Privacy Notice for California Business Contacts

 

Last Updated: February 14, 2025.

The California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”), gives California residents certain rights and requires businesses to make certain disclosures regarding their collection, use, and disclosure of Personal Information. This Privacy Notice for California Business Contacts (the “Notice”) provides such disclosures to California-resident individuals with whom Winnebago Industries, Inc. or any of its affiliates (“Winnebago Industries,” “we,” “us,” “our) interacts with in a business-related capacity (“Business Contacts”).

Please note that this Notice only addresses Winnebago Industries’ collection, use, and disclosure Personal Information of Business Contacts and only applies to residents of California. This Notice does not apply to individuals who are residents of other U.S. states or other countries and/or who do not interact with Winnebago Industries in a business-related capacity. For further details about our privacy practices pertaining to non-Business Contact Personal Information, please see our Privacy Policy and U.S. State Supplemental Privacy Notice, available here.

  1. Definitions
  • “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes Sensitive Personal Information, that we specifically describe in this Notice.
  • “Third Party” means any non-affiliated person that is not a Service Provider.
  • “Service Provider” means a service provider, contractor, or processor which collects, stores, or otherwise handles data for us and is bound by contractual obligations to use your Personal Information only as directed by us.

Other terms used herein that are defined under the CCPA shall have the meanings afforded to them in the CCPA, whether or not capitalized, unless context indicates otherwise.

  1. Overview of Personal Information Processing
  1. Collection of Business Contact Personal Information. We, and our Service Providers, may have collected and Processed the following categories of Personal Information from Business Contacts in the preceding 12 months:
  • Identifiers, such as name, alias, online identifiers, account name, physical characteristics or description
  • Contact information, including phone number, address, email address,.
  • Geolocation data, such as device location
  • Audio, electronic, visual and similar information, such as call and video recordings
  • Sensitive Personal Information, including:
    • Personal Information that reveals:
      • Social security, driver’s license or state identification card
      • Precise geolocation
      • Contents of a Consumer’s email and text messages, unless the business is the intended recipient thereof
  1. Purpose for Collection, Processing, and Disclosing Business Contact Information. We, and our Service Providers, collect, process, and disclose the categories of Personal Information listed in Section B.1 for the following business purposes:
  • Provide you with a service or take an action that your request
  • Determine your potential involvement in future activities with Winnebago Industries and contact you in relation with those activities
  • Communicate with you when you participate in, or request to be considered to participate in Winnebago events or other programming
  • Respond to your requests about our products and services
  • Communicate other information that we think may be of interest to you through our websites and via email, call centers, postal mail, and other channels about our products and services
  • Meet our contractual obligations to you
  • Process and manage contracts and other written agreements we may enter with you and the companies for which you work
  • Conduct auditing related to our current interactions with you
  • Tailor our messaging and communications to you, including messaging and communications for promotional purposes
  • Personalize your experience on our websites
  • Conduct business and marketing research
  • Detect security incidents and other fraudulent activity
  • Monitor and improve our website functionality and security
  • Analyze the quality of services provided, including by analyzing call recordings
  • Monitor and secure our facilities, equipment, and other property
  • Comply with laws and regulations, including, without limitation, applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws
  • Monitor, investigate, and enforce compliance with and potential breaches of Winnebago Industries’ policies and procedures and legal and regulatory requirements
  • Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons
  • Exercise or defend the legal rights of Winnebago Industries and its employees, affiliates, customers, contractors, and agents

We collect, process, and disclose the Sensitive Personal Information of Business Contacts described in Section B.1 only for:

