USA Privacy Addendum
1. Commitment and Scope
1.1 This U.S. Privacy Addendum supplements the information contained in the Global Privacy Policy and our Fair Processing Notice.
1.2 Charles Taylor complies with the requirements of the prevailing data protection legislation with regard to the collection, storage, processing and disclosure of personal information and is committed to upholding the core data protection principles.
1.3 For those who work for Charles Taylor in the USA, the Charles Taylor Employee Privacy Notice is accessible online via our intranet.
2. Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia Residents
If you are a resident of any of the states listed above, you may rely on the Global Privacy Notice and the additional information below.
During the past twelve (12) months, our practices with respect to the collection, use and disclosure of your personal information is reflected in the Global Charles Taylor Privacy Notice and Fair Processing Notice.
If you are a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, you have the rights to:
You may exercise these rights by completing the form here or by contacting dpo@charlestaylor.com.
You must submit a verifiable request to exercise your rights, except, for Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska New Hampshire, New Jersey, Oregon and Rhode Island residents, the right to opt-out of the sale of personal data and processing of personal data for targeted advertising purposes. The verifiable consumer request must:
We reserve the right to verify your identity in connection with any requests regarding personal data to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals to exercise rights with respect to that information. Except where required by applicable law, we cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.
In the event we deny your request, you may appeal our determination not to act on your request within a reasonable period after receipt of our notice. You can submit your appeal in the same manner you submitted your request.
We do not engage in “cross-context behavioral advertising” or share Personal information with third parties for such purposes. We disclose identifiers and internet or other electronic network activity information to certain third parties in exchange for valuable services, such as our business partners who we may work with to improve our services, to provide analytics insights or other business benefits. Under Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island and Texas laws, such processing may qualify as a “sale”. To exercise your opt-out right of the sale of personal information, of if you are an authorized agent of a consumer attempting to exercise the consumer’s opt-out right, please click Do Not Sell or Share My Personal Information. For authorized agents, please note that you must be on the consumer’s device (e.g., laptop, desktop or mobile device) while clicking on the “Do Not Sell or Share My Personal Information” link for the consumer’s right to opt out to be properly exercised.
3. California residents
3.1 If you are a California resident from whom we collect personal information as a business under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), you may rely on the Global Privacy Notice and the additional information below.
3.2 For the purpose of this section for California residents, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA. Personal Information does not include information that is publicly available, deidentified, or aggregated (as those terms are defined in the CCPA) or otherwise excluded from the scope of the CCPA.
3.3 Charles Taylor does not process your data for targeted advertising purposes (also referred to as “sharing” under the CCPA) or carry out profiling on your Personal information. You will not be discriminated against for exercising any of your data rights.
3.4 We do not use, disclose or sell sensitive Personal information for purposes which would require us to offer consumers the right to limit our collection and processing of this data under the CCPA.
3.5 We may disclose your Personal Information in limited circumstances, specifically for fraud prevention and identity verification purposes, as detailed further below. We do not engage in “cross-context behavioral advertising” (“CCBA”)” or share Personal information with third parties for such purposes.”
3.6 CCPA Definition of ‘Selling’ Personal Information
The CCPA defines “selling” Personal Information to include providing it to a third party in exchange for valuable services. We disclose identifiers and internet or other electronic network activity information to certain third parties in exchange for valuable services, such as our business partners who we may work with to improve our services, to provide analytics insights or other business benefits, which may constitute a “sale” under the CCPA.
4. Categories of Personal Information that we Collect and Disclose
4.1 The following is a list of categories of Personal Information (as defined by the CCPA) we have collected and disclosed for a business purpose in the prior 12 months:
5. Sources of Collection of Personal Information
5.1 Charles Taylor obtains the categories of personal information referred to above from the following categories of sources:
5.2 We will only use your information in ways we are allowed to by law, which includes only collecting as much information as we need.
6. Use of your Personal Information
6.1 During the past twelve (12) months, our practices with respect to the collection, use and disclosure of your personal information is reflected in the Global Charles Taylor Privacy Notice and Fair Processing Notice.
6.2 We do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit under the CCPA.
We do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit under the CCPA.
7. Collection and Sale of your Personal Information to Other Parties
7.1 Under the CCPA “Sale” is the selling, sharing, or disclosing of consumers’ personal information in exchange for valuable consideration.
