California Consumer Privacy Act Privacy Notice

Effective Date: March 10, 2023
Last Updated: March 10, 2023

Titan Industries (Global) Co. Ltd. (“Titan”, “we”, “our”, or “us”) cares about your privacy. Thank you for taking the time to read our California Consumer Privacy Act (“CCPA”) privacy notice (“Privacy Notice”). This Privacy Notice covers all personal data processed by our website (www.marketplace.lumerin.io) and our services (“Services”).

If you are a California resident, you may have additional rights and choices about your Personal Information. Please note that the CCPA provides certain exceptions with respect to the Personal Information of California employees, job applicants, owners, directors, vendors, suppliers, and contractors.

1. Information we collect

The categories of personal information we have collected about California residents in the last 12 months are described below:

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. NO
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. 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. 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

2. Use of personal information

In the last 12 months, we have used your personal information for the business and commercial purposes described below.

  • Category A: Identifiers.
  • Category D: Commercial Information
  • Category F: Internet or other similar network activity.
  • Category I: Professional or employment-related information.

3. Sharing of personal information

The business and commercial purposes that we have shared your personal information in the last 12 months are as follows:

  • Sharing your personal information for business purposes. We have shared the following categories of personal information with our affiliated companies and service providers for our business purposes:
    • Category A: Identifiers.
    • Category D: Commercial Information
    • Category F: Internet or other similar network activity.
    • Category I: Professional or employment-related information.

As described above, examples of business purposes include performing transactions, registering accounts, managing our relationship with you, and monitoring for security threats, anti-money laundering, and fraud.

  • Sharing your personal information for commercial or other purposes: We have shared the following categories of your personal information with co-sponsors, business partners, and other third parties in a manner that is likely to be considered to be a “sale” for commercial purposes under the CCPA:
    • None.
  • Sharing your sensitive personal information as defined by Cal. Civ. Code § 1798.140(ae). Sensitive personal information means 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 mail, email, and text messages unless the business is the intended recipient of the communication (F) consumer’s genetic data; (G) biometric information for the purpose of uniquely identifying a consumer; (H) personal information collected and analyzed concerning a consumer’s health; (I) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
    • None.

As described above, this information may be shared for personalization, analytics, marketing, retargeting, and sales. We do not sell or share personal information of consumers we actually know are less than 16 years of age.

4. Your right to know

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we verify your 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.
  • 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.

We do not provide access rights to business to business (“B2B”) information.

5. Your right to obtain a copy of your personal information

You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we verify your request, we will provide you a copy of your personal information that is responsive to your request.

We do not provide portability rights to B2B information.

6. Your right to delete your personal information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We do not provide deletion rights to B2B information.

7. Your right to opt-out of sale of your information

We do not sell or share personal information with third parties that would be considered a “sale” under the CCPA.

8. How to exercise your CCPA rights

To exercise your right to know, right to obtain a copy, or right to delete your personal information as described above, please submit your request to us by:

Contacting us at [support@lumerin.io]

9. How we verify requests and respond to requests

Before fulfilling your request, we take steps to verify you are who you say you are or that you have authority to act upon someone else’s behalf. Therefore, upon receipt of your request, we will request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.

When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of the request you make, we may require you to verify your identity to either a reasonable degree of certainty or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with information that you provide to us. In some cases, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request or that you are authorized to make the request on behalf of someone else.

In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request. We cannot respond to your request or provide you with personal information if we cannot confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. 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 to understand, evaluate, and respond to your request.

We cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.

10. Who may submit requests?

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make request on behalf of your minor child. You may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.

11. How often you can submit requests?

You may make a CCPA consumer request twice within a 12-month period.

12. Response timing and format

We make every attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

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.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, 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 easily.

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.

13. Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.

14. Changes To This Privacy Notice

Changes to this Privacy Notice will be posted on this site, along with information on any material changes. The Company reserves the right to update or modify this Privacy Notice at any time and without prior notice. If the changes made to our Privacy Notice are substantial, we will contact you before the changes take place.

15. Contact Us

If you have any questions about this Privacy Notice or our use of your personal data, please contact:

By email: support@lumerin.io