Last Updated: November, 2023
This State-Specific Privacy Notice for California, Virginia, Nevada, Colorado and Connecticut residents (this “State-Specific Notice”) supplements the information contained in the general Privacy Policy (the “Privacy Policy”) of Similasan Corporation (the “Company”, “we” or “us”) with respect to our Website (as defined in the Privacy Policy ) and applies solely to all visitors, users, and others who reside in the State of California, Virginia, Nevada, Colorado and Connecticut (“consumer(s)” or “you”). This State-Specific Notice contains disclosures that the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”) and such other data protections laws in California (collectively, the “California Law”), the Virginia Consumer Data Protection Act of 2021 (“Virginia Law”), Chapter 603A of the Nevada Revised Statutes (“Nevada Law”), the Colorado Privacy Act (“Colorado Law”) and the Connecticut Data Privacy Act (“Connecticut Law”) require from us with respect to personal information collected from residents of the State of California, the Commonwealth of Virginia, the State of Nevada, the State of Colorado and the State of Connecticut.
For general information on our privacy practices, please refer to the Privacy Policy . Unless otherwise specified, Sections 1 to 5 only apply to residents of the States as indicated in the respective headings. This State-Specific Notice is incorporated in the Privacy Policy hereby by reference. This State-Specific Notice is incorporated in the Privacy Policy hereby by reference. Capitalized terms not defined in this State-Specific Notice shall have the meaning assigned to them in the Privacy Policy.
1. CALIFORNIA
1.1. Information We Collect
Below is a chart containing categories of personal information under California Law that we have collected within the last twelve (12) months and may continue to collect for the purposes described in the Section "How We Use Your Information" of the Privacy Policy:
Category | Examples |
---|---|
Identifiers. | A real name, postal address, email address, internet protocol address. |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, address, telephone number. |
Commercial information. | Products or services purchased. |
Internet or other similar network activity. | Browsing history, information on a consumer’s interaction with a website. |
Geolocation data. | Physical location or movements. |
Please refer to the Section "Information We Collect About You and How We Collect It" in the Privacy Policy for information on the sources from which we collect your personal information.
Please refer to the Section "How We Use Your Information" in the Privacy Policy for the purposes of our collection of personal information.
Please refer to Section "How Long We Retain Your Personal Information" in the Privacy Policy for information on how long we retain your personal information.
1.2. Collected Sensitive Personal Information
In the preceding twelve (12) months, we have collected the following sensitive personal information as defined in the California Law (the “sensitive personal information”) and we intend to collect such information on and after the date of this State-Specific Notice:
- Precise Geolocation.
1.3. Sharing and Sale of Personal Information
In the preceding twelve (12) months, we have disclosed the following personal information to the categories of third parties indicated in the chart below for a business purpose set forth in the Section "How We Use Your Information" in the Privacy Policy and may continue to do so :
Personal Information Category | Category of Third-Party Recipients |
---|---|
Identifiers. | Affiliate, manufacturers, service providers, pharmacovigilance providers, FDA. |
California Customer Records Personal Information categories. | Affiliate, manufacturers, service providers, pharmacovigilance providers, FDA. |
Commercial information. | Affiliate, manufacturers, service providers, pharmacovigilance providers, FDA. |
Internet or other similar network activity. | Service providers such as Google and Meta (only through the use of Google Analytics and Meta Pixel). |
In the preceding twelve (12) months, we have not sold personal information or sensitive personal information for monetary consideration to any third parties. However, there are certain activities being conducted by or on behalf of the Company that may constitute as “sale” or “sharing” of personal information under California Law. Please refer to the section "Sale of Your Information" in the Privacy Policy for more information on this.
1.4. Your Rights and Choices
California Law provides California consumers with specific rights regarding their personal information. This section describes your rights under California Law and explains how to exercise these rights.
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 section "Accessing and Correcting Your Personal Information" in our Privacy Policy), we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources from which we collected the personal information about you;
- Our business or commercial purpose for collecting, disclosing, “selling” or “sharing” that personal information about you;
- The categories of personal information we disclosed about you for a business purpose and the categories of third parties with whom we shared that personal information;
- The categories of personal information about you that we “sold” or “shared” and the categories of third parties to whom your personal information was “sold” or “shared”, by category or categories of personal information for each category of third parties to whom the personal information was “sold” or “shared”;
- The specific pieces of personal information we collected about you.
Deletion Request Rights
You have the right to request that we delete any of your personal information about you that we collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see section "Accessing and Correcting Your Personal Information" in our Privacy Policy), we will review your request to see if an exception allowing us to retain the Personal Information applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 of Title 12 of Part 2 of the Penal Code (Cal. Penal Code § 1546 et. seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research that adheres to all other applicable ethics and privacy laws, when our deletion of the personal information is likely to render impossible or seriously impair the ability to complete such research, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; and/or
- Comply with a legal obligation.
