Effective: 12/01/2022
Last Updated: 12/19/2022

Component Sourcing International, and the subsidiaries and affiliates of our companies (collectively, “CSI,” “we,” “us,” or “our”) developed this Privacy Policy (“Privacy Policy” or “Policy”) to provide individuals in the United States with information concerning our Personal Information collection, usage, and transfer practices, as well as our privacy and security practices.  This policy does not apply to workforce-related Personal Information collected from employees or similar individuals.

For purposes of this Privacy Policy, the term “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. The terms “you” and “your” refer to the person reading this Privacy Policy, which may include CSI customers, potential customers, subcontractors, and suppliers, as well as individuals working for CSI’s customers, potential customers, subcontractors, and suppliers; CSI’s job applicants; and individuals that visit our websites. If you reside outside of the United States, please review our Global Privacy Policy.

To jump to a specific section of this Privacy Policy, please click on a link below:

1. Categories of Personal Information We Collect
2. Categories of Sources of Personal Information We Collect
3. Purposes for Collecting Personal Information
4. Purposes for Disclosing Personal Information
5. Categories of Third Parties to Whom Personal Information is Disclosed
6. Cookies & Similar Technologies
   1. What are Cookies?
   2. How Do We Use Cookies?
   3. How Can You Manage Cookies?
7. Third-Party Privacy Practices
8. Children’s Privacy
9. Protection of Your Personal Information
10. Retention of Personal Information
11. California Notice of Third-Party Disclosures, Selling, and Sharing; Financial Incentives; and Privacy Rights
    1. Third-Party Disclosures, Selling, and Sharing
    2. Notice of Financial Incentive
    3. CCPA Privacy Rights
    4. Shine the Light Privacy Rights
12. Other Personal Information Rights
13. How to Exercise Privacy Rights
    1. General Methods for Submitting Requests
    2. Designating An Authorized Agent
    3. Identity Verification
14. Disability Assistance
15. Do Not Track and Other Similar Technologies
16. Cross-Border Personal Information Transfers
17. Privacy Policy Updates
18. How To Contact Us

I. Categories of Personal Information We Collect

We have collected the following categories of Personal Information within the last twelve (12) months and/or reasonably anticipate collecting the following categories of Personal Information moving forward:

• Identifiers, such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, or other similar identifiers.
• Personal Information Categories Listed in California Customer Records Statute, such as a name, signature, driver’s license or state identification number, Social Security number, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information. Some Personal Information included in this category may overlap with other categories.
• Characteristics of Protected Classifications under California or Federal Law, such as citizenship or sex/gender. Some Personal Information included in this category may overlap with other categories.
• Commercial Information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or Other Similar Network Activity Information, such as browsing history, search history, or information on your interaction with a website, application, or advertisement.
• Professional or Employment-Related Information, such as occupation or current or past job history or performance evaluations.
• Education Information as Defined in the Family Education Rights and Privacy Act, such as student transcripts, GPA, academic evaluations, or other education information.
• Sensitive Personal Information, such as Personal Information that reveals your Social Security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password or credentials allowing access to an account. CSI does not use or disclose Sensitive Personal Information for purposes other than those specified in Section 7027(m) of the CCPA Regulations.

II. Categories of Sources of Personal Information We Collect

We may collect the above-described categories of Personal Information from one or more of the following sources:

• You. We collect Personal Information that you provide to us, such as when you contact us by phone, email or webform; subscribe to a newsletter, marketing email, or other publication; engage us on a service project; submit a supplier or subcontractor registration or update; create an online customer portal account on our websites; purchase something directly though one of our online e-commerce channels or customer forms,  or apply for a job.
• Our Automated Information Collection Technologies. We use automated data collection technologies for reporting and analysis purposes.  For example, we consider metrics such as how you and others interact with our website and applications, ease of website navigation, and the performance of our marketing efforts.  For additional information, see the Cookies & Similar Technologies section, below.
• Your Employer. Your employer may provide us with your Personal Information if (1) your employer is our customer; (2) your employer is our subcontractor or supplier; or (3) if you are a job applicant, and we contact your current or former employer in connection with your job application.
• Social Media Platforms and Networks. If you connect or interact with us on social media platforms and networks such as Facebook, Pinterest, Twitter or Instagram (“Social Media Platforms”), for example, by liking our page or sharing something we post, such Social Media Platforms may provide us with information concerning you, such as your name and other Personal Information.  In addition, the Social Media Platforms will have access to information about you and your use of the Social Media Platforms.  The information that we collect relating to your connections or interactions with us on Social Media Platforms is subject to this Privacy Policy.  The information collected by the Social Media Platforms remains subject to the Social Media Platforms’ privacy practices.
• State Agencies and Organizations that Make Personal Information Publicly Available. We may collect information about you from state agencies and organizations providing publicly available information.
• CSI’s Third-Party Service Providers. We may receive information about you from our third-party service providers, including but not limited to our website hosting providers, website analytics service providers, and website content management service providers (g., qualified lead generation partners).

