If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.  To learn more about your California privacy rights, see Privacy Notice for California Residents attached hereto as Exhibit A.

Exhibit A California Privacy Notice

IntroductionPRIVACY NOTICE FOR CALIFORNIA RESIDENTSThis Privacy Notice for California Residents supplements the information contained in the Privacy Policy of Janie and Jack LLC (the “Company”, “We” or “Us”) and applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “You”).  We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.


Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”).  In particular, we collect the following categories of Personal Information from our Consumers:

Category
Examples
Collected
A.  Identifiers.
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.
YES
B.  Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
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.
YES
C.  Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
E.  Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F.  Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
G.  Geolocation data.
Physical location or movements.
YES
H.  Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I.  Professional or employment-related information.
Current or past job history.
NO
J.  Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K . Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
Personal information does not include:Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from our clients or their agents.
Indirectly from our clients or their agents.
Directly and indirectly from activity on our Website.
Use of Personal InformationWe may use or disclose the personal information we collect for one or more of the purposes in the Privacy Policy or as otherwise set forth in the CCPA.  We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.a.    Sharing Personal Information.  We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we require the recipient to both keep that personal information confidential and not use it for any purpose except for use in connection with performing the services on our behalf.  The CCPA prohibits third parties who obtain the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
i.    The Company discloses the following categories of personal information for a business purpose:
1.    Category A: Identifiers.
2.    Category B: California Customer Records personal information categories.
3.    Category D: Commercial information.
4.    Category F: Internet or other Electronic Network Activity Information (i.e., browsing history and information regarding a consumer’s interaction with our Website). 
5.    Category G: Geolocation data. 
ii.    We disclose your personal information for a business purpose to the following categories of third parties:
1.    Our affiliates;
2.    Service Recipients; and
3.    Third parties to whom you authorize us to disclose your personal information in connection with the products or services we provide to you.
Your Rights and ChoicesThe CCPA provides consumers who are California residents with specific rights regarding their personal information.  This section describes your CCPA rights and explains how to exercise those rights.a.    Access to Specific Information and Data Portability Rights.  You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
i.    The categories of personal information we collected about you.
ii.    The categories of sources for the personal information we collected about you.
iii.    Our business or commercial purpose for collecting or selling that personal information.
iv.    The categories of third parties with whom we share that personal information.
v.    The specific pieces of personal information we collected about you (also called a data portability request).
vi.    If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
1.    sales, identifying the personal information categories that each category of recipient purchased; and2.    disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B personal information.
b.    Deletion Request Rights.  You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
i.    Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
ii.    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
iii.    Debug products to identify and repair errors that impair existing intended functionality.
iv.    Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
v.    Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
vi.    Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
vii.    Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
viii.    Comply with a legal obligation.
ix.    Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
c.    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 either:
i.    Calling us at [1-877-449-8800]; or
ii.    Emailing us at [customer_service@janieandjack.com].
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 your minor child.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period.  The verifiable consumer request must:
i.    Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
ii.    Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.  However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
d.    Response Timing and Format.  We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
e.    Personal Information Sales Opt-Out and Opt-In Rights.  If you are sixteen (16) years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”).  We do not sell the personal information of consumers we actually know are less than sixteen (16) years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least thirteen (13) but not yet sixteen (16) years of age, or the parent or guardian of a consumer less than thirteen (13) years of age.  Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at [customer_service@janieandjack.com].
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.  However, you may change your mind and opt back in to personal information sales at any time by amending your preferences here.
You do not need to create an account with us to exercise your opt-out rights.  We will only use personal information provided in an opt-out request to review and comply with the request.
Non-DiscriminationWe will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:i.    Deny you goods or services.
ii.    Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
iii.    Provide you a different level or quality of goods or services.
iv.    Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
CCPA Rights Request MetricsMetrics regarding the consumer rights requests We received from California residents from January 1, [YEAR] to December 31, [YEAR] appear in the following chart:




Request Type
Received
Granted (in whole or in part)
Denied
Median Days to Respond
Requests to Know
[#]
[#]
Unverifiable: [#].
Not by a California resident: [#].
Called for information exempt from disclosure: [#].
Denied on other grounds: [#].
[#]
Requests to Delete
[#]
[#]
Unverifiable: [#].
Not by a California resident: [#].
Called for information exempt from disclosure: [#].
Denied on other grounds: [#].
[#]
Requests to Opt-Out of Personal Information Sales
[#]
[#]
Unverifiable: [#].
Not by a California resident: [#].
Called for information exempt from disclosure: [#].
Denied on other grounds: [#].
[#]
Other California Privacy RightsCalifornia’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  To make such a request, please send an email to [customer_service@janieandjack.com] or write us at:
Janie and Jack LLC
1 Harrison Street
San Francisco,  California  94105
Changes to Our Privacy NoticeWe reserve the right to amend this privacy notice at our discretion and at any time.  When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date.  Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact InformationIf you have any questions or comments about this notice, the ways in which Building Optics, LLC collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
i.    Website:    www.janieandjack.com
ii.    Email:         [customer_service@janieandjack.com]
iii.    Postal Address:   
Janie and Jack LLC
225 Bush Street, Suite 1300
San Francisco,  California  94105

Revisions:

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