We will then delete or de-identify your personal information not subject to one of these exceptions from our records and will direct our service providers, contractors and third parties to whom we have sold or shared your personal information to take similar action, unless this proves impossible or involves disproportionate effort. However, we may maintain a confidential record of your deletion request solely for the purpose of preventing your personal information from being sold, for compliance with laws of for other purposes permissible under California Law.
Correction Rights
You have the right to request that we correct your personal information if you think it is inaccurate, taking into account the nature of the personal information and the purposes of the processing of the personal information. Once we receive your verifiable consumer request (see section "Accessing and Correcting Your Personal Information" in our Privacy Policy), we will use commercially reasonable efforts to correct your inaccurate personal information and will direct our service providers to do the same.
Right to Opt-Out of Sale or Sharing
You have the right to direct us to stop “selling” (i.e., disclosing your personal information to third parties for monetary or other valuable consideration or “sharing” your personal information (i.e., disclosing your personal information to third parties for cross-contextual behavioral advertising). In case our activities qualify as a “sale” or “sharing” of your personal information (see section "Sale of Your Personal Information" of the Privacy Policy), you can request to opt out of such “sale” or “sharing” here.
Once we receive your verifiable consumer request (see section "Accessing and Correcting Your Personal Information" in our Privacy Policy), we will stop “selling” or “sharing” your personal information, unless you subsequently provide consent for the sale or sharing of your personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information
California Law provides its residents with a right to limit the use and disclosure of sensitive personal information (as defined in the California Law). You can limit the use or disclosure of your sensitive personal information here.
Once we receive your verifiable consumer request (see section "Accessing and Correcting Your Personal Information" in our Privacy Policy), we will stop “using” or “disclosing” your sensitive personal information for any purpose other than those set forth in Section 1798.121 of the CPRA, unless you subsequently provide consent for the use or disclosure of your sensitive personal information for additional purposes.
Other California Privacy Rights
California’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 getinfo@similasanusa.com or write to us at 1805 Shea Center Drive, Suite 270, Highlands Ranch CO 80129.
1.5. Exercising Your Rights under California Law
To exercise your rights described above, please submit a verifiable consumer request to us either by:
- Calling us at +1 (800) 240-9780;
- Emailing us at getinfo@similasanusa.com; or
- Visit our contact us page here
To exercise your right to opt-out of “Sale” or “Sharing” or your right to limit the use and disclosure of sensitive personal information, you may also submit your request via the following link that you can also find on our Website that contains information on how we use your personal infromation.
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 and a request pursuant to California’s “Shine the Light” law once during the course of a calendar year. The verifiable consumer request must:
- Provide information or documentation sufficient to allow us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include but not limited to: name, address, and, if existing, account name and purchase history; and
- Describe your request in detail sufficient to allow 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 that the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. 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 a verifiable consumer request to verify the requestor’s identity or authority to make the request.
1.6. 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 a total of ninety (90) days), we will inform you in writing of the reason and extension period. For requests under California’s Shine the Light Law, we will respond within thirty (30) days of receipt of your request.
We will deliver our written response either electronically via email or via phone, at your discretion.
Any disclosures we provide will only cover the twelve (12)-month period preceding the receipt of the verifiable consumer request. Upon your request, unless impossible or involving disproportionate effort, we will also provide you with disclosures beyond the 12-months period for personal information. The response we provide will also explain the reasons we cannot comply with a request, if applicable, and any rights you may have to appeal the decision. 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.
1.7. Non-Discrimination
We will not discriminate against you for exercising any of your rights under California Law. Unless permitted by California Law, 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 with 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.
1.8. Minors
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization from the parent or guardian of a minor less than 16 years of age.
If you are under the age of 16 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at getinfo@similasanusa.com. We may not be able to modify or delete your information in all circumstances.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).
2. VIRGINIA
We note that Virginia Law uses the term “personal data”. Any references to “personal information” below or in the Privacy Policy shall have the meaning assigned to the term “personal data” under Virginia Law.
2.1. Disclosures under Virginia Law
- Please refer to Section "Information we Collect About You and How We Collect It" of the Privacy Policy for information on categories of personal information we have collected in the preceding twelve (12) months and may continue to collect. For more specific categories, please refer to Section 1.1 of this State-Specific Notice.
- Please refer to Section "How We use Your Information" of the Privacy Policy for information on the purposes for our collection and processing of personal information.