III. Purposes for Collecting Personal Information

We may collect the above-described categories of Personal Information for one or more of the following business, commercial, or other purposes:

• To audit current transactions with consumers and concurrent transactions, including but not limited to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• To help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
• To debug, specifically to identify and repair errors that impair existing and intended website or other technological system functionality.
• To perform services and provide goods on behalf of CSI, including maintaining or servicing customer accounts; providing customer service; processing or fulfilling customer orders and transactions; verifying customer information; processing payments; or providing similar services on behalf of CSI.
• To provide you with advertising and marketing services and analyze our promotional advertising and marketing campaigns.
• To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by CSI; and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by CSI.
• To undertake internal research for technological development and demonstration.
• To respond to inquiries about our services and products and answer questions about the same.
• To send newsletters, marketing emails, or other publications to individuals.
• To request services and products from our suppliers and subcontractors; assess the risks, qualifications, and capacity of our suppliers and subcontractors; and pay our suppliers and subcontractors for services and products provided.
• To receive feedback on services and products, and gather information needed to inform decisions about innovation, growth, pricing, and promotions.
• To conduct analytics to understand how individuals use our websites; determine the methods and devices used to access our websites; and make improvements to our websites.
• To investigate any instances of property damage, theft, and other crimes on or near our offices, parking structures, project sites, and other spaces, and to assist law enforcement agencies in their investigations of the same.
• To provide interactive features for our websites, such as customer account portals and job application forms.
• To receive and review job applications; communicate with job applicants about the status of their applications; verify job applicant identity, qualifications, and experience; evaluate job applicant qualifications and experience; and determine whether applicants are a good fit for the position they are interested in.
• To evaluate our success in pursuing our goal to be an equal opportunity employer and to report required aggregated information to federal regulators.
• To meet our regulatory reporting requirements and comply with our legal and regulatory obligations, including those that require employers to maintain specified types of records.
• To respond to law enforcement requests; meet our obligations in legal proceedings and government investigations; and otherwise comply with applicable laws, court orders, and government regulations.
• To provide information pertinent to an actual or potential merger, acquisition, or other reorganization.
• To protect and defend our legal interests.
• As necessary or appropriate to protect CSI’s rights and property, and the rights, property, and safety of CSI’s customers, employees, subcontractors, and other individuals.
• As otherwise described by CSI to an individual at or before the time that CSI collects such individual’s Personal Information.

IV. Purposes for Disclosing Personal Information

We may disclose the above-described categories of Personal Information for one or more of the following business or commercial purposes:

• To audit current transactions with consumers and concurrent transactions, including but not limited to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• To help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
• To debug, specifically to identify and repair errors that impair existing and intended website or other technological system functionality.
• To perform services and provide goods on behalf of CSI, including maintaining or servicing customer accounts; providing customer service; processing or fulfilling customer orders and transactions; verifying customer information; processing payments; or providing similar services on behalf of CSI.
• To provide you with advertising and marketing services and analyze our promotional advertising and marketing campaigns.
• To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by CSI; and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by CSI.
• To undertake internal research for technological development and demonstration.
• To request services and products from our suppliers and subcontractors.
• To conduct analytics to understand how individuals use our websites; determine the methods and devices used to access our websites; and make improvements to our websites.
• To investigate any instances of property damage, theft, and other crimes on or near our offices, parking structures, project sites, and other spaces, and to assist law enforcement agencies in their investigations of the same.
• To provide interactive features for our websites, such as customer account portals and job application forms.
• To verify job applicant identity, qualifications, and experience.
• To evaluate our success in pursuing our goal to be an equal opportunity employer and to report required aggregated information to federal regulators.
• To meet our regulatory reporting requirements and comply with our legal and regulatory obligations, including those that require employers to maintain specified records.
• To respond to law enforcement requests, meet our obligations in legal proceedings and government investigations, and otherwise comply with applicable laws, court orders, and government regulations.
• To provide information pertinent to an actual or potential merger, acquisition, or other reorganization.
• To protect and defend our legal interests.
• As necessary or appropriate to protect CSI’s rights and property, and the rights, property, and safety of CSI’s customers, employees, subcontractors, and other individuals.
• As otherwise described by CSI to an individual at or before the time that CSI collects the individual’s Personal Information.

