Inland’s Privacy Policy – California Addendum

Last modified: April 21, 2023

Introduction

We respect your privacy and are committed to protecting it through our compliance with this policy.

This privacy policy (our “Privacy Policy”) applies to Inland Label and Marketing Services LLC and its subsidiaries and affiliates (“Inland”, “we”, “us”, or “our”) which operate following websites (collectively the “Websites”):

  • askinland.com
  • beerlabels101.com
  • cutandstackbeerlabels.com
  • inlandcareers.com
  • inlandflexo.com
  • inlandflexollc.com
  • inlandims.com
  • inlandlabel.com
  • inlandlabel.net
  • inlandlabelandmarketingservices.com
  • inlandlms.com
  • inlandmarketingservices.com
  • inlandpackaging.com
  • inlandperformance.com
  • inlandperforms.com
  • inlandpkg.com
  • inlandprinting.com
  • inlandusa.com
  • monetgraphics.com
  • myportal.inlandpackaging.com
  • powergreatpackaging.com
  • wepackageperformance.com
  • wepowergreatpackaging.com

This Privacy Policy identifies our practices for collecting, using, maintaining, protecting and disclosing your information.

Privacy Notice for California Residents

Effective Date: January 1st, 2023

This Privacy Notice for California Residents supplements the information contained in Inland’s Privacy Policy that this is attached to 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, as amended by the California Privacy Rights Act of 2020 (collectively referred to herein as the CCPA), and any terms defined in the CCPA have the same meaning when used in this notice. We may update this Privacy Addendum for California Residents as necessary and in the event of changes to California law. Note that this notice does not apply to our personnel. Please contact your supervisor if you are personnel and would like additional information about how we process your personal information.

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 websites have collected the following categories of personal information, as provided below.

Categories of Personal Information Inland has collected in the preceding 12 months:

  • Identifiers (e.g., name, alias, mailing address, email address, unique personal identifier, online identifier, account name, Internet Protocol address (IP address), or other similar identifiers).
  • Personal Information categories listed in the California Customer Records statute that identify, relate to, describe, or are capable of being associated with a particular individual (e.g., name, address, telephone number, employment, employment history, bank account number, credit card number, or debit card number, or any other financial information. Note, some of this information may overlap with other categories).
  • Commercial information (e.g., records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
  • Internet or other similar network activity (e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement).
  • Geolocation data (e.g., physical location).
  • Sensory data (e.g., audio, electronic, visual, or similar information).
  • Professional or employment related information (e.g., current or past job history).
  • Inferences drawn from other Personal Information (e.g., profile reflecting a person’s preferences).

Personal Information does not include information that is: (a) publicly available information; (b) lawfully obtained, truthful information that is a matter of public concern; (c) deidentified or aggregated consumer information; or (d) certain information excluded from the scope of CCPA, 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. For these purposes, “publicly available” information means information that is lawfully made available from federal, state, or local government records, or information we have a reasonable basis to believe is lawfully made available to the general public by you or from
widely distributed media; or information made available by a person to whom you have disclosed the information, if you have not restricted the information to a specific audience.

In addition, in interacting with some of the Websites, you may be directed to one or more other websites operated by third parties with which Inland may have a business relationship (“Third-Party Websites”). Inland does not control the collection of any information (including Personal Information) at any Third-party Websites. To the extent that you interact with any Third-Party Websites, you should review any notices of collection and privacy policies offered at this sites to understand whether and how any of your personal information my be collected, how that personal information may be used, and what rights you may have with regard to that collection and usage.

Categories of sources from which Inland has collected Personal Information:

  • Directly from you. For example, from forms you complete when registering for an account, receiving services through the portal, or submitting artwork and other documents through the services.
  • Indirectly from you. For example, from our operating systems and platforms.
  • Affiliates, parents and subsidiary organizations of Inland.
  • Service providers.
  • Business partners who we partner with to offer our products and services.
  • Advertising networks.

Inland does not intentionally collect or disclose any personal information of consumers under 16 years of age, nor do we have any actual knowledge of any such personal information having been collected or disclosed in the past 12 months.

Sensitive Personal Information

As amended, the CCPA provides for additional rights and protections related to “Sensitive Personal Information,” which is defined as personal information that reveals:

  • a consumer’s social security, driver’s license, state identification card, or passport number
  • a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
  • a consumer’s precise geolocation
  • a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership
  • the contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication)
  • a consumer’s genetic data

Sensitive Personal Information also is defined to include:

  • biometric information used to uniquely identify a consumer
  • personal information collected and analyzed concerning a consumer’s health
  • personal information collected and analyzed concerning a consumer’s sex life or sexual orientation

We do not collect any of the above categories of Sensitive Personal Information. Note in particular, with regard to access to our Websites by individuals outside of our organization, that we do not keep any account log-in information in combination with any passwords required to utilize those accounts, and we have no ability to view or retrieve any such passwords.