- We are disclosing the following categories of personal information to third parties for a business or commercial purpose: (i) identifiers (ii) other types of personal information that identifies, relates to, describes or is capable of being associated with you which are also referred to in the California notice as personal information pursuant to the California Customer Records statute (Cal. Civ. Code §1798.80 (e)), (iii) commercial information (e.g., products or services purchased.); and (iv) Internet or other similar network activity. For types of personal information that fall under these categories, please refer to Section 1.1 of this State-Specific Notice.
- Please refer to Section "Disclosure / Sharing of Your Information" of the Privacy Policy and Section 1.3 of this State-Specific Notice for information on the third parties we disclose personal information to.
2.2. Your Virginia Rights Regarding Your Personal Data
Virginia Law provides to Virginia residents with the rights listed below. To exercise these rights, see Section 2.3 of this State Specific Notice.
Right to Know.
You have the right to know whether we have collected personal information about you.
You also have the right to know what personal information we have collected about you and to obtain a copy of such personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal information to another controller without hindrance, where the processing is carried out by automated means.
Right to Correct.
You have the right to request that we correct inaccurate personal information about you.
Right to Delete.
You have the right to request that we delete the personal information we have collected about you.
Right to Opt Out from the Sale of Personal Information, Targeted Advertising and/or Profiling.
Virginia Law provides its residents with a right to opt out of (i) targeted advertising, (ii) the sale of your personal information (as defined under Virginia law ), or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the Website.
2.3. Exercising Your Rights under Virginia Law
You do not need to create an account with us to submit a request related to personal information. 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.
To request access to or deletion of your personal information, or to exercise any other privacy rights under Virginia Law, please contact us using one of the following methods:
- Calling us at +1 (800) 240-9780;
- Emailing us at getinfo@similasanusa.com; or
- Visit our contact us page here
To appeal our decision regarding a request related to these rights, you may write to us at getinfo@similasanusa.com. If we deny your appeal, we will provide a way for you to contact the Attorney General to submit a complaint.
2.4. Response Timing and Format
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your verifiable consumer request unless it is manifestly unfounded or excessive, in particular because of its repetitive character. 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.
3. NEVADA
Please refer to Section "Information We Collect About You and How We Collect It" of the Privacy Policy and Section 1.1 of this State-Specific Notice for the categories of personal information that we collect and Section "Disclosure / Sharing of Your Informatio" and "Third-Party Use of Cookies and Other Tracking Technologies" of the Privacy Policy for the categories of third parties with whom we may share such personal information and who may collect such personal information about you over time and across different Internet websites or online services when you use our Website.
If you wish to review or request changes to any of your personal information we collect, please contact us via any of the methods mentioned in Section 8 of this State-Specific Notice.
To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the Website.
Nevada Law provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address:
- Calling us at +1 (800) 240-9780;
- Emailing us at getinfo@similasanusa.com; or
- Visit our contact us page here
However, please know that we do not currently sell personal information triggering Nevada Law’s opt-out requirements.
Please refer to Section 7 below and Section "Changes to Our Privacy Policy" of the Privacy Policy for the process by which we notify you of material changes to the Privacy Policy and this State-Specific Notice.
4. COLORADO
We note that Colorado law uses the term “personal data”. Any references to “personal information” below or in the Privacy Policy shall have the meaning assigned to the term “personal data” under Colorado Law.
4.1. Data Similasan Collects About You and Where We Obtain It
Section "Personal Information We Collect About You and How We Collect It" and "How We Use Your Personal Information" of the Privacy Policy sets forth the categories of personal data that we collect about you, and the purposes for which we use it.
4.2. Similasan’s Data Sharing with Third Parties
We may disclose data that we collect about you or that you provide to us, including personal data. The categories of personal data we may share, and the third parties with which we may share it, are found in Section "Disclosure / Sharing of Your Personal Information" of the Privacy Policy.
4.3. Your Rights in Your Personal Data and How You Can Exercise Them
The Colorado Law provides residents with the right to receive certain disclosures regarding a business’ processing of “personal data,” as defined under Colorado Law. It also provides them with certain rights with respect to our processing of personal data. If you are a resident and we collect personal data subject to applicable law, you have the following rights:
Right to Access
You have the right to confirm whether or not we are processing your personal data and to access your personal data.
Right to Correction
You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.
Right to Deletion
You have the right to delete the personal data provided to us by you.
Right to Data Portability
You have the right to obtain a copy of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller without hindrance, where the processing is carried out by automated means.