V. Categories of Third Parties to Whom Personal Information is Disclosed

In connection with the purposes set forth in this Privacy Policy, we may disclose your Personal Information to one or more of the following categories of recipients:

• Third-party service providers and subcontractors that perform services on our behalf: We may share Personal Information with third-party service providers and subcontractors that perform services on our behalf, including marketing and search engine optimization, advertising, sales channel management, website hosting, website analytics, website content management, customer relationship management, data storage, security, fraud prevention, talent management and recruitment, and legal services.
• Social Media Platforms: Social Media Platforms may offer functionalities, plugins, widgets, or tools in connection with our Sites (g., to share our products with your friends and followers on Social Media Platforms).  If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by such Social Media Platforms and will be subject to such Social Media Platforms’ privacy practices.
• Governmental entities and third parties in connection with legal matters: We may disclose Personal Information to governmental entities, such as regulatory agencies, law enforcement, and judicial authorities, as well as other third parties providing assistance to us or other parties in relevant legal matters (g., attorneys and e-discovery service providers), under any of the following conditions: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, warrant, legal process, or other legal obligation; (c) to enforce or apply any of our terms and conditions, policies, or other agreements; (d) to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; or (e) as necessary to pursue available legal remedies or defend legal claims.
• Third parties in connection with a potential reorganization: We may share Personal Information with a prospective seller, buyer, and any third-party service provider assisting CSI or a prospective seller or buyer in connection with the potential reorganization (g., a law firm assisting CSI) in the event of a potential reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of CSI’s assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

VI. Cookies & Similar Technologies

As you interact with our websites and applications, we, with assistance from third-party analytics service providers, collect Personal Information pertaining to your use of CSI’s websites and the devices and programs from which you access our websites and applications (“Usage Data”) using cookies and similar technologies.

A. What are Cookies?

Cookies are small computer files sent or accessed from your browser on the hard drive of your computer, mobile device, or tablet that contain information about your device, such as your user ID, user settings, browsing history, and activities conducted while browsing websites (e.g., pages viewed; navigation around a website).  Cookies are used to “remember” when your computer or devices access our websites.

B. How Do We Use Cookies?

Cookies are essential for the effective operation of our websites and help you to navigate our websites.  CSI and its third-party service providers use cookies to monitor individuals’ browsing behavior.

The primary purposes for which cookies are used are: (1) For the effective operation of our websites, especially in connection with website navigation and online communications; (2) To monitor and improve the quality and user-friendliness of our website; (3) To monitor the success of our advertising campaigns and marketing-related activities (e.g., promotions); and (4) To assist CSI in detecting and preventing fraud, denial of services attacks, and other malicious activity directed at our websites.

How Can You Manage Cookies?

If you do not want Usage Data collected through the use of cookies and similar technologies, there is a procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.  Cookies that are required to enable core site functionality cannot be disabled without causing substantial website functionality issues.  To assist in controlling website-specific cookies, check the privacy and cookie setting in your preferred browser.

We neither have access to, nor does this Privacy Policy govern, the use of cookies and similar technologies that may be placed on your device you use to access our websites by such third parties. If you are interested in opting out of tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs.

VII. Third-Party Privacy Practices

Our websites may provide links to other third-party websites as a service to you.  We are not responsible for the privacy practices of such other third-party websites. If you link to such a website through our websites, you should always review any privacy notice that is available for that website.

VIII. Children’s Privacy

Our websites are not directed to individuals under the age of 13.  We do not knowingly collect any Personal Information from users under 13 years of age. No Personal Information should be submitted to our websites by visitors under 13 years of age.  If we learn that we have collected Personal Information from someone under 13, we will take steps to delete the Personal Information as soon as possible.

IX. Protection of Your Personal Information

We implement technical and organizational measures designed to assist in maintaining the security and confidentiality of Personal Information; safeguarding against anticipated threats to the confidentiality, integrity, and availability of Personal Information; and protecting your Personal Information against accidental or unlawful destruction, loss, alteration, and unauthorized access or disclosure.

However, whenever Personal Information is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party.  No system or online transmission of data is completely secure.  In addition to the technical and organizational measures that CSI has in place to protect your Personal Information, you should use appropriate security measures to protect your Personal Information.  If you believe that any Personal Information you provided to us is no longer secure, please notify us immediately by phone at (704) 843-9292 or by email at Compliance@CSI.com.

