CCPA Standard work
    The Right to Be Informed
    Model Public-Facing Privacy Notice

    This Privacy Notice applies to Hennessy Industries collection and use of California Residents’ Personal Information, particularly where such use or collection is governed by the California Consumer Privacy Act (CCPA) and relates to consumer transactions. 1 Although the CCPA applies to Personal Information of individuals that are residents of California, Hennessy Industries may as a courtesy extend some of the CCPA’s requirements to the Personal Information of residents of the United State of America more broadly.

    Please read this Privacy Notice carefully because it provides important information and explains your rights. Please visit this website from time to time, as we may update our notice for changes in the law or our data practices. If you have any questions or concerns, or wish to exercise your privacy rights, we invite you to contact us by any of the methods listed at the bottom of this Privacy Notice. Notice last updated: January 1, 2020

    Who are we? 

    We are Hennessy Industries of 1601 JP Hennessy Drive; LaVergne, TN, 37086, our phone number is (615)641-7533. We provide aftermarket wheel service manufactured products. This Privacy Notice explains how we use the Personal Information we hold on prospective, current, or former customers, and the rights you may have in relation to that Personal Information. We may use your information jointly with our affiliated operating companies worldwide and Fortive Corporation, our parent company, located at 6920 Seaway Boulevard; Everett, Washington, 98203; USA.

    What does this Privacy Notice cover?

    We take your privacy seriously. This notice:

    • sets out the types of Personal Information that we collect about you;
    • explains from where we collect Personal Information about you;
    • explains how and why we collect and use your Personal Information;
    • explains when, why and with whom we will share your Personal Information;
    • explains the different rights and choices you have when it comes to your Personal Information; and
    • explains how you can contact us.

    What Personal Information have we collected in the past 12 months?

    It is routine for us to collect, process and store Personal Information about you over the course of your relationship with us.

    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. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.

    The following chart describes the categories of Personal Information we may have collected about you in the past 12 months and, for each category, where and why we collected it, and the categories of entities with which we shared or sold the Personal Information, if any.

    __________________

    1As noted in the description of the policy’s application to consumer transactions, this Privacy Notice does not apply to Personal Information collected or used exclusively in the business-to-business context, and it does not cover Hennessy Industries’ collection or use of Personal Information in the Human Resources context.

     

    Category of Personal Information (PI)

    Sources from which PI was collected

    Purpose of collection

    Categories of entities with whom PI was shared

    Categories of entities to whom PI was sold 2

    Address and other identifiers – such as name, postal address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers

    Directly from you; From your employer; From an agent/third party acting on your behalf, such as a distributor, one of our affiliated operating companies, a lead referral service, or a data provider who collected information from you directly or indirectly; Through publicly available sources

    To perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments; to verify your identity

    Service providers, including to provide and support our data management, analytics, security, and storage systems;

    Group companies, for business and operational purposes

    None

    Financial information

    Directly from you

    To perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments; to verify your identity

    Service providers, including to provide and support our data management, analytics, security, and storage systems;

    Group companies, for business and operational purposes

    None

    Education or other professional information

    Directly from you

    To perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments; to verify your identity

    Service providers, including to provide and support our data management, analytics, security, and storage systems;

    Group companies, for business and operational purposes

    None

    Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology) 

    From the use of our CCTV cameras.  Where we have cameras on our premises, your image and movements may be recorded.

    Service providers, including to provide and support our data management, analytics, security, and storage systems

    None

    Biometric information

    Directly from you

    To perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments; to verify your identity

    Service providers, including to provide and support our data management, analytics, security, and storage systems;

    Group companies, for business and operational purposes

    None

    2This includes information purchased from third parties.

    What categories of Personal Information will you collect in the next 12 months and why?

    We will continue to collect the same categories of Personal Information listed in the chart above, for the same purposes. If this should change, we will issue an updated Privacy Notice.

    Additional facts about how we share your Personal Information

    The third parties with whom we share your Personal Information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.

    We also share your Personal Information with third parties to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our websites, our businesses, or the public.

    We do not grant access to your Personal Information to any other third parties unless we say so in this Privacy Notice or unless the law requires it.

    We do not knowingly collect the Personal Information of minors

    Our products and services are not directed to minors under the age of 18 and we do not knowingly collect or sell the Personal Information of minors.

    How do we keep your Personal Information secure?

    We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards as outlined in the report issued by the California Attorney General in February 2016, available at https://oag.ca.gov/sites/all/files/agweb/pdfs/dbr/2016-data-breach-report.pdf. Specifically, among other safeguards, our reasonable security program implements and maintains all 20 of the Center for Internet Security’s Critical Security Controls for Effective Cyber Defense identified in Appendix A of the California Attorney General Report. As noted in that report, “there is no perfect security,” and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

    Do we respond to “Do Not Track” signals?

    No, we do not respond to browser or do not track signals.

    How do you access or request deletion of your Personal Information?

    You can log into your account to access or request deletion of certain information about yourself, or you can do so by using the contact details set out at the end of this Privacy Notice.

    What rights do you have in relation to the Personal Information we hold on you?

    Residents of certain states may have the following additional privacy rights.

    Your Right To Request Disclosure Of Information We Collect And Share About You

    We are committed to ensuring that you know what information we collect about you. You can submit a request to us for the following information, with respect to Personal Information we have collected :

    • The categories of Personal Information we’ve collected about you.
    • The categories of sources from which we collected the Personal Information.
    • The business or commercial purposes for which we collected or sold the Personal Information.
    • The third parties with whom we shared the information.
    • The specific pieces of information we collected.

