Les Schwab Privacy Notice for California Residents

Effective Date: 1/1/2020

Last Reviewed on: 12/30/2019

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in Les Schwab Privacy Policy (“Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). Les Schwab Tire Centers (“Les Schwab,” “we,” or “us”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

We want you to be familiar with how we collect, use and disclose data. This Privacy Notice describes the privacy practices of Les Schwab for data that we collect: 

  • through websites operated by us from which you are accessing this Privacy Notice, including www.lesschwab.com and other websites owned or controlled by Les Schwab (collectively, the “Websites”)
  • through software applications made available by us for use on or through computers and mobile devices (the “Apps”) 
  • through our social media pages that we control from which you are accessing this Privacy Notice (collectively, our “Social Media Pages”) 
  • through HTML-formatted email messages that we send you that link to this Privacy Notice, and 
  • through your communications with us when you visit our stores or through other offline interactions (collectively, “Store Visits and Offline Interactions”) 

Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, “Online Services” together with the “Store Visits and Offline Interactions”, are referred to as the “Services”. By using the Services, you agree to the terms and conditions of this Privacy Notice.

Information We Collect

Les Schwab collects, through its Services, information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).

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

Information You Provide to Us

We collect information you provide to us. For example, we collect information when you visit our stores and buy our products. We collect information when you sign up to receive news, notifications, or other communications from us. We also collect information when you request customer support; engage with us on social media; fill out a form; or participate in a survey or promotion. The types of information we collect directly from you may include:

  • Identification information, such as your Name, Title, Photo, Date of Birth, Identity Document (e.g., driver’s license, passport or tax identification number), Employer Name. 
  • Contact information, such as your Mailing Address, Email Address, and Phone Number.
  • Payment information, including your Payment Card Information and Billing Address.

Information we collect automatically

We automatically collect information about you when you access or use our Services or do business with us. For example, we collect:

  • Purchase Information: When you make a purchase or return, we collect information about the transaction. This may include product details, purchase price, warranty information, date and location of the transaction. It may also include account notes about the transaction.
  • Browsing and Usage Information: When you use our Services, some information is collected automatically, including as described in our Privacy Policy. For example, when you visit our Websites, our web servers automatically log your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, the website you visited before our site, and your activity on the Websites.
  • Personal Preferences: Customer preferences, inquiries and comments and any other personalized data you advise us about or which we learn about during your visit.
  • Device Information: We collect information about the computer or mobile device you use to access our Services. This may include the Hardware Model, Operating System and Version, Unique Device Identifiers, and Mobile Network Information.
  • Location Information: We may collect or infer information about your general location when you access or use the Services, visit our stores, or turn on your Bluetooth, Wi-Fi or other geolocation functionality on your device. If you enable location services on your device, we collect more precise geolocation information. This lets us serve you location-based ads, notify you of products and services available in your area, and provide location-based services or functions. 
  • Video and Images: We use cameras to capture video and images in and around our Stores. We may use these videos and images for security, fraud, loss prevention, law enforcement or incident reporting, or other operational purposes, such as analyzing traffic patterns.

Information We Receive from Other Sources

We may also obtain information about you from other sources and combine that with the information we collect about you. If we receive Personal Information from a third-party source and/or if we combine the information we receive from these third party sources with your Personal Information, we will treat that information as Personal Information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect, use and share such information.

We may obtain information from third parties and append it to our existing user information to better understand users’ interests and to provide more relevant content.

We may append information about you that is publicly available or information that is aggregated and/or depersonalized by third parties. This information may include, for example, household income range, employment and education history, or postal code. This may include personal information such as names, age, race, gender, marital status, email address, physical address, or phone number. 

How we collect Personal Information

We collect Personal Information in a variety of ways.

Online Services. We collect Personal Information when you make appointments or purchase goods and services from our Websites or Apps, communicate with us by email, fax or via online chat services, connect with us or post to Social Media Pages, sign up for a newsletter or participate in a survey, contest or promotional offer.

Store Visits and Offline Interactions. We collect Personal Information when you visit our stores, make an appointment over the phone or contact customer service. We also collect Personal Information when you attend promotional events that we host or in which we participate, or when you provide your Personal Information to facilitate an event. These communications may be recorded for purposes of quality assurance and training.

From third parties, for example, our business partners and other Sources. We collect Personal Information including education, employment and information regarding creditworthiness from public databases, joint marketing partners, member dealers, and other third parties.

Physical & Mobile Location-Based Services. We may collect Personal Information if you download one of our Apps or choose to participate in certain programs. For example, we may collect the precise physical location of your device by using satellite, cell phone tower, WiFi signals, or other technologies. We may collect this data if you opt in through the App or other program (either during your initial login or later) to receive special offers and to enable location-driven capabilities on your mobile device. If you have opted-in, the App or other program may continue to collect location data when you are in or near a store until you log off or close application (i.e., the App or other program may collect this data if it is running in the background) or if you use your phone’s or other device’s setting to disable location capabilities. 

Use of Personal Information

We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to purchase our products or services, we will use the to (i) comply with Department of Transportation registration requirements; (ii) track warranty information on product or service you purchase from us; (iii) charge your credit card for purchasing a product or service, to process your retail credit application, (iv) to respond to any requests you may have about your account or a transaction; or facilitate new product orders or process returns. 
  • To contact you for the purpose of manufacturer product recalls.
  • 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 experience on www.lesschwab.com 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 analyze purchase patterns and infer customer preferences
  • To help maintain the safety, security, and integrity of www.lesschwab.com, our products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve www.lesschwab.com, our products, and services.
  • 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 Les Schwab’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Les Schwab about our website users is among the assets transferred.

We 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.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose, subject to your right to opt-out of those disclosures. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who receive the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Service providers.
  • Data aggregators.

Sales of Personal Information

In the preceding twelve (12) months, Les Schwab has not sold Personal Information.

Retention

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

  • The length of time you own / maintain products you purchased from us.
  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services.
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation or regulatory investigations).

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 Les Schwab disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we have collected about you.
  • The categories of sources for the Personal Information we have 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 have 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 Les Schwab 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:

  • 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.
  • Comply with Department of Transportation registration requirements, track warranty information on product or service you purchase from us, respond to any requests you may have about your account or a transaction, or contact you for the purpose of manufacturer product recalls.
  • Service your credit account with us in the ordinary course of business and according to the terms and conditions of your application and security agreement with us.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • 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.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

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

Only you, or someone legally authorized to act on your behalf, 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.

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 a legally 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 (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing.

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. 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.

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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. 

To exercise the right to opt-out, you (or your legally authorized representative) may submit a request to us by visiting the following Internet Web page link: Website Request

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information disclosures and/or sales at any time by:

Website Request.

We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate 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. We currently do not provide any financial incentives related to the collection, use, or sale of your Personal Information.

Changes to Our Privacy Notice

We reserve 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 Privacy Notice, the ways in which Les Schwab collects and uses your information described below and in the 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: 1-833-896-9953 1-833-896-9953

Website: Website Request