7.2 We only sell your Personal Information for fraud prevention and identity verification purposes, as detailed further below. We do not “share” Personal Information with third parties for “cross-context behavioral advertising” (“CCBA”).
7.3 The following is a list of categories of Personal Information (as defined by the CCPA) we have sold.
8. Retention
8.1 We use the following criteria to determine the period of time for which we retain each category of personal and sensitive information:
9. Your Privacy Rights
9.1 If you are a California resident, you have the following consumer rights, in line with the California Consumer Privacy Act of 2018 (CCPA).
9.2 You have the right to request that Charles Taylor disclose certain information to you about our collection and use of your personal information over the past 12 months. Specifically, you may request that we disclose to you: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which the Personal Information was collected; (c) the business or commercial purpose for collecting, selling, or sharing Personal Information; (d) the categories of third parties with whom we disclose Personal Information; (e) the specific pieces of Personal Information we have collected about you; (f) the categories of Personal Information that we have sold or shared about you and the categories of third parties to whom the Personal Information was sold or shared; and (g) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
9.3 You have the right to request that Charles Taylor delete your personal information, subject to certain exceptions. After we receive and validate your request, we will delete your personal information as well as direct our service providers to delete your personal information, unless an exception applies.
Please note that you may only make a verifiable consumer request twice within a 12-month period.
9.4 You have the right to request that we correct inaccurate personal information about you. We will take into account the nature of the personal information and the purposes of the processing of the personal information in responding to your request. We will process your request if we receive a verifiable request and we will use commercially reasonable efforts to correct the inaccurate personal information as directed pursuant to the CCPA.
9.5 You have the right, at any time, to direct us to limit our use of your sensitive personal information only to that use which is necessary to perform the services or provide the goods reasonably expected or to fulfil the reason that we collected such information and/or other permissible business purposes. Please see the Global Charles Taylor Privacy Notice and Fair Processing Notice which detail the types of sensitive personal information we may collect. 12.6 We do not use or disclose your sensitive personal information for purposes other than to provide you with products and/or services. However, note that this information may be used, or disclosed to a service provider or contractor pursuant to a written agreement in order to provide such products and/or services. If you choose to limit such use, you can opt-in to such use again by contacting us via email. Note that this right does not apply to sensitive personal information that is collected or processed without the purpose of inferring characteristics about you. 12.7 We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within those forty-five (45) days. To submit a verifiable consumer request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide may differ depending upon the type of request, the type, sensitivity, and value of the Personal Information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. If we cannot verify your identity or authority, we will inform you and will not be able to comply with your request.
If you wish to exercise any of your consumer rights to access, portability, deletion or correction, please submit a verifiable consumer request by calling us at 800-928-1342, completing the form here or contacting dpo@charlestaylor.com.
9.8 Only you, or a person registered with the California Secretary of State that you authorize (“authorized agent”) 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.
We will not discriminate against you for exercising any of your CCPA rights.
If you are acting as an authorized agent to make a request to know, delete, correct, or opt out on behalf of a California resident, you may submit a request by contacting dpo@charlestaylor.com.
Please note that we will require you to attach a written authorization signed by the resident whose Personal Information will be subject to the request.
9.9 Right to Opt Out of the Sale or Sharing of Personal Information. You have the right to direct us not to sell or share your Personal Information with third parties. To exercise this right, and you are an authorized agent of a consumer attempting to exercise the consumer’s opt-out right, please click Do Not Sell or Share My Personal Information. For authorized agents, please note that you must be on the consumer’s device (e.g., laptop, desktop or mobile device) while clicking on the “Do Not Sell or Share My Personal Information” link for the consumer’s right to opt out to be properly exercised. You may also exercise your opt-out right by emailing us at us.marketing.com. For more information on what may constitute a “sale” or “sharing” of Personal Information, please refer to Section 6.6 above.
9.10 Opt-Out Preference Signals. Charles Taylor recognizes opt-out preference signals, such as the Global Privacy Control (“GPC”), as valid requests to opt out of the sale or sharing of Personal Information.
9.11 Minors’ Personal Information. Charles Taylor does not have actual knowledge that it sells or shares the Personal Information of consumers under the age of 16.
10. Changes to this Privacy Notice
10.1 Charles Taylor reserves 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 services following the posting of changes constitutes your acceptance of such changes.
April 2026