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Privacy Policy

MUTUAL TRADING CO., INC. PRIVACY NOTICE
PRIVACY POLICY
Last Updated: March 18, 2021

Scope of Disclosures
This Privacy Policy explains how Mutual Trading Co., Inc., our subsidiaries and our affiliated entities (collectively, “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information about individual residents of the State of California (“consumers” or “you”), either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this Privacy Policy have the same meaning as defined in the CCPA.

What is Personal Information?
When we use the term “personal information”, we mean 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 California household.

For the purposes of this Privacy Policy, personal information does not include the following:

  • Publicly available information from government records.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act or clinical trial data.
    • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.
    • Information relating to our employees, contractors, staff and other personnel, collected and processed within the employment context.

Our Collection and Use of Personal Information
We collect, use and disclose consumers’ personal information for our everyday business purposes, including marketing of our products and services; processing and fulfilling orders; maintenance of the safety, security, and integrity of our websites and other assets; compliance with legal and regulatory obligations, and more.

We collect some of this information from you directly, when you contact us by phone or email or vice-versa; when you submit a webform on our website; when you register to become our customer or subscribe to our incentive or promotional programs; or when you purchase our products and provide us with information necessary to fulfil the transaction (such as your name, address, telephone number and payment information). You may always choose not to provide us with this information, but if you choose not to, you may not be able to access certain of the features or products we offer.

In addition to any information which you provide to us directly, we may automatically collect certain personal information from you whenever you visit and interact with our website, in order to customize your experience with us. For instance, we use a variety of technologies (such as cookies) that may automatically or passively collect and store information about your online interactions, including your browser operating system and device type, general location, browsing history, and more. We treat such usage information as personal information to the extent required by the CCPA.

In certain circumstances, we may also receive certain personal information about you from third parties including service providers working on our behalf. For example, we may receive information about you when you apply for a job with us through one of our service providers, or when you participate in one of our training or certification programs. Such third-party information enhances our ability to best serve you.

What Categories of Personal Information Do We Collect?
Set forth below are the categories of personal information that we have collected from our consumers in the preceding twelve (12) months, as well as the sources from which we have collected such information, and the purposes governing its collection. Please note, however, that the types of personal information we collect, and the manner in which we collect them, depend largely on the nature of your relationship with us. Therefore, not all of the categories below may apply to you. If you wish to obtain further details about the personal information which we collect about you personally, you may exercise your right to know, which is described in the section of this Privacy Policy entitled “Your California Privacy Rights.”

Categories of Personal Information Collected Categories of Sources Commercial and/or Business Purpose for Collection and Use of Personal Information
Identifiers, such as full name, delivery or billing address, email address, telephone or fax number, social security number, driver’s license, unique personal identifiers (cookies, IP address, customer number, etc.). Direct from consumer when the consumer signs up for an account with us, places or returns an order or otherwise transacts with us, subscribes to our newsletter, contacts us by phone, email or webform, submits a product or service evaluation, etc.
Automated collection when the consumer interacts with our website through the use of cookies.
Third-party service providers such as shipping service providers that fulfil consumer orders, and recruiting platforms that receive and process job applications.
Commercial Purposes
• Promoting our products and services through our newsletter and promotional offers (such as first-time order discounts).
• Selling our products and services.
Business Purposes
• Detecting and protecting against security incidents.
• Debugging to identify and repair errors on our website.
• Conducting website analytics in order to improve website performance and provide interest- and location-based advertising and marketing.
• Improving our products and enhancing our services.
• Performing regular business functions, such as maintaining consumer accounts, providing customer service support, processing or fulfilling orders and transactions, verifying consumer information, and contracting with service providers to assist in these functions.
Personal information categories listed in the California Customer Records (Cal. Civ. Code § 1798.80(e)), such as name, bank or credit card number, and certain of the “identifiers” listed above (telephone number, address, email address, social security number, driver’s license, etc.).

