Privacy Policy

PRIVACY POLICY

Privacy Policy 

Last Updated: March 17, 2021

Introduction

Kingston is a global organization comprising of a group of entities affiliated with, controlled by or under common control with Kingston Technology Company, Inc Accordingly, any references to ‘Kingston,’ ‘our,’ ‘we,’ or ‘us’ outlined in this Privacy Policy, related policies, or elsewhere on our website (the ‘Website’) refer to Kingston Technology Company, Inc. and its affiliate entities that are either controlled by or under common control with Kingston Technology Company, Inc. unless otherwise specified.

This Privacy Policy applies to all information, including Personal Information, that Kingston collects about you.

If you are located in the European Union (“EU”) or Switzerland and subject to the General Data Protection Regulation (“GDPR”), please review Privacy Policy and see the below Section 14 for a description of your rights and other information related to the GDPR.

If you are a California resident and subject to the California Consumer Privacy Act, California Civil Code § 1798.100 et seq. (with any implementing regulations and as may be amended from time to time, “CCPA”), please review this Privacy Policy and refer to the California Residents and the CCPA section for a description of your rights and other information related to the CCPA.

OVERVIEW

Your privacy is important to us. This Privacy Policy explains what information we collect from you and how we use that information. It covers the following:

  • What types of information we collect
  • How we use information
  • With whom we share information
  • What rights you may have regarding certain information
  • The steps we take to protect your information
  • How you can contact us if you have questions or concerns

Please read the following sections of this Privacy Policy carefully and contact us with any questions or concerns you may have about how we collect and use your information. Keep in mind that the rights discussed in certain sections of this Policy may be subject to exemptions or other limitations under applicable law.

WHAT INFORMATION DO WE COLLECT?

Kingston collects Personal Information and other information as part of its general business operations, to provide you with services, to respond to requests and offer customer support, to fulfill legal and contractual obligations and to build and improve products and services. When we use the term “Personal Information” we mean information that can help us directly or indirectly identify you, such as your name, address, telephone number, e-mail address, Internet Protocol (“IP”) address, or other online identifiers. We collect some of this information directly when it is provided by you or your representative, other information we collect about you automatically when you visit our Website, and some information we collect from other sources such as our service providers, software applications, and at tradeshow events.

Information You Provide to Us Directly

We or our service providers collect your Personal Information and other information when you directly provide it to us. For example, we collect Personal Information when you make a purchase, use or register our products and services, take part in marketing campaigns, participate in product testing, apply for employment and contact our customer support.

Depending on how you interact with us, we collect the following Personal Information about you:

  • Identifiers like Name and Contact Information. Your first and last name, email address, postal address, phone number, online identifier, Internet Protocol address, social security number, driver’s license number, online identifiers, and other similar contact data.
  • Characteristics Information. This might include your gender, marital status, race, national origin, military or veteran status, or disability.
  • Product Purchase and Registration Information. The type of product being registered, the serial number, date of purchase, or other product identifying information, as well as your credit card number and other billing related information.
  • Usage and Electronic Network Activity Information. Information about the product and features you use, including information about your hardware and software, information about your use of our Website, how our products perform, as well as your settings.
  • Geolocation Data. Information about your location or the location of your device.
  • Responses to Surveys and Promotional Events. Responses to questions and interactions with us on social media, competitions, and at events, or through surveys that we provide to you.
  • Correspondence and Communications. Records of information provided by you when you contact us with feedback, comments, questions or for any other reason. This includes audio, visual and electronic information, for example recordings of calls with our customer support service.
  • Inferences Drawn from Other Information. Certain information we collect from the above categories may be used to create a profile reflecting your preferences, tendencies, and the like.

Product Purchases

When you purchase products through the Website, we require that you provide us with your first and last name, contact information, payment and billing information, and shipping information. This information is collected and used to process your order and payment. If you choose not to provide your Personal Information at the point of collection, you will not be able to purchase products through the Website.

