Privacy Policy for California Residents

Effective Date: May 2023

This Privacy Policy for California Residents (“California Privacy Policy”), as provided by Group USA Inc. (“Company,” “we,” or “us”), supplements the information contained in our Privacy Policy and applies only to all visitors, users, and others who reside in the State of California (“consumers” or “you”), including when consumers visit our websites (collectively, our “Website”).   Please refer to the Privacy Policy (non-California) appearing on the Website (linked above) for additional information relating to our processing of your personal information.

This California Privacy Policy is to inform consumers about our online and offline information practices, including comprehensive information about consumer rights under California’s privacy laws noted below, and how consumers can exercise those rights

We adopt this California Privacy Policy in compliance with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), and implementing regulations. Any terms defined in the CCPA or CPRA have the same meaning when used in this California Privacy Policy.

This California Privacy Policy does not apply to workforce-related personal information collected from the Company’s California-based employees, job applicants, contractors, or similar individuals (“Workforce Members”). If you are a Workforce Member employed by the Company, please see our California Privacy Policy for California Workforce Members.

Changes to Our Privacy Policy

We review and update this California Privacy Policy at least every 12 months. However, we reserve the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post the updated notice on our Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Children's Privacy

Our Website is not intended for anyone under 16 years of age (the “Minimum Age”). Our Website and the services, content, information and products provided or made available on and/or through our Website may not be accessed or used by any individuals who are not at least the Minimum Age.  No one under the Minimum Age may provide any information to our Website.  We do not knowingly collect, sell, or share personal information from anyone under the Minimum Age. 

If you are under the Minimum Age, except with your parent or legal guardian, you are strictly prohibited from the following:

  • using or providing any information to our Website
  • registering for an account with our Website
  • making any purchases through our Website
  • providing any information about you to us, including but not limited to your
    • name
    • billing address
    • shipping address 
    • telephone number
    • email address
    • payment card information
    • username

If we need to rely on consent as a legal basis for processing your information, we may require your parent's consent before we collect and use that information.

If we learn we have collected or received personal information from a person under the Minimum Age without verification of parental consent, we will delete such personal information. If you believe we might have any personal information from or about anyone under the Minimum Age without parental consent, please contact us through the contact information below.  

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, and/or could reasonably be linked, directly or indirectly, with a particular consumer and his/her/its/their 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 of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA),
    • clinical trial data, or
    • other qualifying research data; and
    • personal information covered by certain sector-specific privacy laws, including
    • the Fair Credit Reporting Act (FCRA),
    • the Gramm-Leach-Bliley Act (GLBA),
    • the California Financial Information Privacy Act (FIPA), and
    • the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal Information

Category Examples Collected/Shared/Sold
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. Collected
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.
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). N/A
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected
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. N/A
F. Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Collected
G. Geolocation data. Physical location or movements.  N/A
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. N/A
I. Professional or employment-related information. Current or past job history or performance evaluations. N/A
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.  N/A
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. N/A


Sensitive Personal Information

Sensitive personal information is a subtype of personal information consisting of specific information categories. 

Sensitive Personal Information Category Examples Collected/Shared/Sold
Government identifiers. Social Security number, driver's license, state identification card, and passport and visa information, and immigration status and documentation. N/A
Complete account access credentials. 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 Collected 
Precise geolocation Consumer’s location of receipt of a delivery of a purchased product  N/A
Racial or ethnic origin. Religious or philosophical beliefs, or union membership N/A
Communications. Contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication N/A
Genetic data. Information pertains to a consumer’s genes.  N/A
Unique identifying biometric information. Physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity N/A
Health information N/A
Sex life or sexual orientation information. N/A



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

  • Directly from you. For example, this includes information you provide when
    • you complete or products and services you purchase from our Website
    • you create an account with us
  • Indirectly from you. For example, this includes information we collect
    • from observing your actions on our Website

Use of Personal Information

We may use, disclose, or provide our service providers and contractors your personal information we collect to for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal 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 product orders or process returns.
  • To provide or meet the reason you provided the information;
  • To provide, support, personalize, and develop our Website, products, and services;
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • 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.

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

Sharing Personal Information

We may disclose your personal information for a business purpose with our service providers and contractors. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed the following personal information for a business purposes:

Personal Information Category  Category of Third-Party Recipients
Business Purpose Disclosures Shared/Sold
A: Identifiers.

Performing services for the business, such as

  • maintaining or servicing accounts,
  • providing customer service, 
  • processing or fulfilling orders and transactions,
  • verifying customer information,
  • processing payments,
  • providing analytic services, or 
  • providing other similar services.
B: California Customer Records personal information categories.

Performing services for the business, such as

  • maintaining or servicing accounts,
  • providing customer service, 
  • processing or fulfilling orders and transactions,
  • verifying customer information,
  • processing payments,
  • providing analytic services, or 
  • providing other similar services.
C: Protected classification characteristics under California or federal law.


D: Commercial information.

Performing services for the business, such as

  • maintaining or servicing accounts,
  • providing customer service, 
  • processing or fulfilling orders and transactions,
  • verifying customer information,
  • processing payments,
  • providing analytic services, or 

providing other similar services.

E: Biometric information.


F: Internet or other similar network activity.

Performing services for the business, such as

  • maintaining or servicing accounts,
  • providing customer service, 
  • processing or fulfilling orders and transactions,
  • verifying customer information,
  • processing payments,
  • providing analytic services, or 
  • providing other similar services.

