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  UPI
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
 
 
Effective Date: January 1, 2020
Last Updated: January 1, 2020
 
     
  1. INTRODUCTION  
     
  This Privacy Notice explains how UPI ("UPI", "the Company", "we", or "us") collects and manages personal information relating to California residents, including customers, vendors, business partners, visitors, and users of our website ("consumers" or "you").

This Privacy Notice supplements the information contained in UPI's Privacy Policy located at https://ebusiness.ussposco.com/webcrm/Policies/privacyPolicy.jsp. We are providing 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 we use them in this Privacy Notice.
 
     
  2. DEFINITION OF PERSONAL INFORMATION  
     
  For purposes of this Privacy Notice, "personal information" means 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, household, or device.

Personal Information does not include:
  • Publicly available information from government records;
  • De-identified or aggregated consumer information; or
  • Other information excluded from the CCPA's scope, including:
    • 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; and
    • 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.
 
     
  3. COLLECTION, USE, SOURCES AND DISCLOSURE OF PERSONAL INFORMATION  
     
  The personal information that we collect can vary based on our relationship or interaction with a particular consumer. The following table sets forth (a) the categories of personal information that we have collected from consumers within the past 12 months; (b) the business and commercial purposes for which we use personal information; (c) the categories of sources from which we obtain personal information; and (d) the categories of third parties with whom we share personal information. Please note, however, that not all of the categories and examples listed in the below table are applicable to every consumer.

Personal Information Collected Examples Purposes of Use Sources of Personal Information Third Parties with whom Personal Information is Shared
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers To fulfill the purpose for which the information was provided;

To create, maintain, customize and secure your account with us;

To effectively provide the products, information and services you request or desire;

To process your requests, purchases, transactions and payments;

To prevent transactional fraud;

To provide, support, personalize and develop our website, products and services;

To improve the content, functionality, performance and usability of our website;

To notify you of changes to our website or any products or services we offer or provide;

To provide technical support and troubleshooting;

To improve our marketing and promotional efforts;

To help maintain the safety, security and integrity of our website, products, services, databases, technology assets and physical facilities;

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets;

To evaluate a potential business relationship or transaction with you.

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you (e.g. information you provide by completing our forms, registering for information or services, searching our products, engaging in transactions, contacting us by telephone, email, text or other means, or otherwise delivering information to us);

Indirectly from you through automatic data collection technologies (e.g. information your computer or mobile device transmits when interacting with our website or mobile applications); and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes (e.g., payment processing, customer and supplier due diligence, data transmission and analytics, workplace and data security, audits, or legal compliance)
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes (e.g., payment processing, customer and supplier due diligence, data transmission and analytics, workplace and data security, audits, or legal compliance)

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code 1798.80(e)) 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.) To fulfill the purpose for which the information was provided;

To create, maintain, customize and secure your account with us;

To effectively provide the products, information and services you request or desire;

To process your requests, purchases, transactions and payments;

To prevent transactional fraud;

To provide, support, personalize and develop our website, products and services;

To improve the content, functionality, performance and usability of our website;

To notify you of changes to our Website or any products or services we offer or provide;

To provide technical support and troubleshooting;

To improve our marketing and promotional efforts;

To help maintain the safety, security and integrity of our website, products, services, databases, technology assets and physical facilities;

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets;

To evaluate a potential business relationship or transaction with you;

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Protected classification characteristics under California or Federal Law Race, gender, physical or mental disability, and religion To fulfill the purpose for which the information was provided;

To effectively provide the products, information and services you request or desire;

To provide you with accessible facilities, equipment and services;

To provide this Privacy Notice and other informational forms to you in an accessible format as needed; and

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Commercial information Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies. To fulfill the purpose for which the information was provided;

To create, maintain, customize and secure your account with us;

To effectively provide the products, information and services you request;

To process your requests, purchases, transactions and payments;

To prevent transactional fraud;

To provide, support, personalize and develop our website, products and services;

To improve our marketing and promotional efforts;

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets;

To evaluate a potential business relationship or transaction with you;

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you;

Indirectly from you through automatic data collection technologies; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement To fulfill the purpose for which the information was provided;

To effectively provide the products, information and services you request or desire;

To prevent transactional fraud;

To provide, support, personalize and develop our website, products and services;

To improve the content, functionality, performance and usability of our website;

To provide technical support and troubleshooting;

To improve our marketing and promotional efforts;

To help maintain the safety, security and integrity of our website, products, services, databases, technology assets and physical facilities;

To evaluate a potential business relationship or transaction with you;

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you;

Indirectly from you through automatic data collection technologies; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Geolocation data Physical location or movements. To fulfill the purpose for which the information was provided;

