not have the right to receive it.
- 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. 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 endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
OTHER CALIFORNIA RIGHTS
Shine the Light
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are disclosed to third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. You have the right to ask us one time each year if we have disclosed personal information (as defined under the Shine the Light law) to third parties for their direct marketing purposes.
Do Not Track
We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.
Changes to Our CA Privacy Statement
We reserve the right to amend this CA Privacy Statement at our discretion and at any time.
This CA Privacy Statement is available in alternative formats upon request. If you have any questions or comments about this notice, this CA Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or to request this CA Privacy Statement in an alternative format, please do not hesitate to contact us by:
- Calling us at 1 (866) 390-6487.
- Writing to us at:
Mitsubishi Electric Power Products Inc.
530 Keystone Drive
Warrendale, PA 15086