SUPPLEMENTAL PRIVACY POLICY FOR CALIFORNIA RESIDENTS

Effective Date: July 8, 2021

This Supplemental Privacy Policy for California Residents (“Supplemental Privacy Policy”) supplements and is expressly made part of the information contained in Global Sticks Express, LLC’s (“GSE,” “we,” “us” or “our”) Privacy Policy, available at https://www.shipsticks.com, https://www.shipskis.com, https://www.shipgo.com, https://www.shipcamps.com, https://www.luggagefree.com, https://www.shipschools.com, https://www.shipplay.com and applies solely to visitors to our websites, our customers and others who reside in the State of California (“consumers” or “you”).  We adopt this Supplemental Privacy Policy in part to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

1. Personal Information We Collect

For the purposes of this Privacy Policy, “Personal Information” means any 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”).  

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.  If you do not provide Personal Information when requested, you may not be able to benefit from the particular service, product or functionality if that information is necessary to provide you with such service, product or functionality or if we are legally required to collect it.

The CCPA describes several categories of Personal Information.  The following chart describes those categories and identifies which categories we have collected during the past 12 months.

Category	Examples	Collected?
Identifiers	A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, current or past job history, or other similar identifiers.	YES
Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport 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. Note: Some personal information included in this category may overlap with other categories.	YES
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).	YES
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies	YES
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
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.	YES
Geolocation data.	Physical location or movements.	YES
Sensory data	Audio, electronic, visual, thermal, olfactory or similar information.	NO
Professional or employment-related information	Current or past job history or performance evaluations.	NO
Non-public education information (per the Family Education 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.	NO
Inferences drawn from other personal information.	Profile 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 from 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

2. How We Collect Personal Information

Section I of our Privacy Policy, entitled “Information we Collect” for a description of how GSE collects Personal Information.

3. How We Use Personal Information

Section II of our Privacy Policy, entitled “How We Use the Information We Collect” describes GSE’s use of Personal Information.  To provide greater detail about our business purposes, GSE may use or disclose your Personal Information for one or more business purposes:

• To fulfill or meet the reason you provided the information.  For example, if you share your name and contact information to 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 Personal Information to facilitate new product orders or process refunds.  If you submit a review of our products or your experience with GSE, we may post that submission on our Sites.
• To provide, support, personalize and develop our Sites, 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 experience on our Sites and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Sites, 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 Sites, products and services, databases and other technology assets and our business.
• For testing, research, analysis and product development, including to develop and improve our Sites, 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.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of GSE’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by GSE about users of our Sites and our customers is among the assets transferred.

GSE 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.

4. How We Share Personal Information

Section III of our Privacy Policy, entitled “Who We Share Personal Information With” describes the categories of third parties to whom GSE may disclose your Personal Information.  When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the past 12 months, GSE has disclosed the following categories of Personal Information for a business purpose:

Category	Disclosed?
Identifiers	YES
Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))	YES
Protected classification characteristics under California or federal law.	YES
Commercial information	YES
Biometric information	NO
Internet or other similar network activity	YES
Geolocation data.	YES
Sensory data	NO
Professional or employment-related information	NO
Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	NO
Inferences drawn from other personal information.	NO

5. Sales of Personal Information

In the past 12 months, GSE has not sold Personal Information.

6. 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 those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that GSE disclose certain information to you about our collection and use of Personal Information over the past 12 months.  Once we receive and confirm your verifiable consumer request (see How to Exercise Your Rights), we will disclose to you, based on what you request:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business and/or commercial purposes for collecting or selling that Personal Information.
• The categories of third parties with whom we shared that Personal Information.
• The specific pieces of Personal Information we collected about you (also known as a data portability request).
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (1) sales, identifying the Personal Information categories that each category of recipient purchased; and (2) 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 GSE 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 How to Exercise Your 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 providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service 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.

How to Exercise Your Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at (855) 867-9915
• Emailing us at info@globalsticksexpress.com; or
• Visiting www.globalsticksexpress.com and completing the form in the contact us section. 

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 of that person.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request to exercise your access, data portability and/or deletion rights 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.  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.

Response Timing and Format

We attempt to respond to a verifiable consumer request within 45 days after we receive it.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.

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 prior to the date we receive the verifiable consumer request.  The response we provide will also provide 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

If you are 16 years of age or older, you have the right to direct us not to sell your Personal Information at any time.  We do not sell Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age.  Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA.  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.

However, we may 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 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 Civil Code Section 1798.83 permits visitors to our site who 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 us at info@globalsticksexpress.com.

7. Changes to this Supplemental Privacy Policy

GSE reserves the right to amend this Supplemental Privacy Policy at our discretion at any time.  When we make changes to this Supplemental Privacy Policy, we will post the Supplemental Privacy Policy on the Sites and update the Supplemental Privacy Policy’s effective date.  Your continued use of the Sites following the posting of changes constitutes your acceptance of such changes.

We welcome your questions, comments and concerns about privacy. Please email us at info@globalsticksexpress.com with your feedback pertaining to privacy. You also may write to us at:

Global Sticks Express

324 Datura Street, Suite 400

West Palm Beach, Florida 33401