Privacy Notice for California Residents

Effective date: June 11, 2020
Last modified: December 22, 2020

This Privacy Notice ("Notice") for California Residents supplements the information contained in DEKRA’s Privacy Notice and applies solely to the personal information held by DEKRA pertaining to a California resident (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Consumer Privacy Act Regulations (the “Regulations”). Any terms defined in the CCPA or the Regulations have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (”B2B personal information”) from some of its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“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, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act (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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act.

Our Privacy Notice describes the information we collect and its sources. This Notice organizes that information around the personal information categories set forth in the CCPA and indicates the categories of personal information that we have collected from consumers within the last twelve (12) months:

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.	YES
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).	YES
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 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.	YES
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.	YES
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

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

Directly from you. Examples of information that we might collect directly from you include:

Information that you provide by filling in forms on our websites. This includes information provided at the time of registering to receive materials or coupons from our websites, subscribing to our mailing list, requesting further services, applying for jobs, making online purchases through our websites or completing online surveys. We may also ask you for information when you enter a contest or promotion sponsored by us, OR when you report a problem with our websites.
Records and copies of your correspondence (including e-mail addresses and chat content), if you contact us.
Your search queries on our websites.
Details of transactions you carry out with us.

Indirectly from you. Examples of information that we might collect indirectly from you about your equipment, browsing actions and patterns, including:

Details of your visits to our websites, including traffic data, location data, logs and other communication data and the resources that you access and use on the websites.
Information about your computer and internet connection, including your IP address, operating system and browser type.
Other information based upon our observation of your behavior.

About you from other sources.

Information provided by subsidiaries or affiliates of our parent company, DEKRA SE.
Information provided by third parties, for example, companies from whom we may purchase or rent data.

Use of Personal Information

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

To fulfill the reason you provided the information. For example, if you share your information to request a price quote or ask a question about our products or services, we will use that information to respond to your inquiry. If you provide your information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new orders.
To develop, customize and improve our products, services or our websites.
To present our websites and contents to you, to personalize your website experience, to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or text message (with your consent, where required by law) and to allow you to use interactive features on our websites.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To create, maintain, customize and secure your account with us, and to provide you with support and respond to your inquiries.
For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
To promote our products and services to you.
To consider your candidacy for working at DEKRA.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our websites or any products or services we offer or provide though it.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us about our website users is among the assets transferred.
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.
For any other purpose with your consent.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Disclosures of Personal Information for a Business Purpose

We may disclose your personal information to a third party for a business purpose. In the last twelve (12) months, DEKRA has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

Our parent company and affiliate companies
Our service providers
Our business partners
Our accreditation bodies

Sales of Personal Information

DEKRA does not sell or rent your personal information to third parties for such third parties’ own purposes.

Your Rights and Choices

California residents have the following rights:

Right to Opt-out of Sale: We do not sell personal information, however we are providing the following information to meet CCPA requirements. California residents have the right to opt-out of the sale of their personal information. To exercise this right, please email us at privacy.na@dekra.com with “California Request to Opt-Out” in the subject line, or call us toll free at 1-877-646-7990. You may also opt-out on our website by clicking here .

Right to Know: California residents have the right to request that we disclose what personal information we collect, use, disclose and sell about them specifically. To submit a request to exercise this right to know, please email us at privacy.na@dekra.com with “California Request to Know” in the subject line, or call us toll free at 1-877-646-7990. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access. We do not currently provide these access rights for B2B personal information.

Right to Delete: California residents have the right to request the deletion of personal information that we collect or maintain about them. To submit a request to delete personal information, please email us at privacy.na@dekra.com with “California Request to Delete” in the subject line, or call us toll free at 1-877-646-7990. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA. We do not currently provide these deletion rights for B2B personal information.

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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
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.
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:

Calling us at 1-877-646-7990.
Emailing us at privacy.na@dekra.com
Visiting www.dekra.us

If you submit a request to exercise your CCPA rights, we may ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will only use any additional information we collect for the purposes of verifying your identity and for security or fraud-prevention purposes.

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 can designate an authorized agent to make a request under the CCPA on your behalf if:

The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request, please have the authorized agent take the following steps in addition to the steps described earlier:

Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to DEKRA North America, Inc., c/o Legal Department, 1945 The Exchange SE, Suite 300, Atlanta, GA 30339; and
Provide the information we request in our response to your email to verify your identity.

You may make a verifiable consumer request for access or data portability twice within a 12-month period.

Response Timing and Format

We will confirm receipt of your request within 10 days (and provide you with information on how we will process your request, including our verification process) and will work to respond to your request within 45 days from the date of our receipt of your request (unless additional time is necessary, and, in such cases, we will explain to you the reason it may take more than 45 days to respond). 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 our receipt of the request. If we deny your request, we will explain why.

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.

CCPA Data Rights Are Not Available for Certain Personal Information

CCPA data rights are not available for personal information we collect about you in the course of you acting as a job applicant to or an employee, owner, director, officer, or contractor of DEKRA. Any personal information we collect in these contexts will only be used within the context of your role or former role in these capacities.

Financial Incentives

DEKRA may offer coupons for discounts on consumer services via its website. You may elect to receive available coupons by providing DEKRA with certain Identifiers (including your name, email address and zip code) and answering various questions on our website. DEKRA may also offer access to additional content via its website. You may elect to receive this content by providing DEKRA with certain Identifiers (including your name, company name, job title, contact information and country of residence).

DEKRA will use the information you provide to send the coupon or information that you requested, and also to send you other coupons or marketing communications that DEKRA believes may be relevant to you.

You have the right to withdraw from our couponing program and other marketing communications at any time. You may exercise this right by clicking here and selecting the “Marketing Unsubscribe” option under “Request Type.”

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes once per calendar year. This information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities). To make such a request, please send an email to privacy.na@dekra.com or write us at the address below.

Contact Information

If you have any questions or comments about this Notice, the ways in which DEKRA collects and uses your information described here or 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: 1-877-646-7990
Website: www.dekra.us
Email: privacy.na@dekra.com

Postal Address:
DEKRA North America, Inc.
Attn: Legal Department
1945 The Exchange SE, Suite 300
Atlanta, GA 30339