Contemporary Inc.

PRIVACY NOTICE

This Privacy Policy applies to information we collect from you

Contemporary Inc. (“Cawley”) values your business and your trust. The privacy and confidentiality of your personal information is among our top priorities and we want you to know how we collect, use, share, and protect your information. "Cawley" means any entity that is a division of Contemporary Inc., including The Cawley Company, Cawley Digital ID, Cawley Plastic Printing, and Namebadges.com.

This statement describes our privacy practices for the websites where it is posted. This includes thecawleyco.com, cawleydigitalid.com, namebadges.com, cawleyprinting.com and mobile websites (“digital properties”). It also applies to information we collect at our Corporate Office via telephone or offline.

For information concerning privacy rights of California residents, please refer to PRIVACY NOTICE FOR CALIFORNIA RESIDENTS SUPPLEMENT at the end of this notice.

We collect various information about you

We collect information about you in three ways: directly from your input, through your use of our digital properties, and from third party sources.

· We collect information directly from you.

Contact details, such as your name, email address, social media handle, postal address and phone number;
Account login credentials, such as usernames and passwords, password hints and similar security information;
Other account registration and profile information, such as buying preferences;
Payment information, such as a credit or debit card number;
Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and/or
Interests and communication preferences, including preferred language.

· We collect information from your use of the digital properties.

Usage data, such as the features you used, items you purchased, the settings you selected, URL click stream data, including date and time stamp, and referring and exit pages, and pages you visited or searched for on the digital properties; and/or
Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data.

We collect this data through our servers and the use of cookies and other technologies. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the digital properties.

· We collect information about you from third parties.

Social networks when you grant permission to access your data on one or more networks;
Our service providers that help us monitor and maintain the digital properties; and/or
Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

We use information as disclosed and described here

To look at site trends and customer interests. We may use your information to make website or product improvements. We may also combine information we get from you with information we have gotten from third parties.
For marketing. We may notify you about products, special promotions, or offers. We might tell you about new website features or products.
To communicate with you about your account or our relationship. We may contact you to tell you about changes to this Privacy Notice or our website Terms and Conditions. We may also tell you about issues with your orders.

We may share information with third parties

Your information may be shared when legally permitted, including in the following situations:

Within our company (including our affiliated divisions as outlined above).
With third parties who perform services on our behalf. For example, we share information with vendors who perform services to collect information on our behalf.
If we have to in order to comply with the law. For example, we will share information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests.

Our websites may link to third party sites or services we don’t control

If you click on one of those links, you will be taken to websites we do not control. This policy does not apply to the information practices of that website. You should read the privacy policy of other websites carefully. We are not responsible for such third party's sites.

We may also provide social media features that enable you to share information with social networks and to interact with Cawley on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites. Actions you take in connection with social media features may be reflected in a manner visible to others; for example, if you “Like” us on Facebook, others may be able to see that you have done so.

We use standard security measures to protect your information

We use a variety of administrative, physical and technical security measures to safeguard your personal information. However, the Internet is not 100% secure so please use caution when using the Internet or providing personal information to others.

Our digital properties are not intended for children

Our digital properties are not intended for children under 16. We take steps on these sites to avoid collecting information online from children under 16. In some cases, children may give us information without us knowing about it. If you are a parent or legal guardian and believe that your child under 16 has provided us with personally identifiable information, please email us at website@thecawleyco.com or call us at 1-800-822-9539.

We store information in the United States

Information we maintain is stored in the United States. If you live outside of the United States, you understand and agree that this site is subject to U.S. laws, which may not afford the same level of protection as those in your country.

Data retention

We retain your personal information for as long as necessary to fulfill the transactions you have requested, and for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.

Accessing and updating your information

The digital properties may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is solely the responsibility of the user. Registered users may also close their account directly through the digital properties or by contacting us at website@thecawleyco.com.

Your communication preferences

You can customize and manage your communications preferences and other settings when you register with the digital properties, by updating your account features and preferences, by using the unsubscribe mechanism, or other means provided within the communications that you receive. You can also email us at mailoptout@thecawleyco.com or call us at 1-800-822-9539. We reserve the right to notify you of changes or updates to the digital properties whenever necessary.

SUPPLEMENT

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Notice of Contemporary Inc. (“Cawley”) and applies solely to visitors, users, and others who reside in the State of California. "Cawley" means any entity that is a division of Contemporary Inc., including The Cawley Company, Cawley Digital ID, Cawley Plastic Printing, and Namebadges.com. The following provisions apply to our processing of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the California Consumer Privacy Act of 2018 (“CCPA”). For such consumers, the provisions of this section prevail over any conflicting provisions of this Privacy Notice. We adopt this section of our Privacy Notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this section.

Information We Collect
Our digital properties 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”). Cawley has collected (or not collected, if indicated below) the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, or medical information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.	YES
D. Commercial information.	Records of products or services purchased, obtained, or considered	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal information covered by certain sector-specific privacy laws, 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.

Cawley obtains the categories of personal information listed above from the following categories of sources:

Directly from our clients or their agents. For example, from information that you provide to us when you create a user account on our website.
Indirectly from our clients or their agents. For example, through information we collect from you when you purchase a product through our website.
Directly and indirectly from activity on our digital properties. For example, as you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns.
From third-parties that interact with us in connection with the services we perform. For example, from analytics providers such as Google or providers of payment or delivery services.

Use of Personal Information
We may use and/or disclose the personal information we collect for one or more of the following business purposes:

To register you as a new customer
To process and deliver your order including:

Managing payments, fees and charges
Coordinating the delivery
Collecting and recovering money owed to us

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you

Cawley 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.

Sharing Personal Information
Cawley 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.

In the preceding twelve (12) months, Cawley has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category K: Inferences drawn from other personal information.

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

Our affiliated divisions.
Authorized shippers of Cawley’s products.
Service providers acting as data processors or website consultants.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Cawley disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

· The categories of personal information we collected about you.

· The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that Cawley 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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is 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.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
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

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights, and do not sell rights described above, please submit a verifiable consumer request to us by either:

Emailing us at website@thecawleyco.com.
Call us at 1-800-822-9539.

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. 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 provide a confirmation email to you within 10 days of receipt of a request. The confirmation email will explain how we will verify a request which will vary depending on the type of request made. We endeavor to respond to a verifiable consumer request for access or to delete within 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. We will deliver our response to the email address you provided when you made your request.

Any disclosures we provide may only cover the 12-month period preceding a verifiable consumer request. 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 law, 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.

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 privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by email at website@thecawleyco.com or phone (1-800-822-9539). You can also mail to:

The Cawley Company
Attn: Robert Petri
P.O. Box 2110
Manitowoc, WI 54221-2110