Use of Personal Information

We may use or disclose the personal information we collect and, over the prior twelve (12) months, have used or disclosed the personal information we have collected, exclusively for the business or commercial purposes specifically identified in our Privacy Policy.

Inland 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.

Disclosures of Personal Information for a Business Purpose

We may disclose your personal information to a third party for a business purpose. 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.

We disclose your personal information with the following categories of third parties for a business purpose:

  • Service providers.
  • Affiliates and business partners

In the preceding twelve (12) months, Inland has disclosed the following categories of personal information with the above categories of third parties exclusively for the business or commercial purposes specifically identified in our Privacy Policy:

  • Identifiers.
  • California Customer Records personal information categories.
  • Commercial information.
  • Internet or other similar network activity.
  • Geolocation data.
  • Sensory data.
  • Professional or employment-related information.
  • Inferences drawn from other personal information.

In the preceding twelve (12) months, we have not “sold” or “shared” your Personal Information. For these purposes, “sell” generally means to disclose personal information for monetary or other valuable consideration, and “share” generally means to disclose personal information for cross-context behavioral advertising.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. Those rights are as follows:

  • The right to know what personal information we have collected about a consumer, including:
    • the categories of personal information,
    • the categories of sources from which the personal information is collected,
    • the business or commercial purpose for collecting, selling, or sharing personal information,
    • the categories of third parties to whom we disclose personal information, and
    • the specific pieces of personal information we have collected about the consumer.
  • The right to delete personal information that we have collected from the consumer, subject to certain exceptions.
  • The right to correct inaccurate personal information that we maintain about a consumer.
  • Where we sell or share personal information, the right to opt-out of such sale or sharing.

The sections following below describe how to exercise those rights.

In addition, however, the CCPA, also provides consumers with additional rights related to the sharing of personal information (as “sharing” is defined above), related to the collection and disclosure of Sensitive Personal Information (as that term is defined above), and to not to receive discriminatory treatment by us for the consumer’s exercise of privacy rights conferred by the CCPA. However, as indicated above, we do not share your personal information, and we neither collect nor disclose any Sensitive Personal Information. In addition, as further detailed below, Inland commits to never discriminate against any individuals as a result of those individuals’ exercise of rights conferred under the CCPA.

Access to Specific Information 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. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will disclose to you:

  • The categories of personal information we collected about you, either directly or indirectly, including through or by a service provider or contractor.
  • The categories of sources for the personal information we collected about you, either directly or indirectly, including through or by a service provider or contractor.
  • 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, either directly or indirectly, including through or by a service provider or contractor (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.

The information to be disclosed as set forth hereinabove will cover the 12-month period preceding our receipt of your verifiable consumer request, unless otherwise required by applicable law. You may request that we provide personal information that we collected beyond the 12-month period, as long as it was collected on or after January 1, 2022. However, if providing personal information beyond the 12-month period preceding our receipt of your request would be impossible or would involve disproportionate effort, we may elect not to provide that information, but in so doing we will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot provide personal information beyond the 12-month period.

Deletion Request Rights and Data Retention

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 Rights), we will delete (and will direct any third parties to whom we may have disclosed your personal information to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is reasonably 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, to the extent the use of the personal information is reasonably necessary and proportionate for those purposes.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • 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.
  • 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.

Correction Request Rights

You have the right to request that we correct any inaccurate personal information that we may have collected from you, taking into account the nature of the personal information. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will take commercially reasonable efforts to correct (and will direct any third parties to whom we may have disclosed your personal information to correct) any such inaccurate personal information, unless an exception applies.

We may deny your correction request if we determine that the contested personal information is more likely than not accurate based on:

  • The nature of the personal information (e.g., whether it is objective, subjective, unstructured, sensitive, etc.)
  • How we obtained the contested information
  • Documentation relating to the accuracy of the information whether provided by the consumer, the business, or another source

We also may delete any contested personal information as an alternative to correcting the information if the deletion of the personal information does not negatively impact you, or if you consent to the deletion.

Exercising Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

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. 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.

In addition, you may use an authorized agent to submit a request to delete, a request to correct, or a request to know, as described herein. In such cases, we require the authorized agent to provide proof that you gave the agent signed permission to submit the request, and we also require you to do one of the following:

  • Verify your own identity
  • Directly confirm with us that you provided the authorized agent permission to submit the request

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 will confirm receipt of a verifiable consumer request within 10 business days after receiving it. Thereafter, we will 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.

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 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.

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.

Other California Privacy Rights

California 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 e-mail to [email protected] or write us at: 2009 West Avenue South, La Crosse, WI 54601, Attn: Walter Michels.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’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 California Privacy Addendum, the ways in which we collect and use your information described below 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 [email protected].