  • Performing the services or providing the goods reasonably expected by an average Consumer who requests those goods or services
  • Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Information
  • Resisting malicious, deceptive, fraudulent, or illegal actions directed at us and prosecuting those responsible for those actions
  • Ensuring the physical safety of natural persons
  • Performing services on our behalf, including maintaining or 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 our behalf
  • Verifying or maintaining the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by us, and improving, upgrading, or enhancing the service or device that is owned, manufactured by, manufactured for, or controlled by us
  • Collecting or processing Sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about a Consumer
  1. Sources of Business Contact Personal Information. We obtain the Personal Information listed in Section B.1 from the following sources: directly from your interactions with us, including with the website, our devices and software, desktop and mobile applications, by email, and phone; social media sites; web browsers; advertising, marketing, and analytic service providers; mailing list providers; technology service providers; publicly available sources; mailing list vendors; and Service Providers and Third Parties when they disclose information to us.
  2. Disclosure of Business Contact Information. We disclose, and in the past twelve months have disclosed, the categories of Personal Information of Business Contacts listed in section B.1 for the purposes listed in Section B.2 as follows:
  • To Service Providers we hire to perform services or functions on our behalf such as marketing and advertising services, technology services, security services, analytics services, mailing and shipping services, and other similar services. We grant our Service Providers access to Personal Information only to the extent needed for them to perform their functions, and require them to protect the confidentiality and security of such information.
  • To Third Parties as necessary to protect our rights, defend or prosecute a legal claim, or investigate or prosecute illegal activities.
  • To Third Parties at your direction or with your consent.
  • To government or judicial authorities to comply with a court order, subpoena, search warrant, law, regulation, or government investigation.
  • To a successor entity or purchaser upon a merger, consolidation, or other corporate reorganization in which we participate, a sale of all or a portion of our assets, or pursuant to a financing arrangement. In this situation, we will seek assurances that the successor entity or purchaser will process personal information collected by us in accordance with this notice.
    1. Retention of Business Contact Personal Information. We retain each category of Personal Information listed in Sections B.1 for the duration of your business relationship with us, as applicable, and longer as may be required by applicable laws or necessary for our legitimate business purposes.
      1. Your Rights & Choices.

As a California resident, you have the following rights regarding our collection and use of your Personal Information, subject to certain exceptions:

      • Right to Know: You have the right to know the following details about our privacy practices at or before the point of collection. We have provided such information in this Notice. You may also request that we provide you with information about the following aspects of how we have handled your Personal Information specifically in the 12 months preceding your request: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources from which we collected such Personal Information; (iii) the business or commercial purpose for collecting, Selling, or Sharing Personal Information about you; (iv) the categories of Personal Information about you that we disclosed and the categories of Third Parties to whom we disclosed such Personal Information; (v) the categories of Personal Information about you that we Sold or Shared and the categories of Third Parties with whom we Sold or Shared such Personal Information; (vi) if we collect Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is Sold or Shared; and (vii) the length of time we intend to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
      • Right to Deletion: You may request that we delete any Personal Information about you that we collected from you.
      • Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
      • Rights to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the Sale and Sharing of your Personal Information. You also have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA. We will not Sell or Share any of the categories of Personal Information we collect about Business Contacts, and we have not Sold or Shared any Personal Information of Business Contacts in the past twelve months. Further, we do not use or disclose Sensitive Personal Information of Business Contacts for purposes beyond those authorized by the CCPA. Relatedly, we do not have actual knowledge that we Sell or Share Personal Information of California Consumers under 16 years of age. For purposes of the CCPA, a “Sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “Share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
      • Right to non-discrimination: You have the right not to receive discriminatory treatment by Winnebago Industries for exercising privacy rights conferred by the CCPA and the right not to be retaliated against for exercising your rights conferred by the CCPA.
      1. Exercising Your Rights.

Submit a Request. To submit a request to exercise your data subject rights listed in Section C,  please contact Winnebago Industries at dataprivacy@winnebagoind.com or 941-351-4900.

Authorized Agent. You may designate an authorized agent to make a request under the CCPA on your behalf. Authorized agents may submit a request on your behalf using the methods described above. To be able to act, authorized agents must submit proof that they are authorized to act on your behalf. We may deny requests from claimed authorized agents who do not submit adequate proof that they are authorized to act on your behalf.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before complying with your requests. For example, for requests to know, correct, and delete, we will attempt to match your identity to the information stored in our files. If we cannot, we will ask you to provide additional identifying information. We will use information you provide in your request for the purpose of verifying your identity or authority to make the request.

Opt-Out Preference Signals. We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. However, we do not Sell or Share Personal Information of Business Contacts.

      1. Other Disclosures.

Financial Incentives for California Consumers. We do not provide financial incentives to California Consumers who allow us to collect, retain, Sell, or Share their personal information. We will describe such programs to you if and when we offer them to you.

California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by writing to dataprivacy@winnebagind.com. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.

      1. Contact Us.

If you have questions about the use of your Personal Information, please call or email Winnebago Industries at dataprivacy@winnebagoind.com or 941-351-4900.

We may update this Notice from time to time. When we do so, we will post the updated version of our Notice here.