clé tile privacy policy for california residents

Effective date: December 1, 2025

Last updated on: December 1, 2025

This privacy policy for California residents supplements the information contained in clé tile’s general privacy policy and applies solely to all visitors, users, and others who reside in the state of California (”consumers” or “you”). We adopt this notice to comply with the California consumer privacy act of 2018 (CCPA), as amended by the California privacy rights act (CPRA), and other relevant rules and regulations, including terms defined in the CCPA have the same meaning when used in this policy.

This policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see california employee privacy policy).

Where noted in this policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“b2b personal information”) from some of its requirements.

Information we collect

Your privacy and how businesses use it has become complicated and replete with rules and choices. If you are a California resident, your state has a lot of protections for your information and therefore a lot of choices for you to make regarding how your information is used, protected and stored. In this privacy notice for California residents we will try to explain the classifications of your information, which of these classes we use and why, and your rights and control over these classes of your information. We update this policy from time to time to try to keep up with these constantly changing laws, so please check this policy regularly for updates. Below you will find short definitions of types of categories that we will use to reference throughout this policy. We collect publicly available information from government records. When we refer to “shared” information below, shared refers to sharing for cross-context behavioral advertising as defined by California law.

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information”). Personal information does not include deidentified or aggregated consumer information.

We retain each category of personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, as required by law, or as otherwise disclosed in this policy. When we cannot provide a specific retention period for a category, we describe the criteria used to determine that period.

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

category

Examples

collected

shared

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.

yes

___

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.

yes

__

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).

no

__

d. commercial information.

records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

yes

__

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.

no

__

f. internet or other similar network activity.

browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

yes

__

g. geolocation data.

physical location or movements.

yes

__

h. sensory data.

audio, electronic, visual, thermal, olfactory, or similar information.

no

__

i. professional or employment-related information.

current or past job history or performance evaluations.

no

__

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.

no

__

k. inferences drawn from other personal information.

profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

yes

__

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

        Directly from you. For example, from forms you complete or products and services you purchase.

        Indirectly from you. For example, from observing your actions on our website.

We retain Personal Information for as long as needed to carry out the purposes described in this Policy, unless a longer period is required or permitted by law. Retention periods are determined based on legal requirements, business needs, and the type of information involved.

Sensitive personal information categories chart

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. We may collect sensitive personal information as defined by California law. The right to limit our use of sensitive personal information applies when we use or disclose this information to infer characteristics about a consumer. We do not use or disclose sensitive personal information for purposes other than those permitted by California law to provide our services, unless you instruct us to do so.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last twelve (12) months.

Sensitive personal information category

Collected to infer characteristics?

1. government identifiers, such as your social security number (ssn), driver's license, state identification card, or passport number.

YES

2. complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.

YES

3. precise geolocation, such as physical store visits or physical locations when visiting websites or using mobile apps.

YES

4. racial or ethnic origin.

NO

5. citizenship or immigration status.

NO

6. religious or philosophical beliefs.

NO

7. union membership.

NO

8. mail, email, or text messages not directed to us.

NO

9. genetic data.

NO

10. neural data, such as information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information.

NO

11. unique identifying biometric information.

NO

12. health information.

NO

13. sex life or sexual orientation information.

NO

We retain Personal Information for as long as needed to carry out the purposes described in this Policy, unless a longer period is required or permitted by law. Retention periods are determined based on legal requirements, business needs, and the type of information involved.

Use of personal information

We may use or disclose the personal information we collect 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, 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.

        To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

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.

Use of sensitive personal information

We may use or disclose sensitive personal information we collect for one or more of the following purposes:

        Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect when we process sensitive personal information.

        Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted sensitive personal information.

        Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at us.

        Ensuring physical safety.

        Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:

        disclose the sensitive personal information to another third party; or

        use it to build a profile about you or otherwise alter your experience outside your current interaction with us.

        Services performed for us, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for us.

        Activities required to:

        verify or maintain the quality or safety of a product, service, or device that we own, manufacture, have manufactured, or control; or

        improve, upgrade, or enhance the service or device that we own, manufacture, have manufactured, or controlled.

        Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

Disclosing, selling, limiting or sharing personal information

We may disclose your personal information by disclosing it to a third party for a business purpose. 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, the company has disclosed personal information for a business purpose to the categories of third parties as explained in the charts in this document and other places in more detail.

