Great Northern Corporation Privacy Policy for California Residents

This Privacy Policy for California Residents (the “Policy”) supplements the information contained in Great Northern Corporation’s General Website Privacy Policy and applies only to visitors, users, and others who reside in the State of California (“consumers”, “you” and/or “your”). In the event of any conflict between this Policy and the General Privacy Policy, this Policy will control with respect to California consumers. Great Northern Corporation (“GNC”, the “Company” or “we”) has adopted the Policy to comply with the California Consumer Privacy Act of 2018 (the “CCPA”), and any terms defined in the CCPA have the same meaning when used in the Policy.

The CCPA provides consumers with several rights, including the following: the right to know what Personal Information is collected about you; the right to know how your Personal Information may be used; the right to know to whom/which your Personal Information is disclosed; the rights to request access to and/or deletion of your Personal Information; and the right to request that your Personal Information not be sold under certain circumstances.

Information GNC Collects

GNC collects 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, household, or device (“Personal Information“). Personal Information does not include:

Publicly available information from government records; and
Deidentified or aggregated consumer information.

In particular, GNC has collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category	Examples	Collected
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).	Yes
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.	Yes
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.	Yes
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
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.	Yes
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

GNC obtains the categories of Personal Information positively identified above from the following categories of sources:

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

Use of Personal Information

GNC may use or disclose the Personal Information it collects 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 GNC’s 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/service orders or process returns.
To provide, support, personalize, and develop GNC’s website, products, and services.
To create, maintain, customize, and secure your account with the Company.
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 the Company’s 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 GNC’s website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve GNC’s website, products and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
(For employees) For employment-related purposes, including to administer benefits, facilitate compensation, etc.
As otherwise 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 the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by GNC about its 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.

Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for a business-related purpose and/or as requested by governmental authorities. We only make these disclosures where required by applicable law and/or 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, GNC has disclosed Personal Information to the categories of third parties positively identified in the chart below.

The Company does not sell Personal Information. In the preceding twelve (12) months, the Company has not sold any categories of Personal Information. For more on your personal information sale rights, see the Personal Information Sales Opt-Out and Opt-In Rights section, below.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A: Identifiers.	Service Providers (such as payment processors and (for employees) benefits administrators); Professional Advisors (such as attorneys and/or accountants); Governmental Entities	None
B: California Customer Records personal information categories.	Service Providers; Professional Advisors; Governmental Entities	None
C: Protected classification characteristics under California or federal law.	Service Providers; Professional Advisors; Governmental Entities	None
D: Commercial information.	Professional Advisors	None
E: Biometric information.	Service Providers	None
F: Internet or other similar network activity.	Service Providers	None
G: Geolocation data.	Service Providers	None
H: Sensory data.	None	None
I: Professional or employment-related information.	Service Providers; Professional Advisors; Governmental Entities	None
J: Non-public education information.	None	None
K: Inferences drawn from other personal information.	None	None

Your Rights and Choices

The CCPA provides consumers 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 GNC’s 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 the section on Exercising Your Rights to Know or Delete, below), the Company 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.
The Company’s business or commercial purpose(s) for collecting that Personal Information.
The categories of third parties with whom/which 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).

Right to Delete

You have the right to request that we delete any of your Personal Information that we have 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 section, below), we will review your request to see if an exception allows the Company to retain the information. We may deny your deletion request if retaining the information is necessary for GNC or its 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 the Company’s ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with applicable law, or otherwise perform the Company’s 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 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 the Company.
Comply with one or more legal obligations.
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 or more of these exceptions from GNC’s records and will direct the Company’s service providers to take similar action.

Exercising Your Rights to Know or Delete

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

Calling the Company at 1-800-236-3671.
Emailing the Company at hr@greatnortherncorp.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete concerning your Personal Information.

You may also make a request to know or delete on behalf of your child by submitting a request by one of the avenues identified above.

You may submit a request to know only twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows the Company to reasonably verify you are the person about whom we collected the Personal Information you seek or an authorized representative thereof, which may include:
- The last four digits of your social security number, or
- Other verification information.
Describe your request with sufficient detail that allows the Company 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.

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

We will use Personal Information provided in the request only to verify the requestor’s identity or authority to make it.

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

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 hr@greatnortherncorp.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 forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver GNC’s 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 cover only the 12-month period immediately preceding the Company’s 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 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.

You do not need to create an account with GNC 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.

CCPA Rights Request Metrics

Metrics regarding the consumer rights requests we received from California residents from January 1, 2022, to December 31, 2022, appear in the following chart:

Request Type	Received	Granted (in whole or in part)	Denied	Median/Mean Days to Respond
Requests to Know	None	None	None	N/A
Requests to Delete	None	None	None	N/A
Requests to Opt-Out of Personal Information Sales	None	None	None	N/A

Changes to Our Privacy Policy

We reserve the right to amend the Policy at our discretion and at any time. When we make changes to the Policy, we will post the updated notice on the Company’s website and update the notice’s effective date. Your continued use of the Company’s website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Policy, the ways in which GNC collects and uses your information described here and/or in the Company’s General 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: 1-800-236-3671

Website: https://greatnortherncorp.com

Email: hr@greatnortherncorp.com

Postal Address:

Great Northern Corporation

395 Stroebe Road

P.O. Box 939

Appleton, WI 54914

If you need to access this Policy in an alternative format due to having a disability, please contact hr@greatnortherncorp.com.

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