    We are also committed to ensuring that you know what information we share about you. You can submit a request to us for the following further information:

    • The categories of Personal Information (if any) that we have sold about you, the third parties to whom we sold that Information, and the category or categories of Personal Information sold to each third party.
    • The categories of Personal Information that we have shared with service providers who provide services to us.

    Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.

    Your Right To Request The Deletion Of Personal Information We Have Collected From You

    Upon your request, we will delete the Personal Information we have collected about you, except for situations where specific information is necessary for us to: provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.

    Your Right To Ask Us Not To Sell Your Personal Information

    You can always tell us not to sell your Personal Information. You can exercise this right by clicking on this link: https://privacyportal-cdn.onetrust.com/dsarwebform/621e5a24-4a48-4985-9286-c0aef822c02d/286615cc-a588-4fe2-bfe5-4bc6a8e75587.html. This link will allow you to exercise your right to opt-out of the sale of your Personal Information under applicable law, and provide the mechanism for you to submit certain Personal Information we will use to verify your identity and the validity of your request. You may also use an authorized agent to exercise this right. For more information on how to authorize us to respond to an authorized agent on your behalf, click https://privacyportal-cdn.onetrust.com/dsarwebform/621e5a24-4a48-4985-9286-c0aef822c02d/286615cc-a588-4fe2-bfe5-4bc6a8e75587.html

    Once we receive and authenticate your request that we not sell your Personal Information, we will discontinue selling it unless you subsequently expressly authorize us to do so. We may ask for your permission to resume sale of your Personal Information at a later date, but will wait at least 12 months from receipt of your request before doing so. We do not and will not sell personal information to Third Parties.

    We Are Committed To Honoring Your Rights

    We are committed to providing Consumers control over their Personal Information. If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly.

    California Shine the Light

    California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. No information is shared with third parties for their own marketing purposes.

    For people who do business with us on behalf of their employer or contractor

    If you have provided your Personal Information to Hennessy Industries when communicating or transacting with us on behalf of your employer or another business, you can always direct us not to sell your information by following the directions above. Should you exercise this right, Hennessy Industries will not discriminate against you for doing so and will continue to treat you fairly in our subsequent interactions with you and the business you represent.

    How can you make a request to exercise your rights?

    To exercise any of the rights above, or to ask a question, contact us at 1-800-688-6359, click here https://privacyportal-cdn.onetrust.com/dsarwebform/621e5a24-4a48-4985-9286-c0aef822c02d/286615cc-a588-4fe2-bfe5-4bc6a8e75587.html, or use the contact details set out at the end of this Privacy Notice.

    How will we handle a request to exercise your rights?

    For requests for access or deletion, we will first acknowledge receipt of your request within 10 days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfil, we’ll let you know.

    We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

    In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavour to provide you with an explanation as to why.

    How will we verify your identity when you submit an access or deletion request?

    Requests for Specific Pieces of Personal Information
    We will ask you for at least three pieces of Personal Information and endeavour to match those to information we maintain about you. Additionally, we require that you provide a declaration attesting to your identity, signed under penalty of perjury.

    If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial. Additionally, we will treat the request as one seeking disclosure of the categories of Personal Information we have collected about you and endeavour to verify your identity using the less-stringent standards applicable to such requests.

    Requests for Categories of Personal Information Collected About You
    We will ask you for at least two pieces of Personal Information and endeavour to match those to information we maintain about you.

    If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.

    Requests for Deletion Of Personal Information We Have Collected From You
    We will ask you for at least two pieces of Personal Information and endeavour to match those to information we maintain about you.

    If we are unable to verify your identity with the degree of certainty required before providing you with the information requested, we will notify you to explain the basis of our denial.

    Authorized Agents – Additional Verification Required
    You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State.

    If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. You will be required to verify your identity by providing us with certain Personal Information as described above, depending on whether you hold an account with us or not and the nature of the information your require, which we will endeavour to match the information submitted to information we maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf, and the scope of that authorization. The agent will be required to provide us with proof of the agency relationship, which may be a declaration attesting to the agent’s identity and authorization by you to act on their behalf, signed under penalty of perjury. If the agent is a business entity, it will also need to submit evidence that it is registered and in good standing with the California Secretary of State. Information to identify and verify your agent can be submitted through the same mechanism and at the same time that you submit information to verify your identity.

    What about household Personal Information?

    There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above.

    If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.

    How can you contact us?

    If you have questions on the processing of your Personal Information, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us here: 1601 J. P. Hennessy Drive, LaVergne, TN 37086.

    If you would like to assert your privacy rights, you may also call us toll free at 1-800-688-6359 or submit a request online at https://privacyportal-cdn.onetrust.com/dsarwebform/621e5a24-4a48-4985-9286-c0aef822c02d/286615cc-a588-4fe2-bfe5-4bc6a8e75587.html

    Accessibility of our communications

    We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 1-800-688-6359 or contact tyler.porter@ammcoats.com

    What about changes to this Privacy Notice?

    We will review and update this Notice periodically in light of changing business practices, technology, and legal requirements. If we make a significant or material change in the way we use or share your Personal Information, you will be notified via email or a notice on our website.