When you order any product and/or request an RMA (Returned Merchandise Authorization) on our Website, you may be redirected to a third-party payment gateway service where you will be asked to provide your credit card information including your credit card number, card security code, the expiration date, and the billing address.

Product Registration

When you register a product, we may ask for your name, address, e-mail address, telephone number, the type of product, the serial number and date of purchase or other product-identifying information. If you choose not to provide this information, you will not be able to register products and warranty on the Website; however, you may continue to use the products.

Customer Service and Similar Communications

If you contact us with feedback, comments, questions, or for any other reason, we may keep records of that correspondence and collect your Personal Information, such as your name and contact information, in order to process your enquiries, respond to your requests and improve our products and services.

Surveys, Promotional Communications and Events

In order to improve our products and services, we may use your Personal Information (including your identity, contact details, and usage data) to send you online surveys. If you elect to receive product updates and promotional emails, we will use your Personal Information (including your identity and contact details) to send you newsletters and e-mails that periodically list current special offers, promotions, and deals.

Information We Collect About You Automatically Through Your Use of the Website or Other Services

When you visit our website, and interact with us through online media and advertisements, certain information about your visit is automatically logged though the use of various tools:

  • Cookies. Cookies are text files containing small amounts of information which are stored on your browser or your device when you visit our Website, online media, and advertisements. For additional information on the various cookies we use and the purposes for which we use them, please read our Cookie Policy.
  • Log Files. Records of a range of variables about your visit to our Website, including: (1) IP addresses; (2) browser versions and types; (3) internet service providers; (4) pages visited; (5) entry/exit pages: (6) referring sites; (7) platform types; (8) demographic information; and (9) connection speed.
  • Navigational Data. Information gathered while you browse our Website and other third-party sites, including technical, usage, and navigational data that shows what pages you have visited and how long various features are used.
  • IP Addresses. When you access the website, our servers may record your IP address.

Information We Collect About You from Other Sources

We also collect your Personal Information and other information from additional sources as permitted by law, including from entities that provide us services, such as payment processing services.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect for purposes associated with the growth, maintenance, and management of our business. Depending on how you interact with us, we use your Personal Information and other information for the following purposes:

  • Communication with You. This includes using Personal Information to send you messages, ship products, provide customer care, and respond to your requests.
  • Business Operations. This includes operating our Website, facilitating product purchases, accounting, auditing, billing, and collection activities as well as security, crime or fraud monitoring and prevention, protecting legal rights, and performing contractual obligations.
  • Managing and Developing Products and Services. This includes using information to offer product testing experience and to carry out internal research to develop and improve existing products and services, as well as using information about your interactions with our Website or advertisements to improve user experience.
  • Advertising and Marketing. This includes providing you with communications, conducting contests and promotional events, and providing you with personalized content, where you have consented, as applicable.

Use Cases of Your Personal Information

Product Purchases, Registration, and Similar Transactions

We use your Personal Information to perform our contract to supply you with our products and to communicate with you about your purchases. We use the information collected from you when you register a product to fulfil our contractual and legal obligations including providing you with support and information and managing our relationship with you.

Responding to Requests, Feedback, and Inquiries

We use your Personal Information and information you provide to us about a product or a request in order to communicate with you and respond to your requests. If you contact us with feedback, comments, and questions or for any other reason, we may keep records of that correspondence and your Personal Information in order to process your enquiries, respond to your requests, and improve our products and services.

Marketing and Promotions

If you have consented and in accordance with your preferences, we use information to provide you with marketing communications, including special deals offered through the Website. We also use your Personal Information to send you newsletters and e-mails that periodically list current special offers, promotions, and deals.

Online Surveys

We may use your Personal Information to send you online surveys which help us improve our products and services. Your participation in these surveys is completely optional and your responses are treated as confidential information.

Cookies and Similar Technologies

We use cookies and similar technologies to understand how our visitors are using the Website and to discover how we might modify the site to better serve our customers. Kingston generally uses cookies and other similar technologies for purposes such as: (1) authenticating users; (2) remembering user preferences and settings; (3) determining the popularity of content, including Kingston products or services; (4) delivering and measuring the effectiveness of advertising; or (5) analyzing site traffic and trends; and (6) generally seeking to understand the online behaviors and interests of people who interact with our site. For additional information on the various cookies we use and the purposes for which we use them, please read our Cookie Policy.

