Privacy Notice for California Residents

Effective Date: January 1, 2020
This Policy was last updated on: December 12, 2023

This Privacy Notice for California Residents (this "Notice") supplements the information contained in Pendleton Woolen Mills, Inc.’s ("Pendleton") Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the “CPRA”) (together, the “California Privacy Laws”) and any terms defined in the California Privacy Laws have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

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:

Publicly available information from government records. Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

Information We Collect
Column one has the category or type of information, column two has an example and column three identifies if the information is collected by Pendleton

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).	YES (only age and gender inferred by other information)
D. Commercial information.	Records of personal property, products 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.	YES
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.	NO
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.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We obtain the categories of personal information listed above from the following categories of 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 Website.
From third parties, for example, our business partners.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following 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, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product, 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 contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

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.

For data analytics, research, and marketing, including to personalize your website experience and to deliver content and product offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).

To third parties to market their products or services to you if you have not opted out of these disclosures.

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 California Privacy Laws.

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.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information (as the term “sell” is defined in the California Privacy Laws), subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out). When we disclose personal information to a service provider 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. The California Privacy Laws prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:
Affiliates, partners, and subsidiary organizations. Transaction processors.
Operating systems and platforms.
Advertising networks.
Our Website creator.
Internet service providers.
Data aggregators.
To third parties we use to support our business, including for research, marketing, and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads.
Data aggregators.

One such service provider is the data marketing vendor Oracle America, Inc. (“Oracle”), which provides cloud data services to us. We allow Oracle to place on our website cookies or similar technology (discussed below) to collect information about your activity on our website. Such information may include your IP address, what features of our site you use, and products you browse. Using this information, Oracle provides to us analytics about user activity so we can better understand how our site is used. Oracle may also add this information to its database for development and enhancement of its products and services and to provide targeted advertising services and behavioral marketing information to other businesses that use Oracle cloud data services. For more information about how Oracle uses this type of information, please review Oracle’s privacy policy (Section 5) for these services here.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Pendleton has disclosed the following categories of personal information for a business purpose (see Use of Personal Information):
Category A: Identifiers.
Category B: California Customer Records personal information categories (name, address, and telephone number only).
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.

Sales of Personal Information

In the preceding twelve (12) months, Pendleton has sold the following categories of personal information:
Category A. Identifiers.
Category B. California Customer Records personal information categories.
Category C. Protected classification characteristics under California or federal law.
Category D. Commercial information.
Category F. Internet or other similar network activity.
Category G. Geolocation data.

We sell your personal information to the following categories of third parties:
Data aggregators.

To third parties to market their products or services to you if you have not opted out of these disclosures.

To third parties we use to support our business, including for research, marketing, and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads. As detailed above in our explanation of how and with whom we share personal information, one entity to whom we sell personal information is Oracle, which provides data marketing analytics services to us and also includes information collected about user activity in its marketing database and analytics services to other businesses that subscribe to Oracle’s services.

Your Rights and Choices

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

Right to Know 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 12 months (“right to know”). Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 we 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:
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. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
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 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. 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 either calling us at 800-649-1512, emailing us at pendletoncustomerservice@penwool.com, or writing to us at Pendleton Woolen Mills Customer Service, PO Box 3030, Portland, OR 97208.

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

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, which may include:
Name, e-mail address, mailing address, and/or phone number.

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 sale opt-out rights, see Personal Information Sales Opt-Out.

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 another 45 days), we will inform you of the reason and extension period in writing.

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.

We will only use personal information provided in an opt-out request to review and comply with the request.

Personal Information Sales Opt-Out

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not collect the personal information of consumers we actually know are less than 18 years of age. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following page: Do Not Sell My Personal Information.

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 in to personal information sales at any time by calling 800-649-1512, emailing us at pendletoncustomerservice@penwool.com or writing to us at Pendleton Woolen Mills Customer Service, PO Box 3030, Portland, OR 97208.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your California Privacy Laws rights. Unless permitted by the California Privacy Laws, 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.

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 call 800-649-1512, email us at pendletoncustomerservice@penwool.com, or write to us at Pendleton Woolen Mills Customer Service, PO Box 3030, Portland, OR 97208.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this notice, 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 Notice, the ways in which Pendleton 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, or need to access this Notice in an alternative format due to having a disability, please do not hesitate to contact us at: 800-649-1512, pendletoncustomerservice@penwool.com, or Pendleton Woolen Mills Customer Service, PO Box 3030, Portland, OR 97208.