California Privacy Policy

**ONLY APPLIES TO CALIFORNIA RESIDENTS AND DOES NOT APPLY TO ANY REPORTING OR NEWS INFORMATION**

Effective

This Policy was last modified on: October 1, 2021

Policy

This California Privacy Policy for California residents ("California Privacy Policy") is provided by CNHI LLC and its affiliates and subsidiaries (collectively "CNHI," "we," "us," or "our"), and applies solely to the Personal Information (as defined below) that we collect and use relating to consumers and users who reside in the state of California ("you," "consumer," or "customer"). This California Privacy Policy supplements our general Privacy Policy and applies to the publications, businesses, and websites operated by CNHI including the website from which you accessed this California Privacy Policy. We provide this California Privacy Policy to comply with California privacy laws, including the California Consumer Privacy Act of 2018, as amended ("CCPA"), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

Definitions Specific to this Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to our general Privacy Policy including the following terms:

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.

"Sale" or "sell" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

"Service Provider" means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

"Third Party" means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

Overview

We use reasonable security measures to protect your information including industry-standard processes for sharing information with third parties. You should note that our webpages may contain links to or content from websites or other online services provided by third parties.

The CCPA requires that we use the term "sell" to include information sharing with business partners for operational services. Accordingly, we use this expanded definition of "sell" throughout our California Privacy Policy. When we disclose that we may "sell" Personal Information, it means that we and you may receive some kind of benefit in return for sharing Personal Information, even if no money changes hands.

When you visit our webpages, we may use cookies and other technologies to collect information. These technologies help us personalize experiences, understand news preferences, and learn about the devices used to access our sites. To ensure you receive ads relevant to your preferences we and our advertisers may collect information about your online activities over time and across different websites, apps, and devices. We and our advertisers may use that information to help understand audience segments. Our advertisers may use the segments to determine the audience groups to which they wish to deliver particular ads.

The summary provided below describes all information collected on our sites. Keep in mind that collection includes information you provide to us for our services and passive information regarding your activity on our webpages. You can opt out of receiving interest-based advertising but opting out does not mean you will no longer receive advertising. It means that the company or companies from which you opted out will no longer deliver ads tailored to your preferences.

The Personal Information We Collect and Disclose

We may have collected Personal Information in the following categories from consumers within the last twelve (12) months. The categories and examples provided in the chart below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about consumers. We will update this disclosure from time to time as appropriate.

In response to a verified consumer request for categories of information collected, we will investigate and provide an individualized response to the consumer, and will not merely refer the consumer to our general practices outlined in this California Privacy Policy unless our response would be the same for all consumers and this California Privacy Policy discloses all the information that is otherwise required for the response to such a consumer request.

We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

Personal Information of Minors

We are proud of our online information and we strive to ensure we do not offend people of any age. However, our web pages are not intended for children or minors under the age of sixteen years. Accordingly, we do not knowingly store information from minors under the age of sixteen years. If you believe that a child has submitted personal information to Us, please contact us at privacy@cnhi.com or 1-833-912-2087 and We will delete the information.

Information Collection

You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.

• If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of Personal Information "sold"; (3) the categories of third parties to whom the information was "sold"; and (4) the categories of Personal Information that were disclosed for a business purpose, click here or call 1-833-912-2087. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request
• If you would like to request the specific pieces of Personal Information we collected about you, click here or call 1-833-912-2087. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request>

Financial Incentives and Non-Discrimination

We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

However, our newspapers may offer a limited number of contests to consumers with the primary purpose of community engagement. Consumers who participate in those contests allow us to retain and disclose their Personal Information. Only some newspapers offer contests and an individual newspaper will offer no more than five contest per calendar year. Contests with a financial incentive may range up to $5,000 per contest. You may withdraw from the incentive at any time. If you have previously opted-in to a contest and wish to opt-out, click here or call 1-833-912-2087.

Deletion of Your Personal Information

You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.

• If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, click here or call 1-833-912-2087. The link will take you to an interactive webform that you can complete and submit to make a request for deletion that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.

Right to Opt-Out

You have the right to request that we do not "sell" Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.

• If you would like to request that we do not "sell" your Personal Information pursuant to the requirements of the CCPA, click here or call 1-833-912-2087. The link will take you to an interactive webform that you can complete and submit to make a request for deletion; if you use the telephone number, you will be guided through a process that will allow you to submit a request.
• If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.

If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may "sell" your Personal Information.

You have the right to opt-in to the sale of your Personal Information after you have opted out. If you would like to opt-in to the sale of your Personal Information, click here or call 1-833-912-2087. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Verification Process

In order to protect your information, we will confirm a requestor’s identity before responding to any request. To start the process, you must provide your name and email. We will ask you at least one question, and you must reply by email with the correct answer for each question based on your previous interaction with us. If we still cannot verify your identity as required by the CCPA, we will let you know and may ask additional questions. Otherwise, we will acknowledge your request and contact you later with our full response.

We will only send CCPA verification questions from privacy@cnhi.com. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our CCPA verification email address listed above, do not respond.

Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.

Authorized Agents

You may designate an authorized agent to exercise your rights under the CCPA on your behalf.

Pursuant to the CCPA:

• Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
• You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
• We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
• Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.

Additional Information

If you would like additional information regarding our California Privacy Policy, please contact us at privacy@cnhi.com or 1-833-912-2087.

Additional California Privacy Rights

California Civil Code Section § 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to privacy@cnhi.com with the subject "Shine the Light Request."

Changes to Our California Privacy Policy

We reserve the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.

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