ATW CALIFORNIA PRIVACY NOTICE

Last Updated: 2/2/2026

ATW TRAILER WORLD CORP. d/b/a ATW PRIVACY NOTICE FOR CALIFORNIA BUSINESS CONTACTS

This Privacy Notice for California Business Contacts (“CCPA Business Privacy Notice,” “Privacy Notice”) describes the Personal Information that ATW Trailer World Corp. d/b/a ATW (collectively “ATW,” “we,” “us,” or “our”) collects, uses, discloses, transfers and stores (collectively, “process”) from our Consumers (as defined below) who are California business contacts. The CCPA Business Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and supplements the information contained in the ATW Privacy Policy.

The CCPA Business Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”). We provide you this notice because under the CCPA, California residents who are business contacts of our commercial customers or vendors qualify as Consumers. For the purposes of this CCPA Business Privacy Notice, when we refer to Consumers, we mean you to the extent you are a California business contact.

This CCPA Business Privacy Notice also explains how we intend to use and disclose that personal information, and the rights you may have related to such processing.

In some circumstances, we may provide different or additional notices of our privacy practices to the extent they apply to you because of the product or services you obtain from us, the capacity in which you engage with us, or different laws that may apply. Depending on your relationship with ATW and the jurisdiction in which you reside, please refer to the following:

We may change this CCPA Business Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of this CCPA Business Privacy Notice. If we make material changes, we may provide you with additional notice, such as by sending you a notification or adding a statement to the Website (as defined below).

1. Notice at Collection and Business Purposes for Processing

The categories of personal information we collect depend on how you interact with us, including, but not limited to on our website accessible at https://www.atw.com/ccpa/ (“Website”), through email, and other online products and services, in physical locations, over the telephone, or when you otherwise interact with us where we provide this CCPA Business Privacy Notice, such as through our customer support channels (collectively, “Services”).

We collect business contact information that you provide or communicate to us when you interact with us in a commercial capacity, such as when you obtain commercial products or services from us or interact with us as vendor. We also collect information automatically when you interact with our Website and from other sources such as third-party services and organizations.

As described in the below table, ATW collects the following categories of Personal Information from California business contacts, which depend on the particular uses and bases of such processing, with additional information regarding our practices following the table:

Category of Personal Information Collected by ATW	Business Purpose of Processing
Identifiers: Name, postal address, phone number, email address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, Social Security Number, driver’s license information, [passport or other government identification information,] or payment card information. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Name, address, telephone number, business financial account information, or payment card information. Commercial information: Records of products or services purchased, obtained, or considered, and other purchasing or consuming histories.	· If we seek to or provide you a commercial product, service or engage you as a vendor or in another business capacity, we use your Personal Information to communicate about our potential, current, or former business relationship; · To contact you and to inform you about the benefits or information relating to your commercial products, services or our business relationship; · Provide and administer our Services and user accounts; · Process and fulfill your transactions at our service and/or repair centers; · Develop or improve products and services; · Analytics and conducting market research; · Respond to your requests, questions, and concerns; · Personalize your experience with us, including at our affiliate entities; · Deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our third-party sites and via email (with your consent, where required by law) (for more information, see the Targeted Advertising and Analytics section below); · Direct marketing; · Verify customer information; · Help customer service representatives assist you on request; · Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity; · Manage our stores, service and/or repair centers, and other facilities, including our parking lots; and · Carry out any other purpose described to you at the time the information was collected.
Characteristics of protected classifications under California law: None.	None.
Internet or other electronic network activity information: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, browsing history, search history, cookies (small text file stored on your hard drive or in device memory that help us improve our websites and your experience), pixel tags and web beacons (electronic images that we use on our websites and in our emails to help deliver cookies, count visits, and understand usage), and other tracking technologies, browsing history, search history, the date, time, length of stay, and specific pages accessed during your visits to our Website), IP address, device identifiers associated with your computer or device, mobile carrier and related information, activity logs. Geolocation data: Physical location or movements based on IP address, or precise geolocation data.	· Develop or improve products and services; · Personalize your experience with us; · Conduct market research; · Deliver content and product and service offerings relevant to your interests, including targeted offers and ads through third-party sites and via email (with your consent, where required by law) (for more information, see the Targeted Advertising and Analytics section below); · Record information about your browsing session on the websites, including which pages you visited and any forms on the websites, and track clicks; · Monitor and analyze trends, usage, and activities in connection with our products and services; · Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity; and · Carry out any other purpose described to you at the time the information was collected.
Sensory data: Audio (such as call recordings), photographs and video footage provided by Consumer or recorded as permitted by law, and photos and video recordings via Closed-Circuit Television (“CCTV”) inside and outside our stores, service and/or repair centers, including our parking lots.	· Provide and administer our Services and user accounts;· Help customer service representatives assist you on request;· Process and fulfill your transactions at our service and detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity; · Capture CCTV recordings and photos inside and outside our stores for security and loss prevention purposes; · Manage our stores, service and/or repair centers, and other facilities, including our parking lots; · Monitor and retain your call conversations with customer service for training purposes; and · Carry out any other purpose described to you at the time the information was collected.
Sensitive Personal Information: Passport or other government identification information, Social Security Number, driver’s license information, or precise geolocation data.	· Provide and administer our Services and user accounts;· Process and fulfill your transactions at our service and/or repair centers; · Respond to your requests, questions, and concerns;· Personalize your experience with us, including at our affiliate entities; · Deliver content and product and service offerings relevant to your interests, including targeted offers and ads through third-party sites and via email (with your consent, where required by law) (for more information, see the Targeted Advertising and Analytics section below); · Verify customer information; · Help customer service representatives assist you with a request; · Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity; · Manage our stores, service and/or repair centers, and our facilities, including our parking lots; and · Carry out any other purpose described to you at the time the information was collected.
Professional and employment-related information: Current employer and job title.	· If we seek to or do provide you a commercial product, service or engage you as a vendor or in another business capacity, we use your Personal Information to communicate about our potential, current, or former business relationship; · Providing services, including maintaining and servicing accounts, improving and developing new products and services, debugging and repairing errors in our Services; · Processing or fulfilling transactions; · Verifying customer information; · Direct marketing; · Analytics; and · Security.

