dpHUE

California Supplemental Privacy Policy

Last Updated: June 30, 2023

This Supplemental Privacy Policy and Notice (“Supplemental Policy”) applies only to information collected about consumers residing in California (“consumer(s),” “Consumer(s),” “you,” “your”) and supplements the information contained in the general Privacy Policy. It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”).

This Supplemental Policy describes the practices of DMP COLOR LLC dba dpHUE, (“dpHUE,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information and provides instructions for submitting data subject requests.

If you are unable to review or access this Supplemental Policy due to a disability, you may contact dpHUE at info@dphue.com to access this Supplemental Policy in an alternative format.

Definitions Specific to this Policy

• “Consumer” means a natural person who resides in California and to whom we offer information, goods, or services. For purposes of this Supplemental Policy, this term includes natural persons who reside in California and engage with us as part of business-to-business transactions.
• “Personal Information” means 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. Personal Information also includes “Sensitive Personal Information,” as defined below.
• “Sensitive Personal Information” means Personal Information that reveals a Consumer’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 6) Union membership; 7) Contents of email or text messages, unless we are the intended recipient; 8) Genetic data; 9) Biometric information used to uniquely identify the Consumer, and 10) Health, sex life, or sexual orientation.
• “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.
• “Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for behavioral advertising purposes, whether or not for money or other valuable consideration.
• “Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the CCPA.
• “Vendor” means a “service provider,” “contractor,” or “processor” which collects, stores, or otherwise handles data for us, as those terms are defined in the CCPA.

These definitions apply, whether terms are capitalized or not. Other terms used in this Supplemental Policy may be defined under the CCPA, and they shall have the meanings described in that statute. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state.

The Personal Information We Collect and Disclose

The chart below shows the categories of personal information we may collect; examples of personal information in each category; types of sources from which each category of personal information is collected; the business purposes for which each category of personal information is collected; and the types of Vendors or Third parties with whom that category of personal information is shared. As this chart shows, we may [share or sell personal information to Third Parties or] disclose certain personal information to Vendors for business purposes.

 

 

Sensitive Personal Information We Collect and Disclose

 

 

Retention of Data

We intend to retain each category of personal information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average consumer’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.

Your Rights to Your Personal Information

California consumers have certain rights with respect to the collection and use of their personal information.. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California consumers.

You have the right to submit requests related to the personal information we have collected about you. You may make such a request twice in a 12-month span. Please note,  there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request or we may find that providing a full response conflicts with other legal obligations or regulatory requirements. We will notify you if this is the case.

Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:

• The categories of personal information to be collected;
• The purposes for which the categories of personal information are collected or used;
• Whether or not that personal information is sold or shared with Third Parties or disclosed to Vendors;
• If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
• The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by using the contact information provided below.

Right to Know and Right to Access. You have the right to request certain information we have collected about you. You have the right to request:

• Specific pieces and categories of personal information we collected about you;
• The categories of sources from which personal information was collected;
• The purposes for which personal information was collected, shared, sold, or processed;
• The categories of personal information we shared, sold or disclosed; and
• The categories of Vendors or Third Parties with whom we shared, sold or disclosed personal information.

Right to Delete. You have the right to request that we delete certain personal information that we have collected. 

Right to Correct. You have a right to request that we correct any inaccurate personal information we may retain about you.

Right to Opt-Out of the Sale and Sharing of Your Personal Information. You have the right to opt-out of the sale and sharing of your personal information with Third Parties, and the right to opt out of the processing of personal information for targeted advertising purposes, as defined in the CCPA. We share personal information, or process personal information for targeted advertising purposes. In the past 12 months, we have sold or shared the categories of consumer personal information as listed in this Supplemental Policy. As a consumer, you have the right to opt-out of the sale and/or sharing of your personal information and of the processing of personal information for the purpose of targeted advertising. To submit an opt-out request, please access the below link or follow the “Instructions to Exercise Your Rights,” below. We do not knowingly share personal information of consumers under 16 years of age.

“Do Not Share My Personal Information”

If you opt-out of the sale of your personal information, we will wait at least 12 months before asking you if we may sell or share your personal information.

You have the right to opt-in to the sale of your personal information after you have opted out. If you would like to opt-in to the sale or sharing of your personal information, please email us at info@dphue.com. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Right to Consent to or Limit the Use of Your Sensitive Personal Information. You have the right in CA to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average consumer or for specific business purposes defined by law.  However, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA, or beyond your consent.

Right to Non-discrimination. You have a right to exercise the above rights, and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests.

Instructions to Exercise your Rights. If you would like to make any of the data requests listed above, please click HERE. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. You may also submit a request by emailing us at info@dphue.com

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.

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Verification Process

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.

If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:

• Verify your identity with us directly.
• Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.

We may deny a request from an agent purportedly acting on your behalf if we request, and the agent does not submit, proof that he, she, or it has been authorized by you to act on your behalf.

Personal Information of Minors

Our online content is not intended for children or minors under the age of sixteen years. Accordingly, we do not knowingly store information from minors under the age of sixteen years, except as required by applicable law. If you believe that a child has submitted personal information to us, please contact us at info@dphue.com and we will delete the information.

Additional California Privacy Rights

Shine the Light Request. California Civil Code Section § 1798.83 permits users of our website who are California residents to request information about our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to info@dphue.com with the subject “Shine the Light Request.”

Changes to Our Supplemental Policy

dpHUE reserves the right to amend this Supplemental Policy at our discretion and at any time. When we make changes to this Supplemental Policy, we will post an updated policy on our website with a new Last Updated date.

Additional Information

If you would like additional information regarding our Supplemental Policy, please contact us at info@dphue.com.

DMP Color, LLC d/b/a dpHUE
250 Nicollet Mall, Suite 600
Minneapolis, MN 55401