Navigational Data

We use information related to your use of our Website: (1) to facilitate and improve the Website; (2) to comply with any requirements of law; (3) to serve, or have a third party serve specialised or relevant advertising content and/or recommendations to you on the Website and third party sites; and (4) for our internal purposes. We may supply the owners or operators of third-party sites with aggregate/anonymous information relating to the number of users linking to the Website from their sites.

Log Files and IP Addresses

We use log files and related information to understand how our visitors are using the Website and to discover how we might modify the site to better serve our customers. We may also use IP addresses for system administration and troubleshooting, to ensure user compliance with our Terms of Service, to investigate security incidents, and to compile aggregate data, such as the overall number of users that have visited the Website.

HOW DO WE SHARE THE INFORMATION THAT WE COLLECT?

We do not share or disclose your Personal Information to third parties, except as set forth in this Privacy Policy. We may disclose certain Personal Information and other information about you to the following:

  • Affiliates. These are entities that are directly or indirectly controlled by us or who share common control with us.
  • Service Providers and Strategic Partners. These are entities that provide services for or on behalf of us, such as providing marketing assistance, fulfilling orders, and providing fraud prevention services, as well as partners who we work with to provide you services.
  • Other Parties When Required or Permitted by Law. These entities include government authorities, law enforcement agencies, or other third parties, including where necessary to exercise or defend legal claims on Kingston’s behalf.
  • Other Parties in Connection with a Change of Ownership. These entities might include a third party as part of a merger or transfer, acquisition or sale, or bankruptcy.
  • Other Parties with Your Consent or at Your Direction. These third parties include those for which you separately consent to and/or request such sharing.

Who Do We Share Your Personal Information With?

Our Affiliates

We may share your Personal Information with our affiliates for purposes described in this Privacy Policy. These affiliates may use your Personal Information only in accordance with this Privacy Policy and for the purposes and reasons it sets out.

Our Service Providers and Strategic Partners

We share your Personal Information with certain businesses that provide services to us in connection with those services. For example, data is collected to process payments, or data collected about our products which interest you will be used by the company that administers our customer mailing list, and your name and address shall be disclosed to the delivery service we use to deliver products that you purchase on the Website.

Advertising and Marketing

Where you have consented, we share your Personal Information with service providers and advertising partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalized ads and to study the effectiveness of our campaigns. For example, these companies may communicate regarding products and services that may be of interest to you, in accordance with your preferences. For additional information, see our Cookie Policy.

Legal and Business Purposes

We may be obligated by law to disclose your Personal Information to certain authorities or third parties. For example, we may be required to disclose information to law enforcement agencies in countries where we or others are acting on our behalf operate. We may also disclose and otherwise use your Personal Information to meet our legal obligations and protect our legitimate legal and business interests, and its rights, property, and employees.

Change of Control, Mergers and Acquisitions

If another company acquires a controlling interest in Kingston, or if we experience some other change of control event such as merger, insolvency, bankruptcy or receivership, we reserve the right to include any or all user-related information (including Personal Information) among the assets transferred to the acquiring company.

Aggregated or Deidentified Information

We may share aggregated or deidentified information about the Website with our corporate partners, investors, advertisers or others. Aggregate general information includes without limitation: (1) the number of users of the Website; (2) revenue, including payments by the user type; (3) usage statistics; and (4) user feedback. Aggregated information does not include any Personal Information that could be used to contact or identify you. Deidentified information means the information cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to an individual. Kingston has adopted certain business processes and technical safeguards regarding the use of deidentified information.

With Your Consent

In addition to the disclosures described above, we may share your Personal Information with third parties when you separately consent, direct, or request such sharing, as permitted under applicable law.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods can vary based on the type of information, how it is used, and relevant legal requirements.