X. Retention of Personal Information

CSI will retain your Personal Information for the time period necessary to fulfill the purposes for which your Personal Information was originally collected or received and to meet CSI’s legal obligations.

XI. California Notice of Third-Party Disclosures, Selling, and Sharing; Financial Incentives; and Privacy Rights

A. Third-Party Disclosures, Selling, and Sharing

We have disclosed the following categories of Personal Information for business purposes within the past twelve (12) months and/or reasonably anticipate disclosing the following categories of Personal Information for business purposes (i.e., purposes listed in the CCPA’s definition of “business purpose”),“selling” (i.e., sold, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated a consumer’s Personal Information to a third party for monetary or other valuable consideration), or “sharing” (i.e., shared, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated orally, in writing, or by electronic or other means, a consumer’s Personal Information to a third party for cross-context behavioral advertising) to the following categories of third parties:

We may sell or share the above-described categories of Personal Information for one or more of the following business or commercial purposes:

• Performing services and providing goods on behalf of CSI, including maintaining or servicing customer accounts; providing customer service; processing or fulfilling customer orders and transactions; verifying customer information; processing payments; or providing similar services on behalf of CSI.
• To provide you with advertising and marketing services and analyze our promotional advertising and marketing campaigns.
• To send newsletters, marketing emails, or other publications to individuals.

CSI has no actual knowledge of selling or sharing the Personal Information of consumers (i.e., California residents) under 16 years of age.

B.  Notice of Financial Incentive

We offer the following financial incentive (as such term is defined under the CCPA):

When you visit enaecogoods.com, we offer a referral program where you can send 15% off to a friend (by using a uniquely generated discount code) for $10 off your next order of over $30. If you choose to participate in this referral program, you can opt in by providing us with your name and email address in order to opt-in to this program.  After you provide us with your name and email address, we will provide you with a referral code to forward to your friend.  You will receive the $10 off your next order of over $30 if the friend to which you sent the referral code enters such referral code when purchasing an item through one of our e-commerce channels. We estimate that the value of the Personal Information that you provide to us is reasonably equivalent to the dollar off amount provided to you (i.e., $10 off your next purchase of over $30) because of the anticipated profit generated from the collection of such Personal Information.

You have the right to withdraw from this financial incentive at any time. You may exercise this right to withdraw from this financial incentive program by contacting our Compliance Team by email at Compliance@CSI.com, by phone at (704) 843-9292 or by writing to us at the following address, 1301 Westinghouse Blvd Suite I, Charlotte, NC 28273.

C.  CCPA Privacy Rights

California residents have certain rights under California privacy law, including but not limited to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), which gives California residents (“consumers” or “you”) certain rights and control over their Personal Information.  This section of CSI’s Privacy Policy applies solely to our customers, subcontractors, suppliers, and their employees and officers; users of our website; job applicants and job candidates; and other individuals whose Personal Information we collect that reside in the State of California. If you are a California resident, you have the following privacy rights under the CCPA:

• Right to Know. You have the right to request that we disclose what Personal Information we have collected about you, including the categories of Personal Information; the categories of sources from which the Personal Information was collected; the business or commercial purposes for collecting, selling, or sharing Personal Information; the categories of third parties to whom we disclose Personal Information; and the specific pieces of Personal Information we have collected about you.
• Right to Request Deletion. You have the right to request deletion of Personal Information about you that we have collected, subject to certain exceptions.
• Right to Request Correction. You have the right to request correction of inaccurate Personal Information that we maintain about you.
• Right to Request to Opt Out of Sale or Sharing. You have the right to request to opt out of the selling or sharing of your Personal Information. You may opt of the sale and/or sharing of your Personal Information through the use of an opt-out preference signal, or by clicking our Do Not Sell or Share my Personal Information Link. CSI does not sell your personal information. However, if you are a California resident, you have the right to opt out of our consumer database. To exercise this opt-out right, whether you have an account or not, please submit a request via Compliance@CSI.com. You may also submit an opt-out request to us using the submission methods described in the Exercising Privacy Rights Section, below.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment from us for exercising your rights under the CCPA.

D.  Shine the Light Privacy Rights

Under California’s “Shine the Light” law, California residents can annually request certain information about the Personal Information, if any, we shared with third parties for their direct marketing purposes in the immediately preceding twelve (12) months. You may request this information by contacting us by email at Compliance@CSI.com or by writing us at the following address: (704) 843-9292.

