California Privacy Notice

Last updated [9-1-2022]

Thank you for your interest in Thumbies, LLC (“Thumbies”, "Company", "we", "us", "our") products and services. We are committed to protecting your Personal Information. This California Privacy Notice ("California Notice") supplements our Privacy Policy and provides additional information for California residents on their privacy rights under California law, including the California Consumer Protection Act (CCPA), California Online Privacy Protection Act (CalOPPA) and California Shine the Light law.

When you use our Website or Mobile Application ("Mobile App") and more generally, any other webpages, software, applications, products, content, data feeds and other services on which an authorized link to this Privacy Policy is posted (collectively, the “Services”). In particular, our Services include allowing people through our Website or Mobile App to design, create and purchase custom jewelry or keepsakes with a fingerprints, handprints, footprints, handwriting, soundwaves/voice/audio information, pet prints or other image imprinted onto it.

If you have any questions or concerns about this privacy notice, or our practices with regards to your Personal Information, please contact us at customercare@thumbies.com.

1. CATEGORIES OF PERSONAL INFORMATION COLLECTED

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 person or their household or devices (“Personal Information”). Personal information does not include: information publicly available from government records; de-identified or aggregated consumer information; or information excluded from the scope of CCPA, CalOPPA and other California laws.

In the past twelve (12) months, we have collected one or more pieces of personal information that falls into the following categories:

2. USE OF PERSONAL INFORMATION

The information, including Personal Information, you directly provide and we collect may be used for following business purposes:

• To create and allow access to accounts
• Register, maintain, and provide notifications to you about your account through our Website or Mobile App.
• Fulfill or meet the reason your information was collected or provided, including providing of products or Services.
• To quickly process orders and ship products.
• To allow us to better service you in responding to your customer service requests.
• Allow you to participate in interactive features on our account through our Website and/or Mobile App with Thumbies, including designing products or Services.
• To send periodic emails regarding your order or other products or Services.
• Deliver communications, information or services, and promotions.
• To administer a contest, promotion, survey or other site feature.
• Provide support to you and other users.
• Present, optimize, and maintain the security of our Website, Mobile App and their contents.
• Personalize your Website experience and to deliver content, product and service offerings relevant to your interests, including targeted offers through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• Improve our products, Services, Websites, Mobile App, marketing emails and notifications
• Detect and prevent fraud or other crimes.
• Respond to law enforcement requests and as required by applicable law or court order.

3. SHARING OF INFORMATION

Thumbies has not and does not sell your Personal Information in the past twelve (12) months. For the purposes of this disclosure, "sell” does NOT include you designing and/or purchasing Thumbies products.

We have shared the following categories of personal information with Thumbies employees with a business need to know, our Partners, Service Providers and other third parties with which you have agreed we can share your information, in the past twelve (12) months:

• Identifiers
• Personal Information and Customer Records
• Commercial information
• Internet or other network activity
• Inferences drawn from personal information

If you would like additional information about the kinds of information we collect and how we use it, please see the chart above. Additionally, you may contact us at customercare@thumbies.com.

4. VERIFIABLE CONSUMER REQUESTS

A. Verifiable Consumer Requests for Access to Information and Data Portability

As a California resident, you can submit a verifiable consumer request for the personal information we have collected and retained about you ("Request for Customer Information"), portability of the data, and additional information about our collection, use and/or disclosure of information identified in our Privacy Policy and California Privacy Policy, including the following:

• Categories of personal information we collected about you over the past twelve (12) months;
• Categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting the personal information;
• Categories of personal information, if any, that we have disclosed to third parties;
• For each category of personal information identified, the categories of third parties with whom we share that personal information;
• Certain, specific pieces of personal information we collected about you; or
• If we sold or disclosed your personal information for a business purpose.

Once we receive a Request for Customer Information and are able to verify the authority of the person requesting it we will process the request and provide responsive information. If there is a delay and it is taking longer than expected, we will let you know the reason for delay and anticipated response time.

For data portability requests, we will select a format by which to provide your personal information that is readily useable and should allow you to send the information from one entity to another entity without problems.

B. Verifiable Consumer Requests to Modify or Delete Personal Information

As a California resident, you can also submit a verifiable consumer request that we delete the personal information we have collected and retained about you ("Requests to Delete"). After a Request to Delete is submitted and your identity is verified, we will review it and advise whether we need any additional information and if not will provide a response to your Request to Delete.