We consider the following factors when determining how long we keep your Personal Information: (1) the amount, nature, and sensitivity of the Personal Information; (2) the potential risk of harm from its unauthorized use or disclosure; (3) the purposes for which we process your Personal Information; and (4) whether we can achieve those purposes through other means, and the applicable legal requirements.

CHILDREN’S PRIVACY & INFORMATION FOR PARENTS/GUARDIANS

We do not knowingly solicit, collect, maintain or disclose any Personal Information from children under the age of 18. If you are under the age of 18, please do not:

  • Create or attempt to create an account on the website;
  • Sign up for any subscription service via the website;
  • Buy anything through the website; or
  • Otherwise interact with the website.

Occasionally, we may collect Personal Information from minors who are under 18 in person at tradeshows or for product testing with proper consent from a parent or legal guardian. We may collect name, online identifiers, and email address. We may use this information to provide with communications, conduct contests and promotional events, and participate in product testing.

As a parent or legal guardian, you may request that we delete Personal Information collected from your child in person at any time by contacting us at the email address or telephone number provided below. We will delete such information from our database within a reasonable time.

To request that we delete your child’s Personal Information, or if you have questions regarding our practices as to Personal Information about children, please contact us at:

Email: [email protected]

Phone: 1-800-835-6575

WHERE WE STORE YOUR PERSONAL INFORMATION

Kingston is a global organization with its headquarters in the United States. As such, your information, including your Personal Information, may be transferred to, stored in, entities affiliated with us and other third parties located in countries which do not have the same level of data protection laws as those in the country where you are located.

SECURITY

We take appropriate security measures to protect your Personal Information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. For example, where appropriate, we may:

  • Use Secure Sockets Layer (SSL) technology when collecting or transferring sensitive information, which is designed to make the data unreadable by anyone but us.
  • Take steps to limit access to your Personal Information to employees who require that information in order to operate, develop, or improve our products, services, and the Website.
  • Put in place physical, electronic, and organizational safeguards to protect the Personal Information and other information that we have collected.

Although we take steps to protect your information, no website, internet transmission, computer system, or wireless connection is completely secure.

CHOICE, ACCESS, AND CORRECTION OF YOUR INFORMATION

If you elect or consent to receive certain communications from us, such as promotional e-mails, marketing communications, and surveys, you can withdraw your consent or change your preferences by following the opt-out instructions in those communications or by logging into your account on the Website.

You can review, update, modify or remove any information you have submitted on the Website, either during your online account registration with Kingston, when you log-in to your Kingston account or by contacting us. However, if you request a change or removal of your Personal Information, please keep in mind that we may still need to retain some information for recordkeeping purposes, to comply with applicable laws, and to complete transactions with you.

LINKS TO OTHER SITES

Our site may contain links to the websites of third parties. If you choose to follow a link to any of these websites, please note that these websites have their own privacy policies and that Kingston does not accept any responsibility or liability for these policies. Please check these policies before you provide any Personal Information to these websites.

CHANGES TO PRIVACY POLICY

We may update our Privacy Policy from time to time by posting a new version of it on the Website. We encourage you to check the Website regularly for information about revisions to this Privacy Policy. If you object to the change to our Privacy Policy, then contact us with your objections.

CONTACT INFORMATION

If you wish to request any information or have any questions regarding this Privacy Policy or its implementation, you may email us at [email protected]. You may also write to us at:

Kingston Technology Company, Inc.
Attention: Privacy Compliance
17600 Newhope Street
Fountain Valley, CA. 92708 USA

If you wish to request any EU specific information, please refer to the EU and Swiss Based Users and the GDPR section.

EU AND SWISS BASED USERS AND THE GDPR

If you, or the collection, use, storage, disclosure, or transfer (“processing”) of your Personal Information is subject to the GDPR, please review this section in addition to the entire Privacy Policy. This Section of the Privacy Policy specifically summarizes our lawful basis for processing your Personal Information, how we may transfer your Personal Information, your rights related to your Personal Information, and how you can contact us in the EU and Switzerland.

