CCPA Privacy Policy

NAA Privacy Notice for California Residents

NAA respects your privacy and is committed to protecting it through compliance with this policy. This policy supplements NAA’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. NAA adopts this notice to comply with the California Consumer Privacy Act of 2018 (CCPA).

Information We Collect

Our websites collect 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 or device (“personal information”). In particular, the sites have collected the following categories of personal information from its consumers within the last 12 months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A 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.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Yes
K. Inferences drawn from other Personal Information.	Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’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) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Information Sources

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our sites or mobile apps.

Use of Your Information

To fulfill or meet the reason you provided the information. For example, if you share your 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 your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Websites, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Sharing Personal Information

NAA may disclose your Personal Information to a third party for a business purpose or sell your Personal Information, subject to your Right to Opt-Out (defined below) of those sales (see Personal Information Sales Opt-Out and Opt-In Rights, below).

Disclosure of Personal Information for Business Purposes

In the preceding twelve months, NAA has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.	Yes
Category B: California Customer Records Personal Information categories.	Yes
Category C: Protected classification characteristics under California or federal law.	No
Category D: Commercial information.	Yes
Category E: Biometric information.	No
Category F: Internet or other similar network activity.	No
Category G: Geolocation data.	No
Category H: Sensory data.	No
Category I: Professional or employment-related information.	Yes
Category J: Non-public education information.	Yes
Category K: Inferences drawn from other Personal Information.	No

Sale of Personal Information

In the preceding twelve months, NAA has sold the following categories of Personal Information:

Category A: Identifiers.	Yes
Category B: California Customer Records Personal Information categories.	Yes
Category C: Protected classification characteristics under California or federal law.	No
Category D: Commercial information.	Yes
Category E: Biometric information.	No
Category F: Internet or other similar network activity.	Yes
Category G: Geolocation data.	No
Category H: Sensory data.	No
Category I: Professional or employment-related information.	Yes
Category J: Non-public education information.	No
Category K: Inferences drawn from other Personal Information.	No

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that NAA disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights, below), we will disclose to you:

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 or selling that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
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.

Deletion Request Rights

You have the right to request that NAA 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) to:

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, 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously 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.
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:

Emailing us at [email protected]
By calling 833-866-9622
Only you, or a person registered with the California Secretary of State that you authorize 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 verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
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.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising Personal Information sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights below.

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 90 days) we will inform you of the reason and extension period in writing.

We will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding 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 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.

Personal Information Sales Opt-Out and Opt-In Rights

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us at [email protected] or by phone at 833-866-9622.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into Personal Information sales at any time by contacting NAA at the email address or phone number provided in this notice.

You do not need to create an account with us to exercise your Right to Opt-Out. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Do not sell my personal information page

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.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Page reviewed: 12/26/2019