CALIFORNIA PRIVACY STATEMENT

Effective Date: January 1, 2021

Tuthill Corporation (“Tuthill”, “we”, and “us”) is providing this California Privacy Statement to comply with the California Consumer Privacy Protection Act of 2018 (“CCPA”) and other applicable California statutes and any terms used below that are defined in a statute shall have the statutory meaning. This California Privacy Statement supplements the information contained in our general Privacy Policy published on our website at https://www.tuthill.com/privacy-policy (the “General Privacy Policy”) and applies only if personal information you submit to us is within the scope of the CCPA or other applicable California statute, which may be the case where we receive personal information from individuals in the State of California, USA. In the event of any conflict between this California Privacy Statement (if applicable) and our General Privacy Policy, this California Privacy Statement shall prevail.

Categories of Personal Information Collected

The section of our General Privacy Policy entitled “What personal information we collect” gives details about the personal information we collect. The personal information that we have collected from consumers in the twelve months prior to the effective date of this California Privacy Statement fall into the following categories established by the CCPA:

• Personal identifiers such as name, job title, postal address, phone numbers, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, and account name.
• Financial information such as payment card information.
• Commercial information such as records of products or services purchased or considered, and information on interactions with our distributors, channel partners or offerings.
• Internet or other network activity information such as information regarding your interactions with our services, websites or other offerings.
• Geolocation data indicating the general physical location (IP address and zip code) of you or your device.
• Audio, visual, or similar information such as audio recordings of calls to our customer service centers and CCTV video recorded at our facilities.
• Inferences drawn from any of the above information categories, including information about preferences, characteristics, behavior, and attitudes that we collect via our websites or other offerings in order to personalize content.

Sources of Personal Information

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

• Directly from our customers or prospective customers. For example, from information that our customers provide to us related to the orders for products that they purchase from us or in connection with establishing an account with us.

• Directly and indirectly from activity on our websites, mobile applications and other offerings. For example, from submissions through our website or information collected automatically from use of our websites or mobile applications.
• From publicly available sources.
• From our third party vendors or service providers, including payment processors.
• From third-party website analytics tools and cookies, web tags and other technologies that collect information about visitor traffic on our website and mobile applications.

Purposes for Collecting Personal Information

We may use or disclose the personal information we collect for the purposes identified in the section of our General Privacy Policy entitled “What we do with the information we gather” which include one or more of the following:

• Providing our products and services to you or the business you represent (for example, if you provide us with personal information in order to place an order with us, we will use that information to process your payment, complete the sale, and ship the product to you),
• Maintaining our business relationship and/or providing ongoing support, where you or the business you represent are a user of our offerings, products or services or a customer, or you otherwise engage with us for business purposes,
• Informing you about our products and services, and responding to your comments or requests for information,
• Enforcing any contracts that we enter into with you or the business you represent, or defending claims arising from such contracts,
• Operating, maintaining, improving, administering and providing our offerings, including customizing, personalizing and optimizing offerings and customer experience,
• Safety and security purposes, including where necessary to protect the rights, property or safety of us or other users or customers,
• Where we are obligated, or permitted, to do so by applicable law, regulation or legal process, including disclosure to customs or other governmental authorities, or
• As described to you when collecting your personal information.

Categories of Personal Information Shared or Sold

We may share or disclose the personal information that we collect for the purposes identified in the section of our General Privacy Policy entitled “How we share the information we gather.” In the twelve months prior to the effective date of this California Privacy Statement we have not sold any personal information of consumers. The personal information that we have disclosed about consumers for a business purpose in the twelve months prior to the effective date of this California Privacy Statement fall into the following categories established by the CCPA:

• Personal identifiers;
• Financial information;
• Commercial information;
• Internet or other network activity;
• Geolocation data;
• Audio, visual, or similar information;
• Inferences drawn from any of the above information categories.

The above categories of information have been disclosed to the following categories of third parties:

• Service providers performing services for us or assisting us to provide a requested product or service to you, including shipping companies;
• Analytics Providers that help us generate performance metrics regarding our products, services, sites or apps;
• Our affiliates and related companies;
• Payment processors;
• Third parties authorized by you, including third party channel partners and distributors.

Rights Under the CCPA

The CCPA grants California residents the following rights:

Right to Know and Data Portability
You can request information about how we have collected, used, shared, sold, disclosed and otherwise processed your personal information during the past 12 months, including the right to request the specific pieces of personal information that we possess.

Right of Deletion
You can request that we delete any of the personal information that we have collected from you. We may deny your deletion request pursuant to certain exceptions in the CCPA, and the response we provide will explain any reason for denying your request.

Right of Non-Discrimination
You have the right to not receive discriminatory treatment by us for exercising any of your CCPA rights.

Right to Opt-Out of Sale
We do not sell your personal information as provided in the CCPA. When you request a quote for products and services, we will share your personal information with third party distributors or channel partners and they may contact you regarding your project and use your personal information. By requesting a quote or otherwise authorizing disclosure of your information, you are opting-in to such use. You can contact us using the contact points below to change your privacy preferences or to control future use and disclosure of your personal information. We do not knowingly sell the personal information of minors under 16 years of age without obtaining proper opt-in consent.

Exercising Your Privacy Rights

To exercise your right to know or right of deletion, please submit a verifiable consumer request to us by either:

• Sending us an email at [email protected], or
• Writing us at Tuthill Corporation, ATTN: Privacy, 8500 S. Madison St., Burr Ridge, IL 60527, United States of America.

We reserve the right to confirm your California residency to process your requests. In accordance with the CCPA, we will need to confirm your identity to process your requests and we may require you to login to your account with us, provide information associated with your account or transactions with us, or require you to provide government identification, signed declarations and other proof of identity. You may designate an authorized agent to make a request on your behalf as provided under California law and we reserve the right to request proof of such authorization. You may also make a verifiable consumer request on behalf of your minor child. 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 that the personal information relates to you, or if you do not provide us with sufficient detail to allow us to understand and respond to your request. Our response will explain any reasons we cannot comply with a request, if applicable.

Direct Marketing Disclosures

California’s “Shine the Light” law (Civil Code Section 1798.83) requires businesses to respond to requests from California customers asking about the business’s practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. You may make a request about Tuthill’s collection and disclosure of your personal information using the contact points specified above.

Changes to Our Privacy Statement

We reserve the right to amend this California Privacy Statement from time to time as provided in our General Privacy Policy.