Grounds for Processing Your Personal Information

As outlined in our Privacy Policy, we process your Personal Information. The legal grounds for us processing your Personal Information are:

  • You provided your consent (which you may withdraw at any time).
  • The processing is necessary for us to fulfill a contractual relationship with you.
  • The processing is in our legitimate interests (such as processing for administrative purposes, preventing fraud, and security).
  • The processing is necessary for us to fulfill our legal or regulatory obligations.

Consent

We may collect, use and share your Personal Information on the basis of your consent.

As described in this Privacy Policy, we rely on consent in connection with Personal Information for the following types of processing:

  • Marketing or other promotional materials.
  • Collection of prospective applicant or other employment related data of individuals located or employed by Kingston in the UK or other EU member state.
  • Notifications related to new, relevant products or services, discounts, and news when you have previously consented to receiving such communications (e.g., texts, email, postal mail, etc.).
  • The placement of cookies, remarketing or conversion pixels, beacons, clear GIFs, interest based advertising, or other tools by Kingston or an affiliated third party, in order to provide you with more relevant products or services. For additional information, please see our Cookie Policy.

Performance of a Contract

We must collect and use Personal Information in order to provide you with the products and services that you request. This includes Personal Information used to provide you with products and related services and related transaction information.

Legitimate Interests

We collect and use Personal Information to the extent necessary for our legitimate interests. This may include collecting and using data to:

  • Maintain and enhance our users' safety and security.
  • Prevent, detect and combat fraud in connection with the use of our Website or the purchase of a product or service.
  • Inform law enforcement officials regarding criminal acts or threats to public safety.
  • Provide customer support.
  • Optimize our service and develop new services.
  • Market research and/or analytical purposes.
  • Enforce our Terms of Use.

Fulfill Legal Obligations

We are subject to various legal requirements in the jurisdictions that we operate that require us to collect, process, disclose and retain your Personal Information in order to comply with those laws. We may be required to retain your data for extended periods of time, and to provide copies of such data to law enforcement, governmental or other regulatory authorities, or third parties.

International Transfers of Your Personal Information

The information that we collect from you may be transferred to, stored in, processed in or accessed from countries outside of the European Economic Area (“EEA”). If we possess your Personal Information in the EEA, and we subsequently transfer that information out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your Personal Information from the EEA to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission;
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give your Personal Information the same protection it has in Europe; or
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to the Personal Information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Refer to the EU-U.S. Privacy Shield section for more information on Kingston’s compliance.

Your Rights Related to Your Personal Information

The GDPR provides you with certain rights related to the collection, processing and transfer of your Personal Information. You can exercise these rights by contacting us using the information below in the section entitled “Contact Information for Users Based in the EU or Switzerland”. You may be asked to provide some proof of identification so that we can verify that it is you making the request.

Specifically, you have the following rights:

Access

You have the right to know we collect certain Personal Information about you and to ask us for copies of your Personal Information.

Rectification

You have the right to request that we correct information you think is inaccurate or incomplete.

Object to Processing

You have the right to object to processing in some circumstances, including where we are using your Personal Information for our legitimate interests and for direct marketing purposes.

The GDPR provides a right to object to the processing of Personal Information by an individual when an organization is using the information: (1) for a task carried out in the public interest; (2) for its legitimate interests; (3) for scientific or historical research, or statistical purposes; or (4) for direct marketing.

Erasure

You have the right to request that we erase the Personal Information we have collected about you in certain circumstances.

Please note the right to erasure is not absolute, and only applies in the following circumstances:

  • We no longer need your Personal Information to carry out the purpose that we collected it for.
  • You have withdrawn your consent to our use of your Personal Information.
  • You have objected to our use of your Personal Information and your interests outweigh our interests in using it.
  • You believe we have processed your Personal Information unlawfully.
  • We have a legal obligation to erase your data.
  • The Personal Information you are seeking erasure of was submitted by a child under 16, or equivalent minimum age depending on jurisdiction, at the time of submission.