Auditing related to:

  • counting ad impressions to unique visitors,
  • verifying positioning and quality of ad impressions, and
  • compliance with the CCPA and other standards.

Providing advertising and marketing services to the consumer (excluding cross-context behavioral advertising), if the service provider or contractor does not combine personal information from the business's opted-out consumers with personal information received from, or on behalf of, another person or persons or that it collected independently.

Undertaking internal research for technological development and demonstration.

Verifying or maintaining quality or safety or improving or upgrading a service or device owned, manufactured, or controlled by or for the business.

G: Geolocation data.


H: Sensory data.


I: Professional or employment-related information. N/A N/A
J: Non-public education information. N/A N/A
K: Inferences drawn from other personal information. N/A N/A


Your Rights and Choices

The CCPA, as amended by the CPRA, provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know 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 (the “right to know”). Once we receive your request and confirm your identity (a “verifiable request”), we may disclose to you certain information, including but not limited to the following:

  • 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 or selling that personal information;
  • the categories of third parties with whom we share that personal information;
  • if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased, and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained; and
  • the specific pieces of personal information we collected about you (also called a data portability request).

We may deliver the requestor's personal information:

  • to password-protected account holders using a secure self-service portal; or
  • at your option:
    • by mail, or
    • electronically.
  • Please note that you are only permitted a maximum of two requests in a 12-month period. We may also limit the scope of personal information collected and maintained about you on or after January 1, 2022. We may also refrain providing more than the past 12-months of data. We are not required to retain personal information that we would not normally retain.
  • Upon a verifiable request, we will transfer that information to another entity directly.
  • Before responding to a verifiable request, we may be required by law and regulations to remove certain sensitive information from collected personal information, including:
  • social Security numbers (SSNs), driver's license numbers, or other government-issued identification numbers;
  • financial account numbers;
  • health insurance or medical identification numbers;
  • account passwords or security questions and answers; and
  • unique biometric data generated from measurements or technical analysis of human characteristics.

Right to Delete 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive a verifiable request (see Exercising Your Rights to Know or Delete), we will review your verifiable request to see if an exception allowing us to retain the information applies. 

NOTE that your right to delete is not an absolute right and we may deny deletion requests when we need to retain personal information for certain statutory business reasons.

In particular, we may deny your deletion request (even in part) if retaining any of the information is necessary for us or our service provider(s) to perform the following: 

  • To complete the transaction for which the personal information was collected;
  • To fulfill the terms of a written warranty or product recall conducted in accordance with federal law;
  • To provide a good or service requested by a consumer, or reasonably anticipated by the consumer within the context of a business' ongoing business relationship with the consumer;
  • To otherwise perform a contract between a consumer and us;
  • To help to ensure security and integrity to the extent the use of a consumer's personal information is reasonably necessary and proportionate for those purposes;
  • To debug to identify and repair errors that impair existing intended functionality;
  • To exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided for by law;
  • To comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
  • To engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if a consumer has provided informed consent;
  • ⦁ To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on a consumer's relationship with us and compatible with the context in which the consumer provided the information;
  • To respond to or to contest disputes asserted by or against you; and
  • To comply with a legal obligation.

If we deny your verifiable request, we will notify you of the following:

  • the basis for the denial, including any conflict with federal or state law, or exception to the CCPA, unless prohibited from doing so by law;
  • an explanation that we will delete your personal information is not subject to one of the above exceptions; and
  • confirmation that we will not use your personal information retained for any other purpose than provided for by that exception(s).

If we approve your verifiable request, we will notify you of the following:

  • confirmation of the permanent deletion or deidentification of your personal information not subject to one of the above exceptions from our records;
  • an explanation that we will maintain a record of your deletion request for at least 24 months or as otherwise needed to ensure that your personal information remains deleted from our business records; and
  • notification to our service providers or contractors to delete your personal information from their records and all third parties to whom it has sold or shared your personal information to delete that information, unless the notification proves impossible or involves disproportionate effort.

Alternatively, in responding to a request to delete, we may present you with the choice to delete select portions of your personal information.

Right to Correct

You have the right to request that we correct inaccurate personal information, accounting for the nature of the personal information and the purposes of the processing of the personal information, subject to certain limitations (the “right to correct”).

NOTE that your right to delete is not an absolute right and we must take the personal information's processing purposes and general nature into account.

However, we will use commercially reasonable efforts to correct the inaccurate personal information upon a verifiable request.

Right to Restrict Sensitive Personal Information Processing

You have the right to restrict how we use and disclose sensitive personal information that we collect or process with the purpose of inferring characteristics about you, subject to certain limitations.

Exercising Your Rights

To exercise your rights described above, please submit a request by either:

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information.

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 the personal information relates to you. 

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it. 

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days, generally describing our verification process and providing an expected response timeframe, unless we’ve already granted or denied the request. If you do not receive confirmation within the 10-business day timeframe, please contact us.

We endeavor to substantively respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we first inform you of the reason and extension period in writing.

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 your request. 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable 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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may contact us or submit a request form by visiting

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. 

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.


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.

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 or write us at: Camille La Vie, 61 West Palisade Avenue, Englewood, NJ 0763.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your information described here, 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: 862-895-5089



Postal Address: 

Camille La Vie
61 West Palisade Avenue
Englewood, NJ 0763

If you need to access this California Privacy Policy in an alternative format due to having a disability, please contact and 862-895-5089.