Supplemental California Consumer Privacy Act Disclosures
In these Supplemental California Consumer Privacy Act Disclosures ("CCPA Disclosures"), we, ITT Inc., disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 ("CCPA") and supplement the disclosures in our other privacy notices. These CCPA Disclosures are effective January 1, 2020. You can download a PDF version here.
I. Who and what information is subject to these CCPA Disclosures?
The CCPA protects California residents as "consumers" with respect to their personal information. A number of statutory exceptions apply under the CCPA. As a result, some of these CCPA Disclosures do not apply to the following:
- personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency;
- personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business;
- personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; and
- personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.
II. How can a consumer with a disability access these CCPA Disclosures?
Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this document.
III. CCPA Notice at Online Collection
In this CCPA Notice at Collection Online, we explain what categories of personal information we collect from consumers online and the purposes for which we use them, at or before the point of online collection.
Information You Actively Submit: If you send an email to our team, fill out a form on our website, or otherwise send us information through our website, we collect personal information about you, which may include the following:
- Contact Data, which may include your name, the name of your organization, your address, telephone number and email address;
- Account Data, which may include your Contact Data, login information such as your username and password, and any personal information you provide to us through your account;
- Transaction Data, which may include the details of any products or services that you or your organization purchased or provided to us, and details necessary to process such transactions, such as payment details;
- Social Media Data, which may include your social media account name, social media interactions with us (e.g., if you "like" or "share" something you see on our social medial platforms), and forum posts; and
- Correspondence Data, which may include your requests, comments, survey responses, and any other information you actively provide to us.
Information Automatically Submitted on our Website: When you use our website, we automatically collect certain information about the computer or device you use to access our website and your interactions with our website, including the following:
- Technical Data, which includes your domain name, browser type, internet protocol (IP) address, device identifier, user settings, location information, mobile carrier, and the operating system of your device; and
- Usage Data, which may include the pages you access or visit, the dates and times of your visits, whether you received or opened our emails, the identification number of any cookie on the computer previously placed by us, and, if you have an account on our online services, your use of our online services in connection with your online account.
Information Collected from Third-Party Sources: If you have identified yourself to us as a customer, supplier, or prospective customer or supplier, of ours, we may collect the following personal information about you from third-party sources: your organization, location, contact information, and work functions. These third-party sources include public profiles on company and social media platforms, and industry group databases.
How We Use Your Personal Information: We use the following categories of personal information for the following purposes:
- Contact Data to communicate with you.
- Account Data to establish an account for you, manage the account, and provide online services and functionality to you via your account.
- Transaction Data to enter into transactions with you or your organization, and manage our relationship with you or your organization.
- Social Media Data to interact with you through our social media platforms.
- Correspondence Data to respond to any specific comments or questions you may have, and consider any survey feedback you provide to help improve our products and services.
- Technical Data and Usage Data to provide, maintain, monitor, secure, debug, customize and optimize our online services to and for you, provide you with customer service and technical assistance, measure interest in our services, and develop and improve our products and services.
- Information Collected from Third-Party Sources to supplement information provided by you, so that we can verify information that you have provided to us and enhance our ability to provide you with information about our business, products and services.
We also use your personal information for the following purposes (collectively, the " General Processing Purposes"), as permitted by applicable law:
- Performance of Contracts: To perform our obligations and exercise our rights under our Terms of Use and any other agreement that you conclude with us.
- Compliance with Laws: To verify your identity, comply with any legal obligations that apply to us, and respond to requests from government authorities.
- Protection of Legal Interests: To protect the legal interests, health or safety of you, us, or third parties, such as to prevent fraud and protect the security of our network and information.
- Marketing Activities: To provide you with offers, advertisements and marketing content that we believe you may be interested in, and tailor the content based on our understanding of your preferences.
- Research and Development: To improve our products and services, develop new products and services, and perform historical, scientific or statistical research. We generally seek to use your personal information to generate deidentified or aggregated data sets and only process such data sets for these purposes.
- Merger or Sale: In the event that we, or some or all of our assets are acquired by or merged with a third-party entity or in connection with a merger, acquisition, sale, or other change of control, we may transfer some or all of the personal information that we have collected about you to another organization as part of that transaction. If we intend to transfer your personal information in connection with such a transaction, we will proceed as permitted or required by applicable law.
IV. Supplemental CCPA Disclosures
We provide additional disclosures about consumer rights and our personal information handling practices in the preceding twelve months.
1. Right to Know About Personal Information Collected, Disclosed, or Sold
We describe here the personal information we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically ("right to know"). To submit a request to exercise the right to know, please populate the webform accessible here , call our toll-free phone number 1-888-546-4972 or submit an email request to privacy@itt.com and include "California Request to Know" in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.
We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
2. Our Personal Information Handling Practices in 2019
We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.
Category of personal information | Purposes of collection | Categories of sources of personal information | Categories of third-party recipients of personal information |
---|---|---|---|
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers | We collected this information for the purposes described in Section III above. | We collected this information directly from the consumer. We may supplement the information collected directly from consumers with information received from third-party sources, such as company websites, social media platforms, and industry group databases, as described more fully in Section III above. | We shared this information with the following categories of third parties: -Service providers, including companies we retain to provide hosting, marketing, data enhancement, billing and collections, analytics, support, technical, operational, security, consulting, or other services to us; -Government entities as required by applicable law; -Other recipients at the consumer’s direction or with their consent; -Third parties in the event of a proposed or actual business transaction involving all or any portion of our business. |
Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number, or financial information. | Same as above. | Same as above. | Same as above. |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Same as above. | Same as above. | Same as above. |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. | We collected this information: -To provide, maintain, monitor, secure, debug, customize and optimize our online services to and for consumers, provide consumers with customer service and technical assistance, measure interest in our services, and develop and improve our products and services; and -To fulfil the General Processing Purposes described in Section III above. | Same as above. | Same as above. |
Geolocation data. | Same as above. | Same as above. | Same as above. |
Audio, electronic, visual, or similar information. | We store and process personal information electronically, and collected and used electronic information for the purposes described in Section III above. We collected audio and visual information via security cameras at our premises to secure our network, systems and premises and for the General Processing Purposes described in Section III above, other than for Marketing Activities. | Same as above. | Same as above. |
Professional or employment-related information. | We collected this information to verify information that consumers provided to us, to enhance our ability to provide consumers with information about our business, products and services, and for the General Processing Purposes described in Section III above. | Same as above. | Same as above. |
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences and characteristics. | We collected this information for the General Processing Purposes described in Section III above. | Same as above. | Same as above. |
3. Disclosures of Personal Information; No Sale
Over the preceding 12 months, we disclosed certain categories of California residents' personal information to the categories of third parties as shown in the table above. We do not and will not sell California residents' personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
4. Right to Request Deletion of Personal Information
You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please populate the webform accessible here or submit an email request to privacy@itt.com and include "California Request to Know" in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.
We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
5. Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business. We do not, and will not, sell your personal information.
6. Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
You may not be discriminated against because you exercise any of your rights under the CCPA.
7. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 1 and 4 above:
- Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to ITT, LLC, 831 Pearl Street, Boulder, Colorado, 80302; and
- Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
8. Contact for More Information
If you have questions or concerns regarding our privacy policy or practices, you may contact us at: privacy@itt.com and Global Data Privacy Counsel, ITT Inc., 100 Washington Boulevard, 6th Floor, Stamford, CT 06902.