This privacy notice supplements Wolf’s Privacy Notice to explain the categories of personal data that we collect and how we collect and use personal data consistent with California and Virginia privacy laws. This supplemental notice should be read in connection with Wolf’s Privacy Notice.
Information We Collect, Use and Disclose
Wolf 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). This information is collected in order to carry out the business purposes you engaged Wolf to perform and other commercial purposes. In particular, we collected the following categories of personal information about our consumers:
|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, signature, physical characteristics or description, 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|
|B. Protected classification characteristics||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).||YES|
|C. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|D. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, signatures, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES|
|E. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|F. Geolocation data||Physical location or movements.||YES|
|G. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|H. Professional or employment-related information||Current or past job history or performance evaluations.||YES|
|I. 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.||YES|
|J. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
|K. Sensitive Personal Information||Personal information that reveals (A) a consumer’s social security, driver’s license, state identification card, or passport number; (B) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mall, email and text messages, unless the business is the intended recipient of the communication; (F) a consumer’s genetic data; and (2)(A) the processing of biometric information for the purpose of uniquely identifying a consumer; (B) personal information collected and analyzed concerning a consumer’s health; or (C) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.||YES|
Your legal rights
You have certain rights and choices regarding our use and disclosure of personal information about you:
- Access – You have the right to request, twice in a 12-month period, information from us regarding the categories and specific pieces of personal information we collect, use, disclose and/or share about you during the past 12 months. This includes:
- The categories and specific pieces 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 which we collected or sold the personal information
- The categories of third parties with whom we shared the personal information
- The categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties wo whom we sold or disclosed that information for a business purpose
- Correction – You have the right to request the correction of certain personal information, taking into account the nature of the personal information and the purposes of processing the personal information. We may correct or delete information as allowed by law. Exceptions apply.
- Deletion – You have the right to request the deletion of personal information. Exceptions apply
- Opt-out – You have the right to opt-out of the sale and/or sharing of personal information; and
- Non-Discrimination. You have the right not to be discriminated against for exercising any of the above consumer rights.
Exercising Rights Under State Privacy Laws
You may contact us at anytime to exercise your rights under the law. As part of processing your request, we require you to provide certain personal data about you in order to verify your identity in accordance with the law. This information includes your first and last name, email address, physical address, telephone number, and description of relationship to Wolf, but may also include additional information based on the nature of your request and your relationship with us.
Additionally, you may designate an authorized agent to make a request on your behalf. In order to comply with your request, we will require the personal data referenced above to be used for identity verification purposes, as well as the name, email address, and telephone number of your authorized agent.
After we verify your identity and the validity of your request, we will take the following action free of charge:
- in the case of an access request, provide you any required personal data covering the twelve (12)-month period preceding your request; and
- in the case of a deletion request, delete personal data that we have collected about you, subject to our right to maintain your personal data for specific purposes permitted under CCPA.
We will work to comply with your verified request within forty-five (45) days, but may extend that period when reasonably necessary, in which case we will notify you.
- Limit the use or Disclosure of Sensitive Personal Information. You have the right to request that we limit use or disclose of Sensitive Personal Information as defined by California law. We do not disclose Sensitive Personal Information beyond such authorization.
- Do Not Share My Personal Information. You have the right to opt-out of our sharing of personal information for cross-context behavioral advertising. Wolf, however, does not sell or share personal information for these purposes.
- Opt-Out of Targeted Advertising.Wolf does not engage in advertising on other third-parties digital properties.
- Appeal a Refusal to Take Action. Virginia law requires that we establish a process for a consumer to appeal our refusal to take action on certain requests. You may request an appeal through any of the methods available to exercise your privacy rights under law. If you are not satisfied with the outcome of the process, you may contact the Virginia Attorney General to submit a complaint.
Last Update: 1/15/2023