Sandhills Global, Inc. Privacy Policy for California Residents

Effective Date: May 2, 2023
Last Updated/Reviewed on: May 2, 2023

This Privacy Policy for California Residents replaces the information contained in the Sandhills Global, Inc. and the Sandhills Group Companies (“Sandhills” or the “Company” or the “business” or “we” or “our” or “us”) Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you” or “your” ). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”) and their adopted regulations, and any terms defined in the CCPA and CPRA and their adopted regulations have the same meaning when used in this Policy.

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”). Personal information does not include:

• Information that is lawfully made available from federal, state, or local government records.
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media.
• Information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's/CPRA’s scope, like:
  • 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), clinical trial data, or other qualifying research 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.
• In particular, we have collected the categories of personal information specifically identified in Chart 1 below from consumers within the last twelve (12) months.

Purpose for Collection and Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business and commercial purposes (“Purposes” or Purpose numbers”), as specifically identified in Chart 1 and Chart 2 below:

1. To fulfill or meet the reason the consumer provided the information. For example, if the consumer shares their name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to the consumer’s inquiry. If the consumer provides their personal information to purchase a product or service, we will use that information to process the consumer’s payment and facilitate delivery. We may also save the consumer’s information to facilitate new product orders or process returns.
2. To provide the consumer with physical or digital information, products, or services that consumer requests from us. To provide, support, personalize, improve, and develop our Website, products, and services.
3. To create, maintain, customize, and secure a consumers’ account with us.
4. To process consumer requests, purchases, transactions, and payments and prevent transactional fraud.
5. To provide consumers with support and to respond to consumers’ inquiries, including to investigate and address consumers’ concerns and monitor and improve our responses.
6. To personalize consumers’ Website experience and to deliver content and product and service offerings relevant to consumers’ interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with consumers’ consent, where required by law).
7. To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
8. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
9. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
10. Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
11. Debugging to identify and repair errors that impair existing intended functionality.
12. Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with Sandhills websites, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with Sandhills websites.
13. Performing services on behalf of Sandhills, including maintaining or servicing accounts, providing customer service, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Sandhills.
14. Providing advertising and marketing services to the consumer.
15. Undertaking internal research for technological development and demonstration.
16. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Sandhills, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Sandhills.
17. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
18. As described to consumer when collecting consumers’ personal information or as otherwise set forth in the CCPA and CPRA.
19. 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 consumers is among the assets transferred.

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.

Categories of Sources from which Personal Information is Collected

We obtain the categories of personal information, identified in Chart 1 and Chart 2, from the following categories of sources (“Sources” or “Source numbers”), as specifically identified in Chart 1 and Chart 2 below:

1. Directly from a consumer or a consumer’s authorized agents. For example, from forms or documents user completes or provides or products and services consumer purchases.
2. Indirectly from a consumer or a consumer’s authorized agents. For example, from information we collect from user in the course of providing services to users.
3. Directly and indirectly from activity on our Website. For example, from submissions through our website or observing user’s actions on our Website or website usage details collected automatically.
4. From advertising networks.
5. From internet service providers
6. From data analytics providers.
7. From government entities
8. From operating systems and platforms
9. From social networks
10. From data brokers
11. From CDN and DDoS service providers

Selling or Sharing Personal Information with Third Parties

We may share your personal information by disclosing it to a third party for a business or commercial purpose. We only make these business or commercial purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, the Company has disclosed personal information for a business or commercial purpose to the categories of third parties indicated in Chart 2 below.

We do not sell personal information for monetary consideration, but we may share or transfer personal information to a third party that provides us with services, such as advertising, data analysis and security. These services and business or commercial purposes may qualify as “other valuable consideration” for purposes of the definition of sale under the CCPA and CPRA. We do not sell personal information of individuals who we know are under the age of 16 years of age. In the preceding twelve (12) months, Company has sold/transferred the following categories of personal information to the categories of third parties indicated in Chart 2 below. For more on your personal information sale rights, see Right to Opt-out of Sale or Sharing (below).

Categories of third parties (“Third Parties,” “Third Party,” or “Third Party Recipient category numbers”) include the following:

1. Advertising networks
2. Internet service providers
3. Data analytics providers
4. Government entities
5. Operating systems and platforms
6. Social networks
7. Data brokers

NOTICE AT COLLECTION

Chart 1: Personal Information We Collect

Chart 2: Personal Information We Disclose to Third Parties

Your Rights and Choices

The CCPA/CPRA provides California residents with specific rights regarding their personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information on or after January 1, 2022, including beyond the 12-month period preceding our receipt of the request, unless doing so proves impossible or would involve disproportionate effort (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will disclose to you:

• What personal information we collected about you, including the categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, selling, or sharing that personal information.
• The categories of third parties with whom we disclose that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. 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.
2. Help ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes..
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the ability to complete such research, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information to us.
8. Comply with a legal obligation.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct
You have the right to request that we correct any of your personal information that we collected from you and retained, which is inaccurate. Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will review your request.