XII. Other Personal Information Rights

If you reside in states other than California, or other parts of the world, you may have privacy rights under law[s] that apply to you.  If you are located in Europe or the UK, you are entitled to exercise the privacy rights that are addressed in our Global Privacy Policy.  Please reach out to us if you have any questions about or if you would like to exercise any privacy rights to which you are entitled, using the contact information provided in the How to Contact Us section below.

XIII. How to Exercise Privacy Rights

In this section, we provide an explanation of our process for individuals to exercise their California Privacy rights or any other privacy rights to which they are entitled by law, for designating an authorized agent, and for verifying the identity of individuals who submit privacy rights requests.

A. General Methods for Submitting Requests

To exercise your rights described in this Privacy Policy, please submit a verifiable consumer request to us through one of the following methods:

• Submission Methods:
  • Emailing us at Compliance@CSI.com or
  • Calling us at (704) 843-9292.
  • Mail us by writing to us
    Attention Compliance;
    1301 Westinghouse Blvd Suite i
    Charlotte, NC 28273

• Submission Contents: Requests to exercise your privacy right should include the following information:
  • Your name;
  • The country in which you currently reside;
  • If you reside in the United States, the state in which you currently reside;
  • Which privacy right(s) you are seeking to exercise;
  • Details that will assist us in responding to your request, including:
    • If you are exercising access rights, the information to which you are requesting access;
    • If you are exercising deletion rights, the information for which you are requesting deletion;
    • If you are exercising correction rights, the information you believe to be inaccurate or incomplete;
    • Any other relevant information about your Personal Information and/or the right you are exercising (e., information that you think would assist us in responding to your request); and
    • A phone number and/or email address at which we can reach you.

B. Designating An Authorized Agent

Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may designate an authorized agent to make a verifiable consumer request on your behalf by submitting such request to CSI via email at Compliance@CSI.com with “Request for Authorized Agent” in the subject line. Before taking action in response to such a request, we will require your authorized agent to verify such representative’s authority.

C. Identity Verification

Before responding to your request to exercise your rights, we must verify your identity through reasonable verification measures.  If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account.  If you are requesting the disclosure or deletion of Personal Information, we may require you to re-authenticate yourself before disclosing or deleting your Personal Information.

Our verification processes also may include requiring you to provide answers to questions pertaining to the information we have on file for you; requesting confirmation of the request using the email address we have on file for you; or calling the phone number we have on file for you to confirm the request.

If we cannot verify your identity based on information we already have, we may request additional information from you.  If this is necessary, we will only use the additional information for purposes of verifying your identity and for fraud-prevention.  If we are unable to reasonably verify your identity (and thus unable to comply with your request), we will advise you why that is the case.

XIV. Disability Assistance

We want this Privacy Policy to be accessible to everyone.  Any individuals with difficulty accessing information in this Privacy Policy are encouraged to contact us by email at Compliance@CSI.com or by calling us at (704) 843-9292.

XV. Do Not Track and Other Similar Technologies

We do respond to do not track signals or other similar technologies. Although we do not track your online activities over time and across third-party websites or other online services, our website may place analytic or advertising cookies originating from third parties that may be used for such tracking on your computers and devices.   These third parties may collect Personal Information relating to your online activities over time and across different sites and applications when you use our websites in order for us to provide you with content that is likely to be of interest to you.

XVI. Cross-Border Personal Information Transfers

We may transfer and store your Personal Information on servers outside of your country.  Your Personal Information may be transferred to and processed by CSI and its customers, third-party service providers, subcontractors, and suppliers in the United States or in other countries whose laws may not be as comprehensive and protective as the laws of your country.  For example, Personal Information stored in the United States may be subject to lawful access requests by U.S. federal and state law enforcement and national security authorities.

XVII. Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new services or offerings; as we improve our current services and offerings; and as technologies and laws change. If we make material changes to how we treat the Personal Information that falls within the scope of this Privacy Policy, we will provide notice to you by email or through a prominent notice on the homepage of our websites that is posted thirty (30) days prior to the effective date of the updated Privacy Policy. Any changes will become effective thirty (30) days after our posting of the revised Privacy Policy on our websites.  The effective date and the date this Privacy Policy was last updated are set forth on the top of the first page of the Privacy Policy.

XVIII. How To Contact Us

If you have any questions or concerns about this Privacy Policy, your privacy rights, our privacy practices, or if you need any assistance relating to your Personal Information, you may contact our Compliance Team by email at Compliance@CSI.com, by phone at (704) 843-9292, or by writing to us at Attention Compliance; 1301 Westinghouse Blvd Suite i, Charlotte, NC 28273.