Effective January 1, 2020
This Notice for California Residents (“CCPA Notice”) is a supplement to our Privacy Statement and applies to the “personal information,” as such term is defined in the California Consumer Privacy Act of 2018 (“CCPA”), of natural persons who reside in the State of California (“consumer” or “you”). To the extent of any conflict between this CCPA Notice and any other provision of the Privacy Statement, this CCPA Notice shall control only with respect to California residents and their personal information. If you reside elsewhere, please see the rest of our Privacy Statement in the link above.
Information We Collect About California Residents
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household (“Personal Information”). In particular, we may collect the following Categories of Personal Information from consumers:
Identifiers - A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal Information under CCPA - A 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. Some Personal Information included in this category may overlap with other categories.
Commercial information - Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity - Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data - Physical location or movements.
Professional employment related information - Current or past job history or performance evaluations.
Inferences drawn from other Personal Information - Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Sources of Personal Information
We obtain the Categories of Personal Information listed above from the following Categories of Sources:
- Directly from Consumer, e.g., forms consumers complete or submissions you make to us on our Website or other websites or platforms controlled by Covestro, provide to us in person at trade shows or other marketing and sales related events, or products and services consumers purchase from us, or any of the above activities through our service providers and vendors.
- Indirectly from Consumer, e.g., from observing consumer actions on our Website and other websites.
• Consumer Interactions with Website
• Social Media Websites
- Business Relationships directly with consumers or with other business partners, such as customers, suppliers, distributors, consultants, sponsorships, trade memberships, etc.
- Information Publicly Available Online, such as government databases, online profiles, social media, and Internet search engines.
Table I sets forth the Categories of Sources for each Category of Personal Information collected:
|Categories of Sources||Categories of Personal Information|
|Directly from Consumer||
|Indirectly from Consumer||
|Information Publicly Available Online||
Use of Personal Information of California Residents
We may use any of the Categories of Personal Information set forth above for one or more of the following Business Purposes:
- to meet requirements imposed by law, including court orders, subpoenas, or compliance with the legal process;
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- as described to a consumer when collecting Personal Information or as otherwise set forth in the CCPA; and
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.
In addition to the above, we collect each Category of Personal Information for the Business Purposes as set forth in Table II:
|Point of Collection||Category of Personal Information Collected||Business Purpose|
|Passive Online Interactions
A Passive Online Interaction takes place when a natural person interacts with a Covestro website or mobile application without actively providing information directly within the website or mobile application.
A person who has interacted with Covestro for a limited purpose such as:
|All Categories of Personal Information collected from Passive Online Interactions, and:
||All Business Purposes for which Personal Information is collected from Passive Online Interactions, and
A person who has engaged in a commercial transaction with Covestro such as:
|All Categories of Personal Information collected from Passive Online Interactions and Individual Interactions.||All Business Purposes for which Personal Information is collected from Passive Online Interactions, Individual Interactions, and
Sharing Personal Information of California Residents
Disclosures of Personal Information for a Business Purpose
Covestro may disclose the following Categories of Personal Information for a Business Purpose:
- Categories of Personal Information under the CCPA
- Commercial information
- Internet or other similar network activity
- Geolocation data
- Professional or employment related information
- Inferences drawn from other personal information
Categories of Recipients to Whom We Disclose
Covestro may disclose Personal Information for a Business Purpose to the following Categories of Recipients:
- Service Providers (for-profit legal entities that process information on behalf of Covestro and to which Covestro discloses a consumer's personal information for a business purpose pursuant to a written contract)
- Governmental Agencies (Federal or State)
- Trade or Industry Groups
- Affiliates and subsidiaries of Covestro and other members in the Covestro group of companies (“Affiliates”)
- Recipients in connection with legal or equitable claims, actions or proceedings (“Proceeding Recipients”)
Table III sets forth each Category of Personal Information collected from or about consumers, and the Categories of Recipients to whom we disclosed such Personal Information:
|Categories of Personal Information||Categories of Recipients|
|Identifiers||Service Providers; Governmental Agencies; Trade or Industry Groups; Affiliates; Proceeding Recipients|
|Personal information under CCPA||Service Providers; Proceeding Recipients Governmental Agencies; Trade or Industry Groups; Affiliates|
|Commercial information||Service Providers; Governmental Agencies; Proceeding Recipients; Affiliates|
|Internet or other similar network activity||Service Providers; Proceeding Recipients; Affiliates|
|Geolocation data||Service Providers; Affiliates|
|Professional or employment related information||Service Providers; Governmental Agencies Proceeding Recipients; Affiliates|
|Inferences drawn from other personal information||Service Providers; Affiliates|
Sale of Personal Information
As of January 1, 2020, Covestro LLC will not sell Personal Information, as such term is defined in the CCPA.
Knowing Your Rights Under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Information. In this section, we describe your rights under CCPA and explain how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Covestro provide certain information to you about our collection and use of your Personal Information over the past 12 months. If you wish to exercise either your right to access or your data portability right, you must submit a verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights).
Deletion Request Rights
You have the right to request that Covestro delete your Personal Information, subject to certain exceptions. If you wish to exercise this right, you must submit a verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights).
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by one of the following methods:
- Email: DataPrivacyUS@covestro.com
- Calling us at 1-877-229-3778. A consumer may submit a request by calling the phone number provided and an operator will take your information. Covestro will contact you directly to provide more instruction and procure verification information.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of a minor child to whom you are parent or guardian.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
A verifiable consumer request must:
- Provide sufficient information in response to the website/email/phone verification question asked in the creation of your request that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such a person. In the event we need additional information we will reach out to you personally to ask additional questions.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Covestro or a third party on behalf of Covestro may follow up with you to determine whether a request is a verifiable consumer request under applicable law.
If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, Covestro will deny the consumer request. Covestro will respond to any such consumer request with a denial and will also explain why it has no reasonable method by which it can verify the identity of the requestor.
Response Timing and Format
We will confirm receipt of a verifiable consumer request within ten (10) days of its receipt.
We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option. If you do not indicate a preference for delivery, Covestro will use its discretion in choosing the method for delivery of the information.
We do not charge a fee to process or respond to your verifiable consumer request.
Personal Information Sales Opt-Out and Opt-In Rights
Covestro LLC will not sell the Personal Information of consumers.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Right to Designate an Authorized Agent
If you submit a request for access and portability or deletion through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify your identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization or where you have not verified your identity directly with us.