To effectively provide the products, information and services you request or desire;

To provide, support, personalize and develop our website, products and services;

To improve the content, functionality, performance and usability of our website;

To provide technical support and troubleshooting;

To improve our marketing and promotional efforts;

To help maintain the safety, security and integrity of our website, products, services, databases, technology assets and physical facilities;

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets;

To evaluate a potential business relationship or transaction with you;

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you;

Indirectly from you through automatic data collection technologies; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. To fulfill the purpose for which the information was provided;

To effectively provide the products, information and services you request or desire;

To provide technical support and troubleshooting;

To improve our marketing and promotional efforts;

To help maintain the safety, security and integrity of our website, products, services, databases, technology assets and physical facilities;

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you;

Indirectly from you through automatic data collection technologies; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Professional or employment-related information Current or past job history or performance evaluations To fulfill the purpose for which the information was provided;

To effectively provide the products, information and services you request or desire;

To provide, support, personalize and develop our website, products and services;

To improve our marketing and promotional efforts;

To evaluate a potential business relationship or transaction with you;

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you;

Indirectly from you through automatic data collection technologies; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public
Inferences drawn from other personal information Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. To fulfill the purpose for which the information was provided;

To effectively provide the products, information and services you request or desire;

To provide, support, personalize and develop our website, products and services;

To improve our marketing and promotional efforts;

To evaluate a potential business relationship or transaction with you;

To conform to legal requirements or comply with legal process served on UPI;

To protect and defend the rights or property of UPI;

To protect the personal safety of UPI personnel or members of the public; and

For any other purpose disclosed by us when you provide the information
Directly from you;

Indirectly from you through automatic data collection technologies; and

From affiliates, vendors, service providers, government agencies, or other third parties who support our business performance and purposes
Affiliates, vendors, service providers, government agencies or other third parties who support our business performance and purposes

A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets; and

Any other party as needed to conform to legal requirements, protect and defend the rights or property of UPI, or protect the personal safety of UPI personnel or members of the public


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.

As noted in the above table, we may disclose your personal information to third parties for business purposes. When appropriate, we enter into contracts with third parties that describe the purpose of the disclosure and require the recipient to keep the personal information confidential and not use it for any purpose other than performing the contract.

In the preceding 12 months, we have not sold personal information, and except in connection with a business transfer (i.e., a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UPI's assets) we will not sell your personal information without providing you with an opportunity to opt-out of such sales.
 
     
 

4. YOUR RIGHTS AND CHOICES

 
     
  The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise them.

Access to Specific Information and Data Portability Rights
You have the right to request certain information about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will, to the extent possible and permitted by law, disclose to you:
  • The categories of personal information we collected about you;
  • The categories of sources from which we collected your personal information;
  • Our business or commercial purposes for collecting or selling your personal information;
  • The categories of third parties with whom we shared your personal information;
  • The specific pieces of personal information we collected about you; and
  • If we sold or disclosed your personal information for a business purpose, two separate lists:
    • A list of the sales, identifying the personal information categories that each category of recipient purchased; and
    • A list of the disclosures, identifying the personal information categories that each category of recipient obtained.

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, 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 providers to:
  • Complete the transaction for which we collected the personal information, provide a good, service, or information that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.);
  • 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 businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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 emailing us at ebusiness_admin@ussposco.com or writing to us at:

UPI
Attn: Legal Department
900 Loveridge Road
Pittsburg, CA 94565

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 12-month period. The request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information or an authorized representative; and
  • 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 are unable to verify your identity or authority to make the request and confirm the personal information relates to you.

To verify your identity or authority, we will use information from your online account - such as your account number and email address.

Regardless of how you submit your request, we will use personal information provided in a verifiable consumer request only to verify the requestor's identity or authority to make the request.


Response Timing and Format
We will use reasonable efforts to initially respond to a verifiable consumer request within 10 days of its receipt, and to provide a substantive response within 45 days of receipt. If we require more time (not to exceed 90 days from receipt), 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 12-month period before 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 provide your personal information in a format that is commercially reasonable and should allow you to transmit the information to another entity.

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.

 
     
 

5. NON-DISCRIMINATION

 
 
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; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, 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 to us 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.
 
     
 

6. CHANGES TO THIS PRIVACY NOTICE

 
 
We 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 our website and update the notice's "Last Modified" date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
 
     
 

7. CONTACT INFORMATION

 
 
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please contact us at:

Phone: (800) 877-7672

E-Mail: ebusiness_admin@ussposco.com
Postal Address:
UPI
Attn: Legal Department
900 Loveridge Road
Pittsburg, CA 94565