We do not sell personal information for monetary consideration. We may share personal information for cross context behavioral advertising as defined by California law. We discuss this sharing information in more detail in this document and explain what we may share, the reasons we may share it, and your control over us sharing your information. For more on your personal information sale rights, see personal information sales opt-out and opt-in rights. We may share your personal information with third parties for cross-context behavioral advertising purposes and have shared your personal information in the preceding 12 months. The chart above will identify the categories of third parties to whom we may share personal information for cross-context behavioral advertising purposes.

We may also disclose certain of your personal information with our affiliates for business purposes. Our affiliates act under the umbrella company of tilevera, llc, and include clé tile and outdoor. When our affiliates process personal information on our behalf and pursuant to written agreements that limit their use of the information to legitimate business purposes, those disclosures do not constitute selling or sharing under California law. If an affiliate engages in cross-context behavioral advertising, you have the right to opt out of that sharing under California law.

Your rights and choices

The CCPA 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 over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see exercising your rights to know or delete), we will disclose 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, selling, or sharing 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.

        the specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for b2b personal information.

Right to opt out of sale or sharing

You have the right to opt out of the sale or sharing of your information.

Right to limit use of sensitive personal information

You have the right to limit our use and disclosure of your sensitive personal information. You can do this by writing to us at the email address provided in this notice, by contacting us by mail at our address, or calling us. You may also select the do not share my information with the cookie and share information banner that pops up on our website and this link: do not sell my personal information. You should know that you can change your choice of cookie permission or sharing information at any time by contacting us.

Right to delete and right to correct

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 your request and confirm your identity (see exercising your rights to know or delete), we will review your request to see if an exception allowing us to retain the information applies.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors and other recipients to take appropriate action.

You also have the right to direct us to stop sharing your personal information for cross context behavioral advertising.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

        complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

        detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

        debug products to identify and repair errors that impair existing intended functionality.

        exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

        comply with the california electronic communications privacy act (cal. penal code § 1546 et. seq.).

        engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

        enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

        comply with a legal obligation.

        make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for b2b personal information.

To exercise your rights to know or delete described above, please submit a request by either:

Exercising your rights to know, correct, limit, or delete

        calling us at: (415) 887-9011

        emailing us at: contact@cletile.com

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

You may also make a request to know or delete on behalf of your child by contacting us at the telephone number or e-mail address above.

You may only submit a request to know, correct, limit, or delete twice within a 12-month period. your request to know or delete must:

        provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include reasonable verification requests.

        describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, correct, limit, or delete your personal information.

In response to your request to limit or opt-out, we will process this request, as soon as feasibly possible, but no later than fifteen (15) business days from the date we receive this request. you do not need to create an account with us to submit a request to know or delete.

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, limiting, or opt-in rights, see personal information sales opt-out and opt-in rights. Once you make a request to [limit] [or] [opt-out], we will wait at least 12 months before asking you to reauthorize [the use or disclosure of your sensitive personal information for purposes other than the Permitted SPI Purposes] [or] [personal information sales or sharing].

Response timing and format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us by email at contact@cletile.com

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will 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 usable 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 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.

Personal information sales, sharing and opt-out and opt-in rights

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

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following internet web page link:

Do not sell my personal information

You may exercise your right to opt out of the sale or sharing of your personal information by clicking the “your privacy choices” or “do not sell or share my personal information” link at the bottom of our website. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at contact@cletile.com

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.

Non-discrimination

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.

How we protect your data

We discussed protecting your data in our privacy policy but want to state it here too in order to remind you the safety of your data also depends on you. We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. This includes encryption, access controls and sometimes secure transmission for sensitive and financial information. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, though, using, or in connection with our services. In particular, e-mail, texts, and chats sent to or from our services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk. Again, the safety and security of your information also depend on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

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 contact@cletile.com or write us at: 2143 francisco blvd e, san rafael, ca 94901.

Changes to our privacy policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, 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 information
If you have any questions or comments about this notice, the ways in which clé tile collects and uses your information described here and in the privacy policy, 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: (415) 887-9011

Email: contact@cletile.com

Postal address:

Tilevera llc dba clé tile

Attn:  privacy department

2143 francisco blvd e, san rafael, ca 94901. If you need to access this policy in an alternative format due to having a disability, please contact contact@cletile.com and (415) 887-9011.