Right to Opt-Out of Sale, Targeted Advertising, and Profiling
Under Colorado Law, a “sale” includes disclosing personal data to a third party in exchange for monetary compensation or other valuable consideration. In the preceding 12 months we have not sold personal information or sensitive personal information (as defined in the Colorado Law) for monetary consideration to any third parties.
However, certain activities are conducted by or on behalf of the Company that may constitute as “sale” of personal information or “targeted advertising” under Colorado Law. Please refer to the Section "Sale of Your Information", "Disclosure / Sharing of Your Personal Information" and "Third-Party Use of Cookies and Other Tracking Technologies" in the Privacy Policy for more information on this.
To opt out of sale and targeted advertising, where applicable, please click on the Opt-Out Link on the bottom of the Website.
If you are a Colorado resident, you have the right to opt out of the processing of your personal data by us for to create profiles or to make decisions that produce legal or similarly significant effects concerning you. We do not process personal data for such profiling.
Right to Appeal
If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. You have the right to contact the Attorney General if you have concerns about the result of the appeal.
If any of the rights described in the sections above apply to you, you may make a request by contacting us at
- Calling us at +1 (800) 240-9780;
- Emailing us at getinfo@similasanusa.com; or
- Visit our contact us page here
Please indicate that you are making a request pursuant to your “Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information. We will take steps to verify your request by matching the information provided by you with the information we have in our records.
5. CONNECTICUT
We note that Connecticut law uses the term “personal data”. Any references to “personal information” below or in the Privacy Policy shall have the meaning assigned to the term “personal data” under Connecticut Law.
5.1. Data Similasan Collects About You and Where We Obtain It
Section "Personal Information We Collect About You and How We Collect It" and "How We Use Your Personal Information" of the Privacy Policy sets forth the categories of personal data that we collect about you, and the purposes for which we use it.
5.2. Similasan’s Data Sharing with Third Parties
We may disclose data that we collect about you or that you provide to us, including personal data. The categories of personal data we may share, and the third parties with which we may share it, are found in Section "Disclosure / Sharing of Your Personal Information" of the Privacy Policy.
5.3. Your Rights in Your Personal Data and How You Can Exercise Them
If you are a Connecticut resident, you have the right to receive certain disclosures regarding the way Similasan processes your personal data, as defined by the Connecticut Law. You also have certain rights with respect to our processing of your personal data. If you are a Connecticut resident, and we collect personal data subject to applicable Connecticut Law, you may exercise the following rights:
Right to Access
You have the right to confirm whether or not we are processing your personal data and to access your personal data.
Right to Correction
You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for which we process it.
Right to Deletion
You have the right to delete the personal data you provide to us.
Right to Data Portability
You have the right to obtain a copy of the personal data that you provide to us. You have the right to obtain it in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller without hindrance, where the processing is carried out by automated means.
Right to Opt-Out of Sale, Targeted Advertising, and Profiling
Under Connecticut Law, a “sale” includes disclosing personal data to a third party in exchange for monetary compensation or other valuable consideration. In the preceding 12 months we have not sold personal information or sensitive personal information (as defined in the Connecticut Law) for monetary consideration to any third parties.
However, certain activities are conducted by or on behalf of the Company that may constitute as “sale” or “targeted advertising” of personal information under Connecticut Law. Please refer to the Section "Sale of Your Information" in the Privacy Policy for more information on this.
To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the Website.
If you are a Connecticut resident, you have the right to opt out of the processing of your personal data by us to create profiles or to make decisions about you that may affect you legally or in other similarly significant ways. We do not process personal data for such purposes.
Right to Appeal
We may, in some cases and as provided for by law, decline to take action to respond to you request. When we do, you have the right to appeal. We will notify you of our decision to decline your request, the reasons why, and instructions about how you can appeal our decision. If we deny your appeal, we will provide a way for you to contact the Attorney General to submit a complaint.
5.4. How to Exercise Your Rights
If any of the rights described in the sections above apply to you, you may make a request by contacting us at:
- Calling us at +1 (800) 240-9780;
- Emailing us at getinfo@similasanusa.com; or
- Visit our contact us page here
Please indicate that you are making a request pursuant to your “Connecticut Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records.
6. CHANGES TO THIS PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
We reserve the right to amend this State-Specific Notice at our discretion and at any time. When we make changes to this State-Specific Notice, we will post the updated notice on our 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.
7. CONTACT INFORMATION
If you have any questions or comments about this State-Specific Notice, the ways in which we collect and use your personal information described here, your choices and rights regarding such use, or wish to exercise your rights under the law applicable to you, please do not hesitate to contact us at:
Phone: +1 (800) 240-9780
Postal Address: 1805 Shea center drive suite 270, Highlands Ranch, CO 80129
Visit: our contact us page here