In responding, we will let you know whether or not we are able to comply with your request. If we are not able to grant your request we will explain the reasons we cannot grant the request. If we are only able to comply with part of your request, we will let you know the portions with which we cannot comply and explain why. In particular, it is important to understand that while we may be able to grant your Request to Delete with certain personal information, we may deny your request, if the information we are otherwise required by law to retain such information, it is necessary to provide products to you, or is necessary we retain for business reasons or functions, which may include the following:

• To maintain your Account and to provide information regarding past transactions, purchases and ability to create and/or purchase other products and Services.
• Billing information and transaction histories may be retained to resolve subsequent billing disputes and inquiries.
• Complete the order/transaction for which the personal information was collected.
• Account history may be retained to support subsequent customer service inquiries and to provide, improve and develop Services.
• To promote safety and security on the Service – and detect security incidents.
• Fulfilling the terms of a written warranty or product recall conducted in accordance with federal law.
• To resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with our legal obligations.
• Comply with applicable state and federal law, including but not limited to the CCPA, CalOPPA and California Electronic Communications Privacy Act

Once Thumbies grants a Request to Delete, we will delete your personal information from our records and direct any Partners or Services Providers to also delete your personal information by permanently and completely erasing the personal information on our systems; de-identifying the personal information; and/or, aggregating the personal information. If your personal information is stored on archived or backup systems, we may delay compliance with your request with respect to that data until it is restored.

C. Verifiable Consumer Request Submission, Response Timing and Format

When submitting a verifiable consumer request (e.g. Request for Customer Information and/or Request to Delete), you must provide sufficient information to allow us to reasonably verify that you are the person about whom we collected or were provided personal information or that you are the authorized legal representative of that person. Additionally, your request must provide sufficient details to allow us to understand what you are requesting in order to evaluate it and respond. Information provided to verify the identity or authority of an individual to make the request will be deleted after we have processed your request, except as required by law.

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. If you have an account with us, we will deliver our written response to that account or email used to set up 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.

5. NON-DISCRIMINATION

We will not discriminate or retaliate against you for exercising any of your rights under California law, including the CCPA. Unless permitted by law, we will not: deny you goods or services; charge you different prices or rates; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate or a different level or quality of goods or services.

We may offer 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.

6. OTHER CALIFORNIA RESIDENT PRIVACY RIGHTS

Under California’s “Shine the Light” law in Civil Code Section 1798.83, residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at customercare@thumbies.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by California law. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

7. DO NOT TRACK FEATURES

Some web browsers, mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting that you can activate to signal you do not wish to have data about your online browsing activities tracked. As there is no uniform technology standard or common understanding on how to recognize, interpret and respond to DNT signals, we do not currently respond to DNT signals. We will continue to monitor the technology and legal requirements regarding the understanding and recognition of how to treat DNT signals. In the meantime, you can use the information and methods that we have described above to control data collection and use, including the ability to opt-out of receiving marketing or advertising from us. If there is a change in our policy regarding this we will issue a revised version of this Privacy Notice.

For more information on "do not track", please visit www.allaboutdnt.org.

8. CHANGES TO CALIFORNIA PRIVACY POLICY

We may modify our Privacy Notice and/or California Privacy Notice, from time to time. The most current version of our Privacy Notice and California Privacy Notice, which governs our use of your information will be located at https://thumbies.com/privacy/ and [https://thumbies.com/privacy/California]. You may contact us to obtain prior versions.

If we make material changes to the Privacy Notice and/or California Privacy Notice, we may notify you of those changes by posting a notice at the Website and/or by emailing you at an email address associated with your Account, if applicable, and provide an “at a glance” overview of any changes.

Your purchase of products and/or continued use of our Website, Mobile App and/or Services, will be deemed your consent to the terms of the revised Privacy Notice and California Privacy Notice.

9. CONTACTING THUMBIES

If you have questions or comments about this notice or how we collect and use your personal information, or would like to submit a verifiable consumer request (e.g. Request for Customer Information and/or Request to Delete) you may email us at customercare@thumbies.com or by mail to:

Thumbies, LLC
11701 Catalpa Lane
Woodstock, IL 60098
United States
877-848-6243
customercare@thumbies.com