Additional California Privacy Disclosures
Effective Date: January 1, 2020
These Additional California Privacy Disclosures supplement the information contained in the CDW Privacy Notice. These Disclosures apply solely to our processing of personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (CCPA).
Unless otherwise expressly stated, all terms in these Disclosures have the same meaning as defined in our Privacy Notice as otherwise defined in the CCPA.
Personal Information Disclosures
When we use the term “personal information” in these Disclosures, we mean 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. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or linked to you.
In the last 12 months, we have collected the following categories of personal information:
- Identifiers, such as name, account ID, customer ID, social media handle and username/password.
- California Customer Records (Cal. Civ. Code § 1798.80(e)), such as mailing address, phone number, and payment information.
- Commercial Information, such as order details, order/product preferences, credit information, and investment information.
- Internet/Network Information, such as log file data (e.g., IP address, browser type, clickstream data) and cookies and related technology data (e.g., your usage and activity on our online services).
- Geolocation Data, such as your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.
- Sensory Information, such as voice recordings from calls.
- Profession/Employment Information, such as your job title, department, employer or business, and, if you perform work on our behalf, information obtained from your resume and your drug or background check (if any).
- Other Personal Information, such as your attendance at an event, your responses to survey questions about your business and your satisfaction with CDW, your statements and submissions for entry in a contest, social media account information in accordance with your settings on the social media site, user-generated content (to the extent that it is personal information) and the contents of your email, text or chat with us.
- Inferences, such as order/product preferences and likelihood to purchase.
We disclose all the categories of personal information described above for our business purposes. We do not “sell” personal information as most people would typically understand that term. However, as is common practice among companies that operate online, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” of personal information under the CCPA, please refer to our Cookie Notice for more information, including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.
The right to access and obtain a copy of the specific pieces of personal information we have collected about you in the last 12 months.
The right to direct us not to sell personal information we have collected about you to third parties.
The right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The right to request the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
- The categories of personal information we have collected about you;
- The categories of sources of the personal information we have collected about you;
- The categories of personal information we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
- The business or commercial purposes for collecting or, if applicable, selling personal information about you.
If you have an established customer relationship with us for personal, family, or household purposes, you may also have the right under California’s “Shine the Light” law to request:
- A list of the categories of certain personal information that we have disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes; and
- The names and addresses of all such third parties.
The right not to recieve discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
To submit a request to exercise your right to access, knowledge or deletion, please contact us as set forth in the How to Contact Us section below, by calling 847.419.6160, or filling out our Rights Request Form. If you wish to submit a request to exercise your right to additional information under California's "Shine the Light" law, please indicate in the request you would like to exercise your right under the "Shine the Light" law.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful authentication of your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you.
In certain circumstances, we may decline a request to exercise the right to access, knowledge or deletion, particularly where we are unable to verify your identity.
To Exercise Your Right to Opt Out of Personal Information Sales
As noted above, we do not "sell" personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a "sale" under the CCPA, please see our Cookie Notice for more information, including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.
Changes to These Disclosures
We may update these Disclosures from time to time. When we make changes to these Disclosures, we will change the date at the beginning of these Disclosures to include the "Last Updated" date. If we make material changes to these Disclosures, we will notify you by email to your registered email address, by prominent posting on our services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
How to Contact Us
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to firstname.lastname@example.org.
Alternatively, inquiries may be addressed to:
Global Compliance & Ethics
75 Tri-State International
Lincolnshire, IL 60069