Upon receiving a request from you to erase your Personal Information for any of the above reasons, we will endeavor to remove as much information as is legally allowable. The GDPR provides several exceptions and permits us to object to your request. If we are unable to comply with your request to erase Personal Information, we shall tell you in writing what Personal Information we have continued to retain, the reasons for retaining it and how long we expect to retain it for.

Restrict Processing

You have the right to ask us to restrict the processing of your Personal Information in certain circumstances.

You can request that we temporarily limit the use of your Personal Information when we are reviewing:

  • A challenge you have to the accuracy of your Personal Information.
  • An objection you have made to our use of your Personal Information.

You can also request that we limit the use of your Personal Information rather than delete it if:

  • You believe we processed your Personal Information unlawfully, but you do not want us to delete it.
  • We no longer need your Personal Information, but you want us to keep it in order to create, exercise or defend legal claims.

Data Portability

You have the right to receive a copy of the Personal Information that we collect about you in a way that is accessible and in a machine-readable format where the processing is based on your consent, the performance of a contract with you, or carried out by automated means. You have the right to request that such Personal Information be transmitted directly from us to another data controller, where technically feasible.

Withdraw Consent

You can withdraw your consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Lodge a Complaint with a Data Protection Authority (“EU DPA”)

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you have the right to lodge a complaint with the Information Commissioner’s Office or your local EU DPA.

Contact Information for Users Based in the EU or Switzerland

If you wish to request any EU-specific information, or have any questions regarding this Privacy Policy, or its implementation, you may email us at [email protected]. You may also write to us at:

Kingston Technology Europe Co. LLP [or Kingston Digital Europe Co. LLP]
Attention: GDPR Compliance
Kingston Court, Brooklands Close, Sunbury-on-Thames, Middlesex TW16 7EP UK

EU data subjects may also contact our Lead Supervisor Authority, the Information Commissioner’s Office of the United Kingdom, with any questions about our privacy practices.

EU-US PRIVACY SHIELD

Kingston complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from all EU member countries that are subject to European data protection laws, including but not limited to, the GDPR, the European Privacy and Electronic Communications Directive of 2002 (“e-Privacy Directive”) and their member state equivalents. Kingston has certified that it adheres to the EU-U.S. Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. For more information, learn more about the Privacy Shield.

In cases of onward transfer to third parties, Kingston will only transfer personal data for limited and specified purposes. Kingston complies with the EU-U.S. Privacy Shield Principles for all onward transfers of personal data from the EU and the United Kingdom, including the onward transfer liability provisions.

In compliance with the Privacy Shield Principles, Kingston commits to resolving complaints about our collection or use of your Personal Information in a timely manner. We respectfully request that any EU data subject that is located in the EU, and wishes to submit inquiries or file complaints regarding our compliance with the Privacy Shield policy, first contact us by email at [email protected], or by postal mail at the following address:

Kingston Technology Company, Inc.
Attention: Privacy Compliance
17600 Newhope Street
Fountain Valley, CA. 92708 USA

Kingston has further committed to cooperating with relevant EU data protection authorities (“DPA”) regarding unresolved Privacy Shield complaints, or other matters related to relevant EU Data Protection Laws. If you do not receive timely acknowledgment of your complaint from us, or you believe that we have not satisfactorily addressed your complaint, you can contact your relevant EU DPAs to request more information, or to directly file a complaint. The services of EU DPAs are provided at no cost to you. For more information, learn more about the Kingston Privacy Shield Policy.

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to Kingston at the address given above. Kingston will investigate and respond or attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information in accordance with the principles contained in this Policy within a reasonable amount of time, not to exceed 30 days following the receipt of your question or complaint.

To learn more about how you may pursue binding arbitration through the Privacy Shield Arbitration Panel, please visit https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

Kingston is subject to the investigatory and enforcement powers of the Federal Trade Commission regarding Kingston’s compliance with the Privacy Shield.

CALIFORNIA RESIDENTS AND THE CCPA

If you are a California resident (“California Resident,” “you” or “your”), please review the following information about your potential rights regarding your Personal Information under the CCPA. The rights described in this California privacy policy are only available if you are a “consumer,” meaning a natural person who is a California resident as that term is used in the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.

