California Consumer Privacy Act (CCPA)
Effective Date: 16 Oct 2020
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Who Is Responsible For Processing Your Data
This Privacy Notice applies to personal data of California residents to the extent the data is subject to the California Consumer Privacy Act of 2018 (“CCPA”). This Privacy Notice describes the actions DNOW L.P. and its affiliates that are subject to the CCPA (together “DNOW”, “Company”, “we” or “us”), all of which are part of the NOW Inc. global group of companies (“NOW Group”), take to protect the personal data that we collect from California residents. DNOW is committed to the protection of personal data in line with the data protection principles set out in the CCPA.
If you are a website user or associated with a prospective customer or vendor, the data controller is DNOW L.P. and can be contacted at email@example.com or by calling our toll-free privacy number: 888-342-4934.
What Personal Data We Collect
We do not sell your personal data.
We may source, use and otherwise process your personal data in different ways. In all cases, we are committed to protecting the personal data we collect. We may obtain your personal data from the following sources:
- From you directly
- From a company that employs you, if you are an employee of one of our existing or potential customers or vendors
- From other entities within the NOW Group
- During networking events that we have either hosted, sponsored, or attended
- From publicly available sources (for example, your company website)
In the past 12 months, we have collected the following categories of personal data from and about our website visitors, customers and vendors. Please see the full list of CCPA categories and their descriptions in Appendix A.
|To provide you products or services that are requested from us, or to receive services from you.||
|To manage, operate and give and receive instructions in respect of the accounts you hold with us.||
|To develop and improve the services we provide to you, to learn from the way you manage your accounts with us and for operational and administrative purposes.||
|To exercise and/or defend legal claims between us.||
|To inform you of products, services and events that may be of interest to you by letter, marketing event, telephone, messages, e-mail, website and other electronic methods.||
|To entertain our customers and vendors at sporting events.||
|To enable you to participate in prize drawings, competitions and/or surveys we may administer.||
|To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of DNOW’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by DNOW about you is among the assets transferred.||
|To maintain records of visitors to our premises.||
|To register you as a new customer on our website.||
|To administer and protect our business premises and our websites (physical site security and cybersecurity).||
For any questions or requests, please contact us at firstname.lastname@example.org or at our toll-free privacy number: 888-342-4934.
Where we use your email to communicate marketing information to you, we will seek your prior consent where required by law to do so.
We do not sell your personal data.
We do share your personal data with other members of the NOW Group.
We may also disclose information about you to organizations that provide a service to us, on the understanding that they will keep the information confidential, use the information solely to provide the service to us and will comply with the CCPA and other relevant data protection laws. We may share your information with the following types of service providers:
- Technical support providers who assist with our website and IT infrastructure
- Third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf
- Professional advisers such as attorneys, accountants, tax advisers, auditors and insurance brokers
- Service providers that help us generate and collate reviews in relation to our products and services
- Marketing event partners
- Advertising and promotional agencies and consultants and those organizations selected by us to carry out marketing campaigns on our behalf
- Service providers that help us store, collate and organize information effectively and securely, both electronically and in hard copy format, and for marketing purposes
- Tool vending machine providers
- Banks, payment services and credit check providers
The CCPA provides you with certain rights in relation to the processing of your personal data without discriminatory treatment for exercising those rights.
Note that you can designate an authorized agent to make a CCPA request on your behalf. In order to do so however, we must verify your identity and you must provide the authorized agent with written permission to represent you. CCPA rights include the right to:
- Opt out of the sale of personal data about you (commonly known as “do not sell my personal information”). This enables you to indicate that you do not want a company to sell the personal data that the company has obtained about you. DNOW does not sell your personal data. In addition, because DNOW does not sell your personal data, DNOW does not offer any financial incentive and/or price or service difference in exchange for the retention or sale of your personal information.
- Request categories of personal data maintained about you (commonly known as “right to know”). This enables you to obtain a list of the categories of personal data we collect about you and the service providers we may share the data with, as well as the purposes for which we maintain the data.
- Request access to personal data about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you. You can also request that a copy of the personal data we hold about you be provided in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit this information to another entity without hindrance.
- Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to maintain the data. You should be aware, however, that California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it, such as when retaining your personal information is necessary for us to complete a transaction with you or provide you with a product or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.
The exercise of these rights is not absolute and may be subject to certain pre-conditions and exemptions under the CCPA.
Should you wish to exercise the rights accorded by the CCPA, please contact us at email@example.com or at our toll-free privacy number: 888-342-4934.
The identity of each person exercising the above rights will be verified using 2 pieces of information to identify the requester for requests for categories of information collected and 3 pieces of information to identify the requester for requests of actual personal information collected and deletion requests.
DNOW will keep and process your Personal Data only for as long as is necessary for the purposes for which it was collected in connection with your relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.
Appendix A - CCPA Categories of Personal Information
The list of categories of personal information from 1798.140 (e) of the CCPA are listed below:
|DNOW CCPA Category Abbreviation||Law Text From 1798.140 (e)|
|Identifiers||(A) 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|
|Select Information in Customer Records||(B) Any categories of personal information described in subdivision (e) of Section 1798.80:
1798.80 (e) “Personal information” means 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
|Legally Protected Characteristics||(C) Characteristics of protected classifications under California or federal law. (Race, religion, sexual orientation, gender identity, gender expression, age)|
|Commercial Purchasing Information||(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|Biometric Information||(E) Biometric information|
|Internet or Network Activity||(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement|
|Geolocation||(G) Geolocation data|
|Information Typically Detected by the Senses||(H) Audio, electronic, visual, thermal, olfactory, or similar information|
|Professional or Employment Information||(I) Professional or employment-related information|
|Education Information||(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)|
|Inferences Used to Profile||(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes|