California and Oregon Consumer Privacy Notice

Last Updated: August 30th, 2024

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA), and the Oregon Consumer Privacy Act (OCPA, Recology, Inc. and its affiliates (collectively, “Recology,” “we“, “us” or “our“) provide the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California and Oregon consumers. This California and Oregon Consumer Privacy Notice (the “Notice”) supplements our Privacy Policy.

This Notice does not apply to our employees, contractors, interns, externs, board members, or job applicants where the Personal Information we collect about those individuals related to those current, former or potential roles in the company. These individuals who reside in California are covered under a certain policy. For purposes of this Notice, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular individual or household.

Collection of Personal Information

We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information as listed in the CCPA and OCPA:

1. “Identifiers.” Identifiers, such as name, contact information, Recology account username and password, IP address and other online identifiers, Social Security number, driver’s license number, automobile or other vehicle license plate number;
2. “Customer Records Information.” Personal information, as defined in relevant customer records law, such as name, contact information, Social Security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information;
3. “Protected Class Information.” Characteristics of protected classifications under state or federal law, such as age, race, color, physical or mental disability, sex, veteran or military status;
4. “Transaction Information.” Commercial information, such as transaction information and purchase history;
5. “Online Use Information.” Internet or network activity information, such as browsing history and interactions with our website;
6. “Geolocation Data.” Geolocation data, such as device location and approximate location derived from IP address;
7. “Audio/Video Data.” Audio, electronic, visual and similar information, such as photographs and audio and video recordings;
8. “Employment Information.” Professional or employment-related information, such as job title; and
9. “Inferences.” Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, behaviors, or characteristics.
10. “Sensitive Personal Information.” Government-issued identification numbers, such as Social Security number, passport number, driver’s license or state identification card number, your Recology account log-in information, physical or mental disability, precise geolocation, and race.

Sources of Personal Information

We collect Personal Information from:

• Our interactions with you, such as when you establish an account with us, interact with our websites, or participate in other online or offline services we provide, including our collection and processing of waste or other physical materials you provide to us through our waste collection services or at our waste transfer stations; and
• Third parties that interact with us in connection with the services we perform, such as payment processors.

Purposes for the Collection, Processing, and Disclosure of Personal Information

We collect, process, and disclose all of the above these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information to:

• Provide information, products, or services that you request from us;
• Fulfill your requests and transactions and respond to your inquiries;
• Develop, improve, repair, and maintain our products and services;
• Advertise, and market our products and services;
• Conduct research, analytics, and data analysis;
• Establish and maintain user accounts and authenticate user identity;
• Maintain our property and our records, and undertake quality and safety assurance measures;
• Conduct risk and security control and monitoring, and detect and prevent fraud;
• Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;
• Carry out corporate transactions, such as mergers, joint ventures, or acquisitions; and
• Comply with law, legal process, and internal policies, and exercise and defend legal claims.

Subject to your consent where required by applicable law, we collect, process, and disclose Sensitive Personal Information for purposes of:  providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual.  We do not use Sensitive Personal Information beyond these purposes.

Disclosure of Personal Information

In the preceding 12 months, we disclosed for our operational business purposes the following categories of Personal Information to the following categories of third parties:

We do not “sell” Personal Information (including Sensitive Personal Information), and we do not “share” or otherwise process Personal Information (including Sensitive Personal Information) for purposes of cross-context behavioral or targeted advertising, as defined under applicable law.  We have not engaged in such activities in the 12 months preceding the date this Notice was last updated.  Without limiting the foregoing,  we do not knowingly “sell” or “share” Personal Information (including Sensitive Personal Information) of minors under 16 years of age.

Retention Period

We retain each category of Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected.  The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you, for example, for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
• Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; and
• Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

Individual Rights and Requests

If you are a California or Oregon resident, you may make the following requests:

1. “Request to Know” You may request to know whether we process your Personal Information, and to access such Personal Information, including to receive the specific pieces of your Personal Information in a portable format.
   • If you are a California resident, you may request that we disclose to you the following information:
     • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
     • The specific pieces of Personal Information we collected about you;
     • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
     • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
   • If you are an Oregon resident, you may request that we disclose to you the following information:
     • The categories of Personal Information we process about you; and
     • The third parties to whom we have disclosed Personal Information.
2. “Request to Delete” You may request that we delete your Personal Information.
3. “Request to Correct” You may request that we correct inaccuracies in your Personal Information.

To make a request listed above, please contact us. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.

We may need to request additional Personal Information from you, such as email address, mailing address, Recology account number/name, service levels, or prior correspondence, in order to verify your identity and protect against fraudulent requests. You may make a request on behalf of a child who is under 13 years old if you are the child’s parent or legal guardian. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information. You have the right to be free from unlawful discrimination for exercising your privacy rights.

Appeal Process: If you are an Oregon resident and we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us via privacy@recology.com.

Authorized Agents

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.”  We will process the agent’s request consistent with applicable law.  As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent.  In addition, we may require that you verify your identity as described in the section entitled “Individual Rights and Requests” or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

Changes to this Notice

We may change or update this Notice from time to time. When we do, we will post the revised Notice on this page with a new “Last Updated” date.

Contact Us

If you have any questions regarding this Notice, please contact us.