Terms used in this section have the meaning given to them in the CCPA. Under the CCPA, Kingston is a business. For purposes of this section only and regarding California residents only, Personal Information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. Personal Information does not include deidentified information, aggregate consumer information, or publicly available information, as those terms are defined in the CCPA.

Our Collection, Use, Disclosure, and Sharing of Personal Information

  • In the preceding 12 months: (1) we may have collected the categories of Personal Information from or about you; (2) we may have disclosed all or some of the categories of Personal Information for business purposes; and (3) we may have “sold” within the meaning of the CCPA all or some of the categories of Personal Information to third parties.
  • We may collect Personal Information from all or some of the categories of sources.
  • We may collect, use, or sell Personal Information for the business or commercial purposes We may share Personal Information with all or some of the categories of third parties. We may share your information with third parties outside of Kingston to largely help us improve our products and services. In addition, we may disclose your Personal Information to our service providers or other entities that have agreed to limitations on the use of your Personal Information or that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA or other applicable laws.

California Residents’ Rights Under the CCPA

If your Personal Information is subject to the CCPA, you may have certain rights regarding such Personal Information, including the right to:

  • Be informed, at or before the point of collection, of the categories of Personal Information to be collected and the purposes for which the categories of Personal Information shall be used.
  • Request that we delete any Personal Information about you that we have collected or maintained, subject to certain exceptions (“Request to Delete”). We reserve the right to retain, and not to delete, certain Personal Information after receipt of a Request to Delete where permitted by the CCPA or where another law or regulation is applicable. We may retain your Personal Information if doing so is necessary for us or our service providers to, for example:
    • Comply with a legal obligation.
    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
    • Complete a transaction for which we collect the Personal Information, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
    • Use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.
  • Request that we, as a business that collects, discloses for a business purpose, and sells Personal Information within the meaning of the CCPA, disclose to you (“Request to Know”):
    • The categories of Personal Information we have collected about you.
    • The categories of sources from which we collected the Personal Information.
    • The business or commercial purpose for collecting or selling the Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • The specific pieces of Personal Information we have collected about you.
    • The categories of Personal Information we have disclosed about you for a business purpose.
    • The categories of Personal Information we have sold about you and the categories of third parties to which we sold the Personal Information.
  • Not be discriminated against because you exercised any of your rights under the CCPA.
  • Opt-out of the sale of your Personal Information (“Request to Opt-Out”).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.

How to Submit a Request to Know or to Delete

To submit a Request to Know, you may call us at the toll-free telephone number 1-800-835-6575, or by clicking here.

You may submit Requests to Delete your Personal Information via the following methods:

  1. Call us at 1-800-835-6575
  2. Email us at [email protected]
  3. Submit an online request

We are required to provide certain information or delete Personal Information only in response to verifiable requests made by you or your legally authorized agent. We may need to request specific information from you or your agent to help us confirm your identity or your agent’s authorization to act on your behalf and ensure your right to access the requested information. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. We may also contact you or your agent to ask for further information in relation to your request to speed up our response. Any information gathered in this process will be used for verification purposes only.

We will deliver responses to verifiable consumer requests free of charge either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election.

We will try to respond to your requests to know or to delete within forty-five (45) days of receipt of the request. If we require more time, we will try to inform you of our need for an extension within forty-five (45) days of receipt of the request. Any extension will be limited to an additional forty-five (45) day period, meaning we will try to provide a response within ninety (90) days of initial receipt of the request.

Any response to a Request to Know will only cover the 12-month period preceding the verifiable request. If we cannot comply with your verifiable request, we will let you know.

How to Submit a Request to Opt-Out

If Kingston sells your Personal Information within the meaning of the CCPA, you may have the right to opt-out of those sales. You may submit a Request to Opt-Out by clicking: Do Not Sell My Personal Information, calling (800) 835-6575, or sending an email to [email protected].

Contact for More Information

If you have any questions or concerns about this California privacy section, please email [email protected].

This California section was last updated as of June 1, 2020.