Consumer Privacy Act (CCPA)
This section applies to any California residents about whom we have collected personal information from any source, including through your use of our Website(s), by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).
For purposes of this section, “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 California consumer/resident or household. Personal information does not include publicly available information or information that has been de-identified.
A. What Information We Collect
We may collect the following categories of personal information about you:
- Identifiers, which may include real name and alias; postal address; unique personal identifier; online identifiers as detailed below; Internet Protocol (“IP”) address; email address; telephone number; account number, name, and password; driver’s license number, state or other government-issued identification card number; MAC address; and/or other similar identifiers;
- Commercial information, which may include purchasing and transaction history online and in stores, or consumer histories or tendencies;
- Biometric information, which may include voice recognition information; facial scans; and/or other similar biometric identifiers;
- Information relating to Internet activity or other electronic network activity, which may include cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”), CPU ID and type, build, model, manufacturer, operating system version, screen size, screen resolution, mobile network status, device locale, and carrier ID;
- Geolocation data, which may include Global Positioning System (“GPS”) data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s) or vehicle(s);
- Audio, electronic, or visual information, which may include records of calls to or from our customer service centers; and/or video surveillance information;
- Professional or employment-related information, such as whether you are a MINI Health colleague;
- Inferences about you, such as household income level and demographic information; credit card types you may have; homeowner / renter status; interest in certain types of merchandise; coupon interaction data; transaction return history;
- Information not listed above and related to characteristics protected under California or federal law; which may include gender; race and ethnicity; language; religion; country of origin; marital status; military service / veteran status; and/or date of birth;
- Other personal information not listed above and described in California Civil Code § 1798.80(e), which may include signature; physical characteristics or description; and/or bank account number credit card number, debit card number, and other financial or health information).
B. What We Do With Your Information
We may collect or use personal information from you for the following purposes:
- Internal analytics
- Assessing third party vendors / service providers
- Audit, compliance, policy, procedures, or regulation
- Billing, payment, and fulfillment
- Customer claims and fraud investigation and prevention
- Customer communications
- Customer relationship management
- General business administration
- Marketing products and services
- Financial reporting and accounting
- Website optimization and maintenance
- Systems and data security
C. Sources of Collected Information
We may collect personal information from the following categories of sources:
- Our customers, and prospective customers, including via purchasing goods and services in our stores, our Websites, mobile applications, telephone, text message, postal mail, social media, forums, message boards, chatbots, or other means;
- Our parent, subsidiaries and affiliates;
- Our service providers, which includes affiliates, marketing / customer relationship management providers, social media, technology / website hosting providers, analytics providers, and systems administrators / security and fraud investigations providers;
- Third parties: Companies that collect publicly available information or business partners that collect information and provide to us pursuant to their privacy policies and terms of service.
D. Who We Share Information With
We do not sell personal information or otherwise provide personal information to third parties, other than service providers receiving information to perform services for us on our behalf.
As with other companies that conduct digital marketing, we do share a limited set of data that is gathered when you visit our Websites and other web-based services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements about our products and services. We may also share certain information to enhance our ability to communicate with you and provide you with promotional information. To the extent this activity is interpreted as included in California law’s broad definition of “data sale,” we have provided you with opt-out rights as to that activity as further described in Section G below.
We may share your personal information with the following categories of third parties:
- Advertising and marketing companies
- Social media companies
- Technology companies
We do not knowingly sell the personal information of minors under 16 years of age.
E. Your Privacy Rights
If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information.
- Right to Know. You have the right to request what personal information we collect, use, disclose, and/or sell, as applicable.
- Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by us.
- Right to Opt-Out of Sales. You have the right to opt-out of the sale of your personal information by us.
- Right to Non-Discrimination. We may not discriminate against you because you have exercised any of the privacy rights described above.
You may also authorize someone to exercise the above rights on your behalf. Documentation will need to be provided that reflects that you have requested an authorized agent to make a request on your behalf. This may include a Power of Attorney document or other signed document. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child.
We must be able to reasonably verify your identity and authority to exercise these rights before fulfilling a request. There are also various exclusions and exceptions that apply to these rights under applicable laws. So that we can verify your identity when you make a request, you will need to sign into your MINI.com account or provide certain personal information via webform or over the phone.
If you are a California resident and wish to seek to exercise these rights, please reach us in one of the following ways:
Right to Know / Right to Delete:
- Contacting us at 1-888-545-6464
- Submit a written request to: email@example.com See Section G for instructions on how to Opt-Out of Sale.
G. Notice of Right to Opt-Out of Sales
If you wish to opt-out of our sharing of the limited data that is gathered when you visit our Websites and other web-based services for purposes of targeted digital advertising, you may do so in one of the following ways:
- Contacting us at 1-888-545-6464
- Submit a written request to: firstname.lastname@example.org
Please note that the effectiveness of your opt-out request may be limited by our ability to associate the cookies and/or pixels that we may collect from your web session with your identity, browser, device, and/or browsing session. As a result, your opt-out request will be more effective for future visits to the Websites if you:
- Utilize the same device that was used to exercise the opt-out request;
- Have not cleared cookies from your web browser; and
- Are not using a private or “do not track” mode in your web browser;
- Provide the same personal information that you provided previously.
Deidentified Patient Information
In addition to personal information, we may sell or disclose patient and/or member information that has been deidentified as permitted by law. To the extent we sell or share such deidentified patient and/or member information, we do so pursuant to one of the deidentification methodologies described in Section 164.514(b)(1) or (b)(2) of Title 45 of the Code of Federal Regulations, commonly known as the HIPAA expert determination method and the HIPAA safe harbor method, respectively.
CCPA Reporting Metrics
California Shine the Light Law
- If you are our customer and a California resident, you may request that we provide you with certain information about the entities with which we have shared our customers’ personal information for the entities own direct marketing purposes during the preceding calendar year. To do so, please write to us at email@example.com .
If you have any questions or concerns about this statement, or about the way your information is collected and used, please contact us call us toll-free at (888) 545-6464.