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Effective: January 1, 2020
This CCPA Personal Information Policy (“Policy”) provides guidance to Club Champion LLC (“Club Champion,” “our,” “we” or “us”); its subsidiaries, and all of their respective staff members, employees, consultants, contractors, distributors, temporary workers, suppliers, agents, representatives, partners, and all personnel affiliated with such third parties (“Covered Persons”) on the management of Personal Information (as defined below) Processed (as defined below) by or on behalf of Club Champion, in accordance with the California Consumer Privacy Act (the “CCPA”). This Policy describes how Personal Information must be collected, handled, and stored to meet Club Champion’s data protection standards, and to comply with the CCPA. The purpose of this Policy is to ensure fair and transparent Processing of Personal Information.
Club Champion’s policy is to respect and protect Personal Information collected or maintained by or on behalf of Club Champion. All Personal Information must be Processed in a lawful, fair, and transparent manner and it is Club Champion’s duty to ensure the security and confidentiality of such Personal Information at all times. This Policy covers all Personal Information obtained from Club Champion’s customers and other California Residents (defined below) for which Club Champion collects Personal Information.
Covered Persons can contact the Club Champion Marketing Department at
Capitalized terms used but not defined in this Section 2 have the meanings given elsewhere in this Policy. In this Policy, unless stated otherwise:
“California Consumer Privacy Act” or “CCPA” means the California Consumer Privacy Act of 2018.
“California Resident” means a natural person who is a California resident, as defined in section 1798.140(g) of the CCPA.
“Verifiable Personal Information Request” means a California Resident request that a business disclose or delete Personal Information that it has about the California Resident pursuant to CCPA sections
1798.100, 1798.105, 1798.110, or 1798.115.
“Data Incident” means a breach of Club Champion’s security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information on systems managed
by or otherwise controlled by Club Champion. “Data Incidents” does not include unsuccessful attempts or activities that do not compromise the security of Personal Information, including unsuccessful log-in
attempts, pings, port scans, denial‐of‐service attacks, and other network attacks on firewalls or networked systems.
“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 California
Resident or household. (See Appendix A for examples of Personal Information.)
“Information Security Policy” means Club Champion’s internal information security policy.
“Process” means any operation or set of operations that are performed on Personal Information or on sets of Personal Information, whether or not by automated means.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its
shareholders or other owners, that Processes information on behalf of a business and to which the business discloses a California Resident’s Personal Information for a business purpose pursuant to a written
contract, provided that the contract prohibits the entity receiving the information from retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the
services specified in the contract for the business, or as otherwise permitted by the CCPA, including retaining, using, or disclosing the Personal Information for a commercial purpose other than providing the
services specified in the contract with the business.
(a) Club Champion Marketing Team Responsibilities
(b) Covered Person Responsibilities
Covered Persons may have access to the Personal Information of other Covered Persons and of our customers in the course of their employment, contract, volunteer period, internship or apprenticeship. Where
this is the case, Club Champion relies on Covered Persons to help meet its data protection obligations.
Covered Persons who have access to Personal Information are required:
Failing to observe these requirements may amount to a disciplinary offense, which will be dealt with under Club Champion’s disciplinary procedure. Significant or deliberate breaches of this Policy, such as accessing employee or customer data without authorization or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
(c) Operations Department Responsibilities
The Operations Department is responsible for:
All Personal Information should be Processed by lawful and fair means, in a transparent fashion. It is important to ensure that at or before Club Champion collects Personal Information, Club Champion provides California Residents with an appropriate notice (“Privacy Notice”) and information as to the categories, use and disclosure of the Personal Information Club Champion collects and Processes. Club Champion should only collect categories of Personal Information that have been appropriately disclosed to California Residents in a Privacy Notice. Covered Persons should limit Personal Information Processing to the minimum amount necessary to accomplish the purpose for which such Personal Information is collected, pursuant to Club Champion’s policies and procedures. Under no circumstances should Club Champion or Covered Persons sell Personal Information.
(a) California Resident Rights. California Residents have a number of rights in relation to their Personal Information. California Residents can;
(b) Verifiable Personal Information Requests. Verifiable Personal Information Requests may be made in writing or via phone. If you receive a Verifiable Personal Information Request, please notify the Club Champion Marketing Team immediately. It is Club Champion’s duty to confirm receipt of a request by a California Resident within 10 days and provide information about how Club Champion will Process the request.
The Club Champion Marketing Team will be responsible for sending the California Resident the appropriate Verifiable Personal Information Request form to verify the identity of the California Resident. (See Appendix B for sample email responses to common Verifiable Personal Information Requests and Appendix C for common Verifiable Personal Information Request forms.) Club Champion must receive the completed Consumer Right Request form prior to addressing the California Resident’s request.
Club Champion has a duty to respond to verified Requests to Know and Requests to Delete within 45 days from the date the request was received.
California Residents may exercise their rights by contacting the Club Champion Marketing Team at
(a) Verifiable Personal Information Requests.
If a Service Provider Processes Personal Information on behalf of Club Champion, Club Champion must have in place a written contract:
(b) All business units and departments shall work with Operations Department and the Club Champion Marketing Team to:
Club Champion may amend this Policy consistent with the requirements of the CCPA, including notice about any amendment.
This Policy is effective as of January 1, 2020.