Direct from consumer when the consumer signs up for an account with us, places an order or return or otherwise transacts with us, subscribes to our newsletter, contacts us by phone, email or webform, etc.
Third-party service providers such as anti-fraud service providers which help us prevent against fraud and other illegal conduct, recruiting platforms that receive and process job applications, and payment processors and shipping service providers that complete transactions and fulfil customer orders.

Commercial Purposes
• Promoting our products and services through our newsletter and promotional offers (such as first-time order discounts).
• Selling our products and services or enabling order refunds.
Business Purposes
• Detecting and protecting against fraudulent or illegal activities.
• Performing regular business functions, such as maintaining consumer accounts, providing customer service support, processing or fulfilling orders and transactions, verifying consumer payment information, and contracting with service providers to assist in these functions.
Commercial Information, such as purchasing or consuming history of our products or services, including records of products or services purchased, obtained or considered (including feedbacks on our events).

Direct from consumer when the consumer places an order, exchange or return or otherwise transacts with us for our products or services.
Third-party service providers such as payment processors when the consumer purchases, returns or exchanges certain products or services.

Commercial Purposes
• Selling our products and services to companies and consumers.
Business Purposes
• Performing regular business functions, such as providing customer service support, processing or fulfilling orders and transactions, verifying consumer information, accounting, and contracting with service providers to assist in these functions.
• Conducting analytics of purchase activities such as records of products or services purchased, obtained or considered (including feedbacks on our events) for general marketing and inventory purposes.

Internet/Network Information, such as browsing and search history on our Website (including the pages viewed, time and duration of views), IP address, device and browser type, operating system, internet service provider, etc.

Automated collection when the consumer interacts with our website through the use of third-party cookies and logs.

Business Purposes
• Detecting and protecting against security incidents and fraudulent or illegal activities.
• Debugging to identify and repair errors on our website.
• Conducting website analytics in order to improve website performance.
• Tracking consumers’ online interactions and browsing history for general marketing and inventory purposes.
Geolocation Data, such as your IP address, general device physical location, etc.

Direct from consumer when the consumer contacts us by phone, email or webform.
Automated collection when the consumer interacts with our website through the use of third-party cookies.

Business Purposes
• Detecting and protecting against security incidents and fraudulent or illegal activities.
• Debugging to identify and repair errors on our website.
• Conducting website analytics in order to improve website performance and limit consumers’ experience on our website to local products and services.

Professional/Employment Information, such as professional background and work experience

Direct from consumer when the consumer contacts us directly regarding employment opportunities, or to establish new business accounts.
Third party service providers such as recruiting platforms that receive and process job applications.

Business Purposes
• Conducting hiring activities, including reviewing and interviewing job applicants and processing their applications.
• Performing regular business functions, verifying consumer information, accounting, approving new business accounts, and contracting with service providers to assist in these functions.

Inferences, such as preferred language, age-range, gender, product interests, etc.

Direct from consumer when the consumer signs up for an account with us, contacts us by phone, email or webform, submits a product or service evaluation or complaint, or based on previous purchases or inquiries relating to our products or services.
Automated collection when the consumer interacts with our website through the use of third-party cookies.
Third party service providers such as website analytics providers.
Business Purposes
• Tracking consumers’ online interactions and browsing history in order to better understand consumer interests and market trends.

Disclosure and Sale of Personal Information
In the last twelve (12) months, we have not sold personal information about you, but we have, at times, disclosed certain categories of personal information to third parties for business purposes.
We employ third party service providers to perform functions on our behalf that, from time to time, require us to disclose your information. Such functions may include, but are not limited to, securing our data and IT systems, processing payment and shipping information to complete consumer transactions, performing data analysis, and more. In some instances, we may also be required to disclose your personal information to comply with a legal obligation or governmental request, to detect and prevent fraud, to verify or enforce our Terms of Service or other applicable policies, or to otherwise protect the rights, property, safety or security of you, third parties, or the general public. Further details about the categories of your personal information, and the “business purposes” for which we disclose such categories, are set forth in the table below.
We may also allow third party partners and providers to collect certain of your information directly through our services, in order to optimize our services and business relationships, personalize online content on our website, and more.

Minors Under Age 16
Our website is not directed to, and we do not intentionally or knowingly collect the personal information of consumers less than 16 years of age. Furthermore, we do not and will not “sell” the personal information of consumers we know to be less than 16 years of age.

In the last twelve (12) months, we have disclosed for a business purpose the categories of personal information to the categories of third-party service providers, listed below. Please note, however, that whether or not we disclose your personal information and the nature of such potential disclosure (including the types of personal information disclosed, the business purposes involved, and the categories of recipients) depend on the nature of your relationship with us. Therefore, not all of the categories below may apply to you. If you wish to obtain further details about the disclosures of personal information which are specific to you, you may exercise your right to know, which is described in the section of this Privacy Policy entitled “Your California Privacy Rights.”


Category of Personal Information

Disclosures for a Business Purpose
&
Categories of Recipients

Identifiers

website analytics/marketing providers
data security and IT support providers
internet and cloud service providers
Commercial Information

website analytics/marketing providers
Internet/Network Information<

data security and IT support providers
website analytics/marketing providers
Geolocation Data

data security and IT support providers
website analytics/marketing providers

Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):


The Right to Know


You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last twelve (12) months, upon verification of your identity:
• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information we have collected about you;
• The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
• The business or commercial purposes for collecting or, if applicable, selling personal information about you.


The Right to Request Deletion


You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.


The Right to Opt-Out
of Personal Information Sales



You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.


The Right to
Non-Discrimination



You have the right not to receive discriminatory treatment for exercising any of the rights described above.

However, please note that if your exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), fulfilment of that right may mean that we are no longer able to provide you with our products or services or engage with you in the same manner.

How to Exercise Your California Privacy Rights

How To Exercise Your Right to Know or Right to Deletion
To exercise your right to know and/or right to deletion, please submit a request by:
· Emailing: with the subject line “California Rights Request,” or
· Calling: 877-779-3389

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity

How To Exercise Your Right to Opt-Out of Personal Information Sales
As explained above, we do not currently sell your personal information to third parties. However, if at any point we begin selling personal information to third parties for monetary or other valuable consideration (a change which will be reflected in this Privacy Policy), then we will provide you with a right to opt-out of such sales.

Authorized Agent
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (a) you provide sufficient evidence to demonstrate that the requestor is an authorized agent, by directly confirming that with us or by providing us with your signed written permission or a power of attorney; or (b) you successfully verify your own identity with us.

“Shine the Light”
California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of personal information to third parties for their direct marketing purposes. At this time, we do not disclose your personal information to third parties for their direct marketing purposes, as defined by the Shine the Light law

Financial Incentives
We currently offer the following financial incentives in exchange for the collection of certain personal information:
· Discount for Online Newsletter Subscription: If you opt-in to receive our online newsletter service by providing us with your email address for that purpose, we will send you a regular email newsletter that includes promotions and occasional discounts. We require your name or alias and email address in order for us to send you our newsletter. You can unsubscribe from our newsletter at any time by clicking on the unsubscribe link provided at the bottom of each newsletter.
· First-Time Purchase Discount: We offer a discount code for first-time purchases. If you wish to make use of such discount, you will need to create an account with us in order for us to verify that you are a first-time customer and are therefore eligible for the discount. This will require you to provide us with certain identifiers, including your name, address, email and telephone number. In addition, you will need to complete a first-time purchase (which will require you to enter additional transaction information, including your payment, shipping and billing details). All the personal information we collect from you for purposes of this discount is necessary to enable its utilization by first-time customers. At any time after using the discount (or before, if you wish to forfeit such discount), you are able to delete your account and/or submit a request to exercise your right to deletion of your personal information.

Updates to This Privacy Policy
We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the "Last Updated" date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you with notice to the extent required by law, including notice to your registered email address, prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us
If you have any questions or requests in connection with this Notice or other privacy-related matters,
please send an email to .

Alternatively, inquiries may be addressed to:

Mutual Trading Co., Inc.
Customer Service
4200 Shirley Ave.,
El Monte, CA 91731
TEL (213) 626-9458