Introduction

This Zacks Enterprises Inc. (“Zagwear”, “We”, “Us”, or “Our”) California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act (the “CCPA”). This Notice supplements our other policies and notices, including our Privacy Policy. In the event of a conflict between any other Zagwear policy, statement, or notice and this Notice, this Notice will prevail as to California consumers and their rights under the CCPA.

Consistent with the CCPA, the information in this Notice and the rights described do not apply to job applicants, current and former employees/contractors, or to people whose Personal Information we collected in the context of their employment at another business (“business-to-business contact(s)”). If you are an employee, job applicant, or business-to-business contact and you have questions about how we use your Personal Information, please contact us as provided below.

Personal Information We Collect

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

Within the past 12 months, we collected the following categories of Personal Information about California consumers. Note that the specific pieces of Personal Information we collected about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

We collect the following categories of Personal Information (note that some Personal Information may be included in multiple categories):

• Identifiers (e.g., name, phone number, postal address, email address, I.P. address, and mobile device identifiers). We collect this information to communicate with you about our services; to recognize you when you use our Website and services; to detect and prevent fraud against you and/or us; and for any other internal business purposes.

• Internet usage information (e.g., information regarding your interaction with our online services). We use this information to facilitate, manage, and improve your Website experience; to improve our service; for research, and analysis, to maintain and improve the Website; to detect and prevent fraud against you and/or us; and for any other internal business purposes.

We may also collect Personal Information about you that does not directly fit within one of the categories defined by the CCPA. For example, we collect the contents of messages you submit to us through a general inquiry. We use the information included in your communications to communicate with you about our services, to provide customer service and support, to improve our Website, and to detect and prevent fraud against you and/or us.

Subject to the CCPA’s restrictions and obligations, our business partners and Service Providers may also use your Personal Information for some or all the above-listed business purposes.

We may share your Personal Information with our business partners or Service Providers.

Sources of Personal Information We Collect

We may collect your Personal Information directly from you when you provide us information through the Website; automatically through the Website via cookies and other tracking technologies; or from our business partners.

Disclosure of Your Personal Information

We share the following categories of Personal Information with our Service Providers and affiliates for a business purpose:

• Identifiers
• Internet Usage Information

The categories of persons to which we disclosed this Personal Information include affiliated and related companies and Service Providers.

California Privacy Rights

California residents have the right to submit certain requests relating to their Personal Information as described below. Please note that when submitting a request, you may be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us before we can process the request. Please allow 30 days for a response.

To submit a request, please email privacy@zagwear.com.

1. The right to know

If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:

• The categories of Personal Information we have collected about you.
• The categories of sources from which we collected your Personal Information.
• The business or commercial purposes for our collecting your Personal Information.
• The categories of third parties to whom we have shared your Personal Information.
• A list of the categories of Personal Information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
• The specific pieces of Personal Information we have collected about you.

You may submit a request for this information as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

2. The right to delete

You may request that we delete your Personal Information that we have collected directly from you and are maintaining. Following receipt of a request to delete, we will let you know what Personal Information we can delete from our records, and we will direct any of our Service Providers that may have processed your Personal Information on our behalf to delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct Service Providers to delete your Personal Information from their records. For example, if we need to: (1) retain your Personal Information to provide services to you; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug or repair errors; or (5) comply with a legal obligation.

3. Do Not Sell Rights

We do not “sell” your Personal Information based on the CCPA definition of a “sale” and we have not sold your Personal Information in the prior calendar year. We may share information for purposes described in our Privacy Policy.

4. Non-Discrimination

You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.

California Shine the Light

California law permits customers in California to request certain details about how their personal information is shared with third parties if personal information is shared for those third parties’ own direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at privacy@zagwear.com or write to us using the details below:
Zagwear
PO Box 623

Orangeburg, New York 10962

Requests must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mailing address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

How to Contact Us

For more information on your California privacy rights, please email us at privacy@zagwear.com.