Notice at Collection and Privacy Policy for California Residents

Effective Date: December 30, 2022
Last Revised/Reviewed on: February 6, 2023

This California Notice at Collection and Privacy Policy ("CCPA Disclosure") explains how WRJ Holdings, LLC, d/b/a Classic Firearms and its subsidiaries and affiliates ("Classic Firearms", "Company", "us", "our", or "we") collect, use, disclose, sell, share, and/or retain personal information ("Information Practices") subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"). This CCPA Disclosure applies solely to California residents ("consumers" or "you").

NOTICE AT COLLECTION

The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared.

General Personal Information

We do not collect: biometric information, professional or employment related information, or education information.

Sensitive Personal Information

We do not collect: precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer's mail, email, and text messages (unless we are the intended recipient of the communication); genetic data; biometric information for the purpose of unique identification; health information; or information concerning sex life or sexual orientation.

Retention Periods

We retain information for different periods of time depending on the purposes for which we collect and use it. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above, unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

Notice of Sale and/or Share

Our use of tracking technologies may be considered a sale or sharing with third parties for cross-context behavioral advertising (e.g., targeted advertising) under California law. You can opt-out of being tracked by these third parties by clicking the "Do Not Sell or Share My Personal Info" link and selecting your preferences.

Please review our California Privacy Policy below.

PRIVACY POLICY

The purpose of this privacy policy is to provide you with a comprehensive description of our online and offline practices regarding our Information Practices. You have certain rights to control the use of your personal information. This privacy policy describes your rights as it relates to our Information Practices as to your personal information and how you can exercise those rights.

The following table includes disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.

General Personal Information

Category	In the preceding 12 months this category was:		Business or Commercial Purpose for Collection & Disclosure	Categories of third parties to whom the information was disclosed
	Collected	Disclosed
Identifiers			For our operational purposes or the operational purposes of our service provider or contractors. Keeping track of visitors to our website and monitoring the effectiveness of our advertising, including auditing relating to counting ad impressions of unique visitors, verifying positioning and quality, and auditing compliance. Ensuring security and integrity as needed and as reasonably necessary and proportionate for this purpose. Debugging to identify and repair errors that impair existing functionality. Short-term, transient use. Performing services on behalf of the business, including maintaining or servicing accounts, providing products or services, providing customer service, processing orders or transactions, verifying customer information, processing payments, providing financing, providing analytic services, storage, or other similar services. To facilitate contests, sweepstakes, and giveaways. Providing advertising and marketing services, except for cross-context behavioral advertising. Undertaking internal research for technological development. Undertaking activities to verify or maintain quality or safety of a service or device and to improve or enhance a service or device.	Managed service provider for back office functionality Payment processors Web analytics providers Web hosting service providers E-mail and SMS text distribution service providers Contest and sweepstakes promotion service providers Call center and help desk service providers Financial and accounting service providers Cybersecurity and fraud detection service providers Review platform providers Government entities Data brokers
Personal Information Categories from Cal. Civ. Code § 1798.80(e)
Characteristics of California or Federal protected Classifications				E-mail and SMS text distribution service providers
Commercial Information				Managed service provider for back office functionality Payment processors Web analytics providers Web hosting service providers E-mail and SMS text distribution service providers Contest and sweepstakes promotion service providers Call center and help desk service providers Financial and accounting service providers Cybersecurity and fraud detection service providers Review platform providers
Internet or Other Similar Network Activity				Managed service provider for back office functionality Payment processors Web analytics providers Web hosting service providers E-mail and SMS text distribution service providers Contest and sweepstakes promotion service providers Call center and help desk service providers Financial and accounting service providers Cybersecurity and fraud detection service providers Review platform providers Data brokers
Geolocation Data
Sensory or Surveillance Data				Managed service provider for back office functionality Web hosting service providers
Profile Data				Managed service provider for back office functionality Web hosting service providers E-mail and SMS text distribution service providers

We do not collect: biometric information, professional or employment related information, or education information under this policy.

Sensitive Personal Information

We do not use or disclose the below sensitive personal information for purposes other than those business purposes specifically enumerated under CCPA. As a result, we do not offer a right to limit our use or disclosure of these categories of sensitive personal information.

