Customer-Client CCPA Notice

This notice describes the categories of personal information which may be collected by Kenco PPC Buyer LLC and subsidiaries (“Company”) and the purposes for which such information may be collected and used. For additional information about the Company’s data privacy practices, please review our Privacy Policy https://kencogroup.com/privacy-policy/.

Categories of Personal Information Collected

Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signatures, account names, dates of birth, bank account information, and other similar contact information and identifiers.

Protected Classification Information. This category includes characteristics of protected classifications under California or federal law.

Commercial Information. This category includes, without limitation, products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or Other Electronic Network Activity Information. This category includes, without limitation, browsing history, search history, or a consumer’s interactions with a website, application, or advertisement.

Geolocation Data. Such as location information when using one of our apps, devices, or vehicles.

Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information. This category includes, for example, information collected from voicemail messages, while speaking with one of our service representatives, and/or by video camera.

Biometric Information. This category includes, without limitation, an individual’s physiological, biological, or behavioral characteristics used or intended for use – singly or in combination with each other or with other identifying data – to establish individual identity.

Professional and Employment-Related Information. This category includes, without limitation, information regarding job applications, information related to onboarding for payroll and benefits, and information needed for evaluating performance.

Education Information. This category includes, without limitation, 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, Sec. 1232g; 34 C.F.R. Part 99) Sensitive Personal Information. This category includes sensitive information such as:

social security, driver’s license, state identification card, or passport number

financial account information that allows access to an account, including log-in credentials, financial account numbers, passwords, etc.

precise geolocation

racial or ethnic origin, religious or philosophical beliefs, or union membership

content of mail, email, and text messages (unless the Company is the intended recipient of the communication)

genetic data

biometric information for the purpose of uniquely identifying a consumer

health information

Consumer Profile. This category includes information drawn from any of the categories above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.

Google Analytics and Other Third Parties. We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding visitors to the Website. These cookies collect data tied to a user’s IP address such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting https://kencogroup.com. Based on this information, Google Analytics compiles aggregate data about Website traffic and Website interactions, which we use to offer you a better experience when you visit https://kencogroup.com. Other Google advertising features we use include Dynamic Remarketing, DoubleClick, and AdWords Conversion.

You can obtain more information about Google Analytics here: https://www.google.com/analytics/learn/privacy.html?hl=en-GB.

For information about how to prevent your data from being used by Google Analytics, visit https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631.

Purposes For Which Personal Information, Including Sensitive Personal Information, Is Used

To provide you with information, products, or services you request from us.

To fulfill or meet the reason for which the information is provided.

To contact you and/or provide you with email alerts and other notices concerning our products, services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.

To process payments.

To engage in marketing activities.

To communicate with you via social media concerning our products and services.

To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your personal information with data from various sources for purposes of keeping information up to date. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal or share and use it as described elsewhere in this Policy.

To carry out our obligations and enforce our rights including those arising from any contracts entered into with you, including for billing, payment, and collections.

To review, improve, and monitor our website, applications, online services, and overall consumer experience, including to provide customization to meet the specific needs.

To provide customer service and engage in quality control activities concerning our products and services.

For testing, research, analysis and product and service development. We may use data, including public feedback and surveys, to conduct research and for the development of the Site and the services, products, and information we provide.

To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.

As described to you when collecting your personal information.

To manage our recruiting efforts and employment and workforce relationships. These activities include, for example, sourcing and processing employment applications, onboarding employees and contingent workers, and carrying out a range of employments activities relating to the employment relationship, such as compensation, benefits, promotion, discipline, termination, and certain post termination activities.

As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.

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 is among the assets transferred.

Retention. We retain your personal information for as long as is necessary to provide you with services and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, address other legitimate business needs, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors, such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.

Disclosure. To carry out the purposes outlined above, the Company may disclose personal information to service providers or other outside parties. The Company shares Personal Information for legitimate business purposes. For example, we may disclose your Personal Information with services providers and contractors who help us provide the products and services, such as, shipping, payment processing, marketing and advertising, email, text and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services. The Company does not sell personal information as the term is traditionally understood (i.e., we do not exchange Personal Information directly for monetary consideration.) The Company may add to the categories of personal information it collects and the purposes for which it uses that information. The Company will inform you in the event it does so.

California Resident Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights, which are outlined below.

Right To Know About Personal Information Collected or Disclosed. As a California resident, you have the right to request additional information, beyond that disclosed above, regarding the following, to the extent applicable:

the categories of personal information the Company collected about you

the categories of sources from which that personal information was collected

the business or commercial purposes for which that information was collected, sold, or shared

the categories of third parties to whom the information was disclosed

the specific pieces of personal information collected

Upon receipt of a verifiable request to know and as required by applicable law, we will provide a response to such request.

Right To Request Deletion of Your Personal Information. You have the right to request that we delete the personal information we collected or maintain about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and will direct any service providers and contractors to whom we disclosed your personal information to also delete your personal information from their records.

There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Such instances include, without limitation, when the information at issue is maintained: (a) to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information, or (b) to comply with a legal obligation.

Upon receipt of a verifiable request to delete, and as required by applicable law, we will provide a response to such requests.

Right to Request Correction. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable request to correct (see below), and as required by the CCPA, we will provide a response to such requests.

Right to Limit Use or Disclosure of Sensitive Personal Information. You have the right, subject to certain exceptions, to request that we limit the use and disclosure of your sensitive personal information, as that term is defined in the CCPA. Upon receipt of a verifiable consumer request, and as required by the CCPA, we will take appropriate steps to respond to your request.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate or retaliate against you for exercising any of the rights described above.

Submitting CCPA Rights Requests. To submit a CCPA Rights request as outlined above, please contact us at 1-800-758-3289 or privacy@KencoGroup.com. We reserve the right to only respond to verifiable consumer requests that are submitted as instructed.

We reserve the right to amend this notice at any time without advance notice. Please direct questions about this notice to 1-800-758-3289 or privacy@KencoGroup.com.