Right to Opt-out of Sale or Sharing
You have the right to opt-out of the sale or sharing of personal information by us that we collected from you and retained. If you would like to instruct us not to sell or share your personal information, please visit our Your Privacy Choices web page located here. If you request that we not sell or share your information, we will honor your request within 15 business days, will notify those who received your information during the 90 days before your request to not further sell or share your information and will notify you when this is completed. Once we receive your Do-Not-Sell or Share request, we will wait at least 12 months before asking you to reauthorize sales or sharing of your personal information.

Right to Limit Use or Disclosure of Sensitive Personal Information
You have the right to request that we limit our use or disclosure of your sensitive personal information that we collected from you and retained, subject to certain exceptions listed below. If you would like to instruct us not to use or disclose your sensitive personal information, please visit our Your Privacy Choices web page located here. If you request that we not use or disclose your sensitive personal information, we will honor your request within 15 business days, will notify those who received your sensitive personal information for purposes other than the exceptions listed below during the 90 days before your request to not further use or disclose your sensitive personal information and will notify you when this is completed. Once we receive your Do-Not-Use request, we will wait at least 12 months before asking you to reauthorize use or disclosure of your sensitive personal information for purposes other than the exceptions listed below.

The purposes for which we may use or disclose your sensitive personal information without being required to offer you a right to limit are as follows:

1. To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
2. To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at Sandhills and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
4. To ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
5. For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with Sandhills, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with Sandhills.
6. To perform services on behalf of Sandhills, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Sandhills.
7. To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Sandhills, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Sandhills.

Exercising Your Rights to Know, Delete or Correct
To exercise your rights to know, delete or correct described above, please submit a request by either:

• +1-844-203-0366
• privacy@sandhills.com
• Online Request Form –
  • Request to Know: https://www.sandhills.com/privacy-rights/request-form?type=know
  • Request to Delete: https://www.sandhills.com/privacy-rights/request-form?type=delete
  • Request to Correct: https://www.sandhills.com/privacy-rights/request-form?type=correct

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know, delete or correct on behalf of your child.

You may only submit a request to know twice within a 12-month period. Your request to know, delete or correct must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
  • If Sandhills maintains a password-protected account with the consumer, Sandhills verifying the consumer’s identity through Sandhills’ existing authentication practices for the consumer’s account. Sandhills may also require a consumer to re-authenticate themselves before deleting, correcting or disclosing the consumer’s data.
  • For Sandhills compliance with a request to know categories of personal information, Sandhills identifying the consumer to a reasonable degree of certainty, which may include matching at least two data points provided by consumer with data points maintained by Sandhills, which Sandhills has determined to be reliable for the purpose of verifying the consumer.
  • For Sandhills compliance with a request to know specific pieces of personal information, Sandhills identifying the consumer to a reasonably high degree of certainty, which may include matching at least three pieces of personal information provided by the consumer with personal information maintained by Sandhills that Sandhills has determined to be reliable for the purpose of verifying the consumer together with a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.
  • For Sandhills compliance with a request to delete or a request to correct, Sandhills verifying the identity of the consumer to a reasonable or reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm to the consumer posed by unauthorized deletion or correction.
  • For Sandhills compliance with a request to correct, Sandhills verifying the consumer’s identity based on personal information that is not the subject of the request to correct.
  • Requesting additional information from you if we cannot verity your identity from the information already maintained by us. Such additional information would only be used for purposes of verifying your identity regarding exercising your rights under the CCPA, security or fraud-prevention.
• 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.

Response Timing and Format for Request to Delete, Correct or Know
We will confirm receipt of your request to delete, request to correct or request to know within ten (10) business days. If you do not receive confirmation within the 10-business day timeframe, please contact: Phone: +1-844-203-0366 or Email: privacy@sandhills.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time (up to another 45 calendar 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 cover the 12-month period preceding our receipt of your request and beyond, unless doing so proves impossible or would involve disproportionate effort. 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, 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.

However, we may offer you certain financial incentives permitted by the CCPA/CPRA that can result in different prices, rates, or quality levels. Any CCPA/CPRA-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.

Other California Privacy Rights

California's "Shine the Light" law (Cal 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 privacy@sandhills.com or write us at:

Sandhills Global Inc.
Attn: Legal Department
120 West Harvest Drive
Lincoln, NE 68521

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, 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 Information

If you have any questions or comments about this notice, the ways in which Sandhills 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:

Phone: +1-844-203-0366
Website: https://www.sandhills.com/contact-us
Email: privacy@sandhills.com
Postal Address:
Sandhills Global Inc.
Attn: Legal Department
120 West Harvest Drive
Lincoln, NE 68521