Privacy Policy for California Residents

This privacy policy is intended for all individuals who reside in California and outlines CTL's obligations under the California Consumer Privacy Act of 2018 ("CCPA"), as of January 1, 2020, and other California privacy laws ("Privacy Policy"). Any capitalized terms used in this Privacy Policy shall either (i) have the same meaning as found within the CCPA, or (ii) be defined within the text of this policy. This Privacy Policy is intended to supplement the information contained in CTL's general U.S. privacy policy so please refer to CTL’s Privacy Policy for additional information on the processing and protection of your Personal Information.

We may update this Privacy Policy to communicate changes in our data handling practices. When we make changes to this Privacy Policy, we will modify the Effective Date. Our changes will become effective immediately upon posting.

How to Contact Us and Processing of Your Data

  • How to Contact Us. If you have a question about this Privacy Policy or requests related to your Personal Information pursuant to the CCPA or applicable privacy laws, please email us at, and we will route your question appropriately. If you prefer to contact us by regular mail, our US Mailing address is: 9700 SW Harvest Ct. Ste 100, Beaverton, OR 97005
  • Processing of Your Data. Your Personal Information will be optimally processed in the United States. Your Personal Information may also be transmitted by us to other CTL entities for the purposes set out in this Privacy Policy, for company administration purposes, and to other third parties as further outlined below.
  • CTL including our subsidiaries ("CTL," "we," "us," and "our") owns and operates this website, which may include a software application, our products and services, and any other related commerce solution where this Privacy Policy appears ("Website"). Generally, any Personal Information collected by visiting this Website is controlled by CTL,9700 SW Harvest Ct. Ste 100, Beaverton, OR 97005, USA ("Business")

Scope of this Privacy Policy

Background and Purpose

This Privacy Policy applies to each Website operated by CTL where this Privacy Policy appears. If you are purchasing products through a CTL subsidiary, please note that this Website is hosted and/or operated by CTL under an agreement with the subsidiary who is listed as the seller of products in the terms of sale on this Website. The purpose of this Privacy Policy is to provide you with information as required under the CCPA.

Partner or Other Third-Party Privacy Policies

This Privacy Policy only applies to the use of information we collect from you through this Website and any other website on which this Privacy Policy appears. Our Website may be co-branded with the information of the company whose product you are purchasing ("Partner"). However, this Privacy Policy does not apply to information collected directly by our Partners or any other third party as we do not control these other privacy policies. Please carefully review each privacy policy posted on each website you visit.

How We Protect Your Information

CTL takes reasonable steps to provide a level of security appropriate to the sensitivity of the information we collect. We have implemented physical, technical and administrative security practices and safeguards reasonably designed to protect your Personal Information from unauthorized access and disclosure When we collect or transmit sensitive information such as a financial account number, we use industry standard methods to protect that information as required by applicable laws. Although we use reasonable measures to protect your information, we cannot guarantee the security of information provided over the Internet or stored in our databases. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse, for example, by protecting your password and signing off when finished using a shared computer or mobile device. We leverage industry best practices to mitigate potential compromises. If the Personal Information under the custody of CTL is (or is likely to be) divulged, damaged or lost, we will immediately take remedial measures, inform the users in a timely manner and report to the competent government agencies as required by applicable laws.

Collection of Information, including Use of Cookies

Information You Manually Provide

We collect Personal Information from you when you use this Website such as:

  • when you provide information during a purchase of a product or service,
  • when you request information about or otherwise use the Website,
  • when you enter into a contest or promotion, sign-up for a newsletter or related services,
  • when you submit an order or purchase, download or register products, or request additional services,
  • when you call our customer service, you may voluntarily provide information to our representatives, and
  • when you apply for a job opening or otherwise submit employment data to us.


Category: Identifiers

Examples: Full name, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.

Collected by CTL: Yes

Category: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Examples: A name, address, telephone 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.

Collected by CTL: Yes, CTL's Human Resource team may collect certain personal information listed in this category for employment purposes. CTL collects payment related information for the processing of payments in accordance with PCI-DSS standards


Category: Protected classification characteristics under California or federal law

Examples: 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).

Collected by CTL: Yes, CTL's Human Resource team may collect certain personal information listed in this category for employment purposes. However, only the employee's birthdate is required - the rest of the information is voluntary

Category: Internet or other similar network activity.

Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Collected by CTL: Yes, CTL may also receive information from your web browser. This may include information that does not identify you personally (such as the date and time of your visit). The information we receive depends on the settings on your web browser. If you created a user identity during a visit to this Website, this shall be regarded as giving your consent for processing your Personal Information, if any, and we may link the information provided by your browser to information that identifies you personally. Please review the settings on your web browser to learn how to change your browser settings. We may also collect limited Personal Information (e-mail address) through web technologies in connection with your use of a Website.

Category: Geolocation data.

Examples: Collection of geolocation data such as IP address.

Collected by CTL: Yes, when you use a smart phone, mobile device or computer to access our Website or use our mobile application, we may collect information about your physical location. We may combine this information with other location-based information (e.g., your IP address and billing/postal code), to provide you with other services on your mobile device. We share your location information only with third parties that help us provide you with services. You can opt-out of sharing this information by changing the permissions in your mobile device.

Category: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected by CTL: Yes, the Human Resources team retains this information

Cookies and Other Similar Technologies

The information we collect using cookies and similar technologies is not typically personally identifiable, but we may link it to Personal Information that you provide. We use cookies and other similar technologies to collect information and support certain features of this Website. As the Internet evolves, we may use different types of technologies for this purpose. For example, we may use these technologies to collect information about the ways visitors use this Website (such as which pages they visit, links they use). We analyze this information to better understand our visitors' interests and to improve the content and functionality of the Website. We also use the information to support Website features by not asking you to re-enter information already in our database. We also use this information to personalize your experience when you use the Website and to improve our marketing efforts, including through use of targeted advertising.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies, you may be unable to use all of the Website functionality if your browser rejects our cookies.

Information about Third-Party Cookies and Other Technologies

Web technologies may also be placed on this Website by third party providers. Also, we or third-party providers may place web technologies on behalf of the Partner whose branding appears on this Website or its service providers. In this way, our Partner would be allowed to use the data collected. This information is used to enhance your experience with the Website, for marketing analysis, for targeted and display advertising, and for quality improvement. We may collect your IP address through web technologies.

We and our Partners use third party service providers in connection with this Website, which may include Alexa Metrics, Google Analytics and Omniture, and ClickTale. These and other service providers may collect information about your visits to websites, your interaction with that website, and the products and services offered by us, our Partners and our suppliers. Their collection and use of information is subject to their own privacy policies. Please visit the applicable third party service provider if you would like to opt-out

Do Not Track Requests

If you opt-out of having your information collected through cookies and other web technologies, your existing display advertising cookie(s) will be deleted and a new cookie will attempt to be placed that instructs service providers not to track your future activities when that cookie is detected (a "no-track" cookie). If your browsers are configured to reject cookies when you visit our opt-out page, a "no-track" cookie cannot be set on your computer. Also, if you subsequently erase "no-track" cookies, use a different computer or change web browsers, you will need to opt-out again. We currently do not respond to browser "no-track" signals.

Information from Third Parties

We may also receive certain information about you from third parties such as through your use of a social network authentication to sign-in to this Website, or through other online data sources, according to the rules of the use and processing of such information established by the respective online data sources. If any information is freely available or accessible in the public domain, we will not have any obligations to you regarding the same.

Personal Information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated information
  • Information excluded from the CCPA's scope such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Use and Sharing of Information

Your Personal Information provided will be processed on our computer servers. In some cases (such as where it is necessary to fulfill our contractual obligations to you the information may also be made available to third parties providing services to CTL.

How We Use Your Data

We may use your Personal Information we collect for one or more of the following business purposes:

  • to fulfill our obligations to you based on the information you provided to us,
  • to contact you if you have requested communication from us,
  • to determine the country where you are located such as for trade compliance, security and fraud prevention,
  • to otherwise verify compliance with applicable laws,
  • to help verify that data we have about you is accurate,
  • to provide you with product updates, special offers and other promotional information, either on our own behalf or on the behalf of a Partner, where you have consented to receive it and in accordance with applicable law,
  • in connection with keys, access codes or other information so you can access the websites or services of our Partners to receive products or services,
  • as identified in a supplemental privacy notice posted on the Website, and
  • for human resources such as to collect your email address if you are applying for a position online.

We may also use your Personal Information for the following purposes where you visit the Website to complete a transaction:

  • to process your order, process payment, verify your tax status, contest chargebacks, determine your eligibility for a line of credit, or notify you of the status of your order,
  • for fraud monitoring and prevention purposes,
  • to provide you with a personalized shopping experience,
  • to register your purchase with the manufacturer or service provider for warranty, technical support or similar purposes,
  • to provide notice of your purchase to the provider of an online service for which you purchase a service use right from us,
  • to establish an account for future purchases that you have consented to,
  • to facilitate the renewal of subscriptions for products or services, and
  • to provide you with an effective experience and support (which may, as allowable by law, include contacting visitors who start a checkout process to follow-up on the incomplete session or to see if there was a problem with their use of the Website).

We will take reasonable steps to ensure any person or entity receiving Personal Information for the purposes described above, are obligated to keep the Personal Information secure. Our obligations will not apply to information shared with any Government entity mandated under law to obtain such information or by an order under law for the time being in force.

Our Use of Anonymous Information

We may use Anonymous Information collected by us. In this case, the following data elements will be anonymized such as first and last name, street address, phone number, email address and other data elements in accordance with applicable law. The Anonymous Information may be used as described here:

  • to personalize and support your use of this Website and/or the services of our Partners,
  • to improve this Website, the customer experience, our advertising systems, and our products and services,
  • for fraud prevention purposes, such as device fingerprinting,
  • to identify transactions as originating through an affiliate marketing or referral program,
  • to deliver targeted advertisements on this Website and other commerce solutions,
  • to provide reporting to our current and prospective Partners and service providers, and
  • for other historical, statistical, research and analysis purposes.

We may also use de-identified data for the purposes mentioned above, and related purposes as allowed by applicable law.

Our Partners

We will provide certain Personal Information, Anonymous Information or De-identified Data to our Partners to fulfill our obligations to you, and otherwise assist CTL's use of Personal Information as described in the "How We Use Your Data" section:

  • for reporting purposes,
  • to allow our Partner or its service provider to register your purchase,
  • to enable your access to products or services provided by our Partner or its suppliers,
  • to facilitate warranty, technical support or after-sales service,
  • to allow our Partner or subcontractor to send email or direct mail communications if you have consented to receive them,
  • to allow our Partner or its service provider to provide services in connection with this Website (such as customer support or single sign-on functionality), or
  • for similar purposes in order to fulfill obligations to you.

Our Service Providers

We utilize other companies, including our corporate affiliates, to provide certain services to us or on our behalf to help us operate our business such as:

  • to host or maintain this Website,
  • to process credit card payments,
  • to provide fraud monitoring or detection services,
  • to perform data integrity checks,
  • to offer you a line of credit,
  • to provide optimization services,
  • to fulfill your order,
  • for payment collection,
  • to deliver advertisements on this Website and third party websites,
  • to send mail or e-mail,
  • for purposes related to employment and human resources, and/or
  • to provide customer service.

We will not share your Personal Information with our service providers in connection with their offering of services to us, unless it is required for the purposes of our Legitimate Interests and purposes of fulfilling our obligations as to delivery of our commerce solution to you. These service providers may be contractually required to use any information we share with them only to perform services to us or on our behalf and to protect the confidentiality of your Personal Information. We may also allow these companies to use Anonymous Information for their business purposes. We will not share your Personal Information with our affiliates or unrelated third parties to use for their own marketing purposes without your consent.

To Comply With Legal Requirements, Prevent Fraud and Crimes

As permitted by applicable law, we may disclose Personal Information about you when we believe disclosure is appropriate to:

  • comply with the law or a regulatory requirement,
  • to comply with governmental, administrative or judicial process, requirement or order (such as a court order),
  • to cooperate with law enforcement or other governmental investigations or report any activities that may be in violation of legal or regulatory requirements,
  • to prevent or investigate a possible crime (such as fraud or identity theft) or breaches (also suspected breaches) of security or of this Privacy Policy,
  • to enforce a contract,
  • to protect the legal rights, Website or safety of CTL and our employees, Partners, third parties, the public in general or you.

In Connection with a Sale, Merger or related Event

If one of our corporate affiliates or a third party has acquired our business, specific assets or the business of one of our operating divisions (such as part of a sale, merger, reorganization, or similar event), your Personal Information will become owned by that company, unless otherwise provided for by the local legislation. In that event, the acquiring company's use of your Personal Information will be subject to the governing Privacy Policy, any applicable supplemental privacy notices, and the privacy preferences you have expressed to the governing entity.

Your Choices

We respect your right to make choices about the ways we collect, use and share your Personal Information.

Sharing Personal Information

CTL may disclose your personal information to a third party for a business purpose. CTL will not sell your personal information as such term is defined under the CCPA. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except in performance of our contractual commitments.

We share your personal information for a business purpose with the following categories of third parties: service providers and data aggregators.

Disclosure of Personal Information for a Business Purpose

In the preceding twelve (12) months, CTL has disclosed the following categories of personal information for a business purpose: Identifiers; Internet or other similar network activity; Geolocation data; Professional or employment-related information;

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

No Sale of Personal Information

In the preceding twelve (12) months, CTL has not sold your Personal Information and we do not sell your Personal Information today.

Access to Your Information and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the last twelve (12) months. Once we receive a verifiable request, we will disclose the following information to you:

  • The categories of personal information we collected about you,
  • The categories of sources for the personal information we collected about you,
  • Our business or commercial purpose for collecting that personal information,
  • The categories of third parties with whom we share that personal information,
  • The specific pieces of personal information we collected about you (also called a data portability request),
  • Where there has been a disclosure for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

If you would like to request erasure of your Personal Information, please send us a request using the information in the "How to Contact Us" section of this Privacy Policy.

If you contact us we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements as noted in our data retention policy. When we delete your Personal Information, it will be disposed of in a manner that prevents loss, theft, misuse, or unauthorized access in-line with our data retention policy.

Please contact us directly as we are committed to working with you to help resolve any concerns about your privacy.

Data Retention Policy

CTL may retain your Personal Information for as long as you continue to use our Website, and thereafter as permitted or required by applicable law or to satisfy our business requirements.

Exercising Your Rights and Response

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: calling us at 1-800-642-3087 or emailing We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to [45/90] days), we will inform you of the reason and extension period in writing. We will deliver our response to the email we have on file.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. 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 usable.

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.

Marketing and Related-Communications

When you provide Personal Information, we may offer you a choice as to whether you would like to receive further marketing and related communications from us or our Partners. These communications could be in the form of direct mail, email or telephone and will contain information to inform you of our products and services. You may opt-out of receiving these communications by e-mailing us at, or by following any unsubscribe instructions in e-mail communications.

If you give us consent to add your contact information to our Partner's mailing list and later withdraw this permission, you must contact our Partner (or follow the unsubscribe instructions in the e-mails from our Partner) to have your name removed from our Partner's mailing lists.

Children's Privacy

This Website is not directed at nor targeted to children. If you have not reached the age of majority or are not able to enter into legally binding agreements in your country, you may not use this Website unless necessary parental consent has been obtained. If you believe that we have received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify us immediately, and we will take reasonable steps to securely remove that information.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section §1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to