Privacy Notice for California Residents

Effective Date: 9/24/2026

This Privacy Notice for California Residents supplements the information contained in ABC's Website Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the "CCPA"), and the regulations issued by the California Privacy Protection Agency (CPPA). Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects 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"). In particular, ABC's website has collected 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, driver's license number, passport 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, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance 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, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	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.	YES
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.	YES
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.	NO

Personal information does not include:

- Publicly available information from government records.

- Deidentified 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Sensitive Personal Information

Some of the personal information we collect is "sensitive personal information" under the CCPA. In the last twelve (12) months, we have collected the following categories of sensitive personal information: [a consumer's Social Security, driver's license, state identification card, or passport number; and account log-in credentials]. We use and disclose sensitive personal information only for the purposes permitted by CCPA regulations (for example, to perform services you request, to prevent fraud, to ensure security and integrity, and for our own internal business purposes), and not for the purpose of inferring characteristics about you. Because we limit our use of sensitive personal information to these CCPA-permitted purposes, we are not required to offer, and do not offer, a right to limit the use of your sensitive personal information. If our practices change, we will update this notice and provide a "Limit the Use of My Sensitive Personal Information" option. [ABC to confirm the categories of sensitive personal information it actually collects.]

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

- Directly from you. For example, from forms you complete or products and services you purchase.

- Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

- To provide, support, personalize, and develop our Website, products, and services.

- To create, maintain, customize, and secure your account with us.

- To process your requests, purchases, transactions, and payments and prevent transactional fraud.

- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

- As described to you when collecting your personal information or as otherwise set forth in the CCPA.

- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ABC's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ABC about our Website users is among the assets transferred.

ABC 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.

Retention of Personal Information

We retain each category of personal information, including sensitive personal information, for only as long as reasonably necessary for the purposes described in this notice, unless a longer retention period is required or permitted by law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, and applicable legal, tax, accounting, warranty, and recordkeeping requirements. The retention periods, or the criteria used to determine those periods, for each category of personal information are set forth below:

Category of Personal Information	Retention Period or Criteria
Identifiers	Duration of the customer relationship plus7 years
Commercial information	7 years after the transaction, consistent with tax and warranty requirements]
Internet or network activity	Expires after 6 months
Geolocation data	Expires after 6 months
Professional or employment-related information	Duration of the relationship plus 3 years
Sensitive personal information	Duration of the relationship plus 3 years

Selling or Sharing Personal Information

ABC 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 requires the recipient to keep the personal information confidential, to use it only for the limited and specified purposes of performing the services, and to provide the same level of privacy protection required by the CCPA, as described in CCPA regulations governing service providers, contractors, and third parties.

Under the CCPA, "selling" means disclosing personal information for monetary or other valuable consideration, and "sharing" means disclosing personal information for cross-context behavioral advertising (targeted advertising), whether or not for consideration. ABC does not sell or share your personal information, and does not use third-party advertising or analytics technologies to engage in cross-context behavioral advertising.

We disclose your personal information only to the following category of third parties:

- Service providers and contractors that perform services on our behalf.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed 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 E: Biometric information.

- Category F: Internet or other similar network activity.

- Category G: Geolocation data.

- Category H: Sensory data.

- Category I: Professional or employment-related information.

- Category J: Non-public education information.

- Category K: Inferences drawn from other personal information.

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

- Service providers.

Sales and Sharing of Personal Information

In the preceding twelve (12) months, ABC has not sold or shared personal information in any of the following categories:

- 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 E: Biometric information.

- Category F: Internet or other similar network activity.

- Category G: Geolocation data.

- Category H: Sensory data.

- Category I: Professional or employment-related information.

- Category J: Non-public education information.

- Category K: Inferences drawn from other personal information.

Your Rights and Choices

The CCPA provides consumers (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 ABC disclose certain information to you about our collection and use of your personal information. For personal information collected on or after January 1, 2022, you may request that we disclose this information beyond the 12-month period preceding your request, and we will provide it unless doing so proves impossible or would involve disproportionate effort. Once we receive and confirm your verifiable consumer request, we will disclose to you:

- The categories of personal information we collected about you.

- The categories of sources for the personal information we collected about you.

- Our business or commercial purpose for collecting or selling that personal information.

- The categories of third parties with whom we share that personal information.

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

- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

- sales, identifying the personal information categories that each category of recipient purchased; and

- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that ABC 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:

1. 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.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. 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.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct Inaccurate Personal Information

You have the right to request that ABC correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of processing it. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information as directed by you, subject to the exceptions permitted by the CCPA.

Right to Limit the Use and Disclosure of Sensitive Personal Information

If we use or disclose your sensitive personal information for purposes other than those permitted by the CCPA, you have the right to direct us to limit our use and disclosure of your sensitive personal information to those permitted purposes. [As described above, we use sensitive personal information only for CCPA-permitted purposes and therefore are not required to offer this right; if our practices change, we will provide a "Limit the Use of My Sensitive Personal Information" option. / To exercise this right, use the "Limit the Use of My Sensitive Personal Information" link described below.]

Right to Opt Out of Automated Decisionmaking (Effective January 1, 2027)

Beginning January 1, 2027, if ABC uses automated decisionmaking technology (ADMT) to make significant decisions about you, you will have the right to opt out of that use and to obtain information about how the ADMT was used. We will update this notice to describe these rights before they take effect if they apply to our practices.

Exercising Access, Data Portability, Correction, and Deletion Rights

To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by:

- Calling us at 1-800-222-2871; or

- Emailing us at hr@abc-companies.com.

You do not need to create an account or complete an online form to submit a request.

Only you, or a person or business you authorize to act on your behalf as your authorized agent in accordance with CCPA regulations, 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. When an authorized agent submits a request, we may require the agent to provide proof of authorization and may require you to verify your own identity directly with us.

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.

Making a verifiable consumer request does not require you to create an account with us.

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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we may extend the response period once by an additional forty-five (45) days (for a total of up to 90 days), and we will inform you of the reason and extension period in writing within the first 45-day period.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Unless you request otherwise, the disclosures we provide will cover the 12-month period preceding our receipt of your verifiable consumer request; however, for personal information collected on or after January 1, 2022, you may request disclosure beyond the 12-month period as described above. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

Right to Opt Out of the Sale or Sharing of Personal Information

The CCPA gives consumers the right to opt out of the sale or sharing of their personal information. ABC does not sell or share your personal information, and does not use it for cross-context behavioral advertising (targeted advertising). Because we do not sell or share personal information, we do not offer a "Do Not Sell or Share My Personal Information" opt-out, and no opt-out request is necessary.

If our practices ever change so that we sell or share personal information, we will update this notice, provide the required "Do Not Sell or Share My Personal Information" link, and honor opt-out preference signals such as the Global Privacy Control (GPC). We also do not sell or share the personal information of consumers we know to be under 16 years of age.

Non-Discrimination and Non-Retaliation

We will not discriminate or retaliate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us at: Attn: Marketing Department, ABC Companies, 17469 West Colonial Drive, Winter Garden, FL 34787.

Changes to Our Privacy Notice

ABC reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which ABC collects and uses your information described above and in the Website Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-222-2871 Website: www.abc-companies.com

Postal Address: ABC Companies Attn: Legal Department 1506 30th Street NW Faribault, MN 55021