Category	In the preceding 12 months this category was:		Business or Commercial Purpose for Collection & Disclosure	Categories of third parties to whom the information was disclosed
	Collected	Disclosed
Social Security Number			To perform services or provide goods you request and reasonably expect from us. We only collect and use Social Security Numbers ("SSN") if a contestant wins a contest, sweepstakes, or giveaway, and we only disclose SSN for tax compliance purposes.	Government entities for legal compliance Financial and accounting service providers
Account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account			To perform services or provide goods you request and reasonably expect from us. To detect, prevent, and investigate security incidents involving your information. To investigate or curtail malicious, fraudulent, or illegal actions directed at us and to prosecute those responsible. To enhance your experience on our website in real time, so long as we do not disclose your information to a third party. To perform services for our business needs such as maintaining accounts, providing customer service, providing financing, verifying customer information, processing payments, providing analytics services, storage, and to fulfill orders. To ensure the quality or safety of a product, service, or device.	Managed service providers for back office functionality Payment processors

We do not collect: precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer's mail, email, and text messages (unless we are the intended recipient of the communication); genetic data; biometric information for the purpose of unique identification; health information; information concerning sex life or sexual orientation.

The categories identified as collected in the tables above were collected from the following categories of sources:

• You directly
• Fraud monitoring services
• Marketing partners
• Licensing entities
• Data brokers
• Data analytics providers
• Operating systems and platforms
• Social networks

What We Sell to Third Parties or Share with Third Parties for Cross-Context Behavioral Advertising and Right to Opt-Out

We have sold or shared with third parties for cross-context behavioral advertising personal information to third parties in the preceding 12 months as disclosed in the table below. We do not sell or share your sensitive personal information.

General Personal Information

We do not sell or share: personal information categories from cal. Civ. Code § 1798.80(e), characteristics of California or Federal Protected Classification, commercial information, sensory or surveillance data, professional or employment related information, education information, or profile data.

The purpose of the notice of Right to Opt-Out is to inform you that you have the right to direct us to stop selling or sharing your personal information, which is called the "Right to Opt-Out." 

You may exercise your Right to Opt-Out by: (1) clicking "Do Not Sell or Share My Personal Info" to use the interactive form, or (2) submitting your request through an opt-out preference signal (described further below in the section titled "Opt-Out Preference Signals").

Once you make an opt-out request, we will comply within 15 business days.

We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

Your Right to Know

You have the right to request that we disclose any of the following:

• the categories of personal information we have collected about you
• the categories of sources from which the personal information is collected
• the business or commercial purpose for collecting, selling, or sharing with third parties for cross context behavioral advertising (e.g. targeted advertising)
• the categories of third parties to whom we disclose personal information
• the specific pieces of personal information we have collected about you

You can do this through a verified consumer request. That process is described below in the section, "Submitting a Verified Consumer Request."

Your Right to Request Correction of Inaccurate Personal Information

You have the right to request correction of inaccurate personal information maintained by us. We may request documentation from you to determine the accuracy of the information. If you provide us documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your personal information and complying with our recordkeeping requirements. We may deny your request if we have previously denied your same request to correct an alleged inaccuracy in the past six (6) months, unless you provide new or additional documentation that the information at issue is inaccurate.

As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, "Submitting a Verified Consumer Request."

Your Right to Request Deletion of Your Personal Information

You have the right to request that we delete any of your personal information collected by us, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, "Submitting a Verified Consumer Request."

There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your personal information.

Submitting a Verified Consumer Request

You have the right to submit verified consumer requests to know information, to correct information, or for deletion.

The response to a request to know will provide all personal information collected and maintained about you since January 1, 2022, unless doing so proves impossible or would involve disproportionate effort.  Please note that we are not required to provide personal information to you more than twice in a 12-month period.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

A form is available at https://classicfirearms.com/privacy-form/ to request your personal information or request to delete your personal information. You can also place a request by calling (855) 831-3337. If you call that toll-free number, you will be asked to provide the same information requested on the webform for verification purposes. Your request either through the webform or over the phone will be verified using information you provide as described on the webform.

If you submit a request that is not through one of the above designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies with your request.

Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.

Using an Authorized Agent to Submit a Request

Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information, to opt-out of sale or sharing, or to limit the use or disclosure of your sensitive personal information. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section "Submitting a Verified Consumer Request," and directly confirm with us that you provide the authorized agent permission to submit the request by emailing us at privacy@classicfirearms.com.

Opt-Out Preference Signals

Our use of tracking technologies may be considered a sale/sharing under California law. You can opt-out of being tracked by these third parties by clicking the "Do Not Sell of Share My Personal Info" link at the bottom of our website and selecting your preferences, or by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. Because the signal is browser-specific, you will need to broadcast subsequent signals if you are accessing our website through different online devices (e.g., computers, smartphones, tablets).

Your Right to Non-Discrimination for the Exercise of a Privacy Right

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 still offer you certain financial incentives permitted by the CCPA such as discounts, rewards, premium features, loyalty accounts, or club card programs that can result in different prices, rates, or quality levels.

Notice of Financial Incentive

The purpose of this notice of financial incentive is to explain to you the material terms of a financial incentive we are offering so that you may make an informed decision on whether to participate.

 We currently provide the following financial incentives:

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the 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.

Contact for More Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: