California Privacy Notice

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit the majorel.com website or subscribe to receive our newsletter (our “Services”). Majorel will process your personal information in accordance with this Privacy Notice and will be responsible for complying with applicable data protection laws.

Information We Collect

We collect 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 device (“personal information”). In particular, we collect or process the following categories of personal information:

• Contact information, such as name, email address, postal address and phone number;
• Device and browser information including the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet;
• Online identifiers such as the date and time you access our website, the pages that you access while at our website and the Internet address of the website from which you linked directly to our website; and
• Professional or employment-related information, such as your occupation and employer information.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, such as while signing up to receive our newsletter; and
• Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our website.

Grounds for Processing

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

• To fulfil the purpose for which the information is provided;
• To provide you with our Services or to contact you if you request us to do so; and

To operate the majorel.com website.

Except as mentioned in this Privacy Notice, 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

Majorel occasionally contracts with other companies to provide limited services on our behalf.  These service providers are authorized to use your personal information only as necessary to provide the requested services to us.  We will only transfer to those companies the personal information they need to deliver the service.

Other Uses and Disclosures of Information

We also use and disclose your personal information for other legitimate interests and legal reasons, as follows:

• To comply with applicable law or regulation, including laws outside of your country of residence;
• To respond to requests from public and government authorities, including authorities outside of your country of residence;
• To cooperate with law enforcement;
• To enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others;
• To comply with or monitor compliance with any corporate governance requirements; and
• In connection with a sale or business transaction, including any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

Data Retention

We retain your personal information for as long as necessary to provide the Services or for other essential purposes such as complying with our legal obligations.

Children’s Privacy

We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.

Your Rights and Choices

The California Privacy Rights Act (CPRA) provides California residents with specific rights regarding their personal information.  You may have certain rights available to you, which may include the following:

• Review the personal information we have about you or request a copy of it;
• Ask us to update or correct personal information if it is inaccurate;
• Request that we delete your personal information;
• Opt-out of sharing your personal information with third parties for some purposes; and
• Object to certain types of uses of your personal information.

Exercising Your California Privacy Rights

To exercise the rights described above, please submit a verifiable consumer request to us by writing to privacy@majorel.com with the subject line ‘For the attention of the Data Protection Officer’.

Only you or your authorized agent may make a verifiable consumer request.  The 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.  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 endeavour to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by email. Any disclosures we provide will only cover the 12-month period preceding the request.  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.

Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:

• Deny you use of our Services.
• Provide you a different level or quality of Services.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this document. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes.

Contact Information

If you have any questions or requests, or wish to make a complaint, you may contact us by writing to privacy@majorel.com with the subject line ‘For the attention of the Data Protection Officer’

Last updated: 05/2022