De-identified, Anonymized, or Aggregated Data: In addition, we may use the above categories of information to create de-identified, anonymized, or aggregated information that cannot reasonably be used to identify you. We process, use, and disclose such de-identified, anonymized, or aggregated information only in a deidentified manner and will not attempt to re-identify such information, except as permitted by applicable law.
Other Purposes: We may also use the Personal Information listed above to comply with legal and financial obligations and/or carry out any other purpose described to you at the time the information was collected or to which you consent.
Information from Other Sources, Including from Publicly Available Sources. We may collect or receive information about you from other sources, including through third-party partners, advertising networks, mobile advertising data providers, services, organizations and other business contacts, which may supplement information provided by you. For example, we may collect and process information from identity verification, background checks, credit reports, and risk assessment providers for fraud prevention purposes.
Sensitive Personal Information. In some cases, as described in the above table, we collect sensitive personal information about you, which requires a higher level of protection. We will only use such sensitive personal information for the purposes set out in this CCPA Business Privacy Notice, or as otherwise described to you at the time such information is collected, and in accordance with applicable law. We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you.

2. How We Disclose Your Information

We may disclose your information as described in this CCPA Business Privacy Notice (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. The following table describes the categories of personal information ATW has collected and the categories of third parties to which such information has been disclosed for a purpose in the preceding 12 months, with additional information regarding the purposes of the disclosures to those third parties following the table. See the Notice of Personal Information We Collect and Business Purposes for Processing for detailed examples of Personal Information for each category.

The bulleted list below the table provides further details and examples about the recipients within ATW, service providers, contractors, and other third parties to whom we disclose such Personal Information.

Category of Personal Information Collected by ATW	Category of Third Parties to which Personal Information is Disclosed
Identifiers.Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Geolocation data.Sensitive Personal Information.	· Service Providers and Contractors · Advertising Partners
Internet or other electronic network activity information.	· Service Providers and Contractors

Further Details About Those to Whom We May Disclose Personal Information

Service Providers and Contractors. We may communicate Personal Information to service providers and contractors that need access to such information to perform services on our behalf. The types of service providers to whom we disclose personal information include service providers, such as: account service providers, legal service providers, web hosting and internet service providers, cloud service providers, the provision of IT and security services, marketing and advertising, reporting and analytics, fraud prevention, identity verification/background checking services, credit reporting services, and service providers which manage our facilities, including our stores, service and/or repair centers, and parking lots, as applicable.
Affiliates, Subsidiaries, and Employees. ATW may disclose your Personal Information to our affiliates, subsidiaries and employees who need to know the information.
Advertising Partners: We may disclose Personal Information to third parties for the marketing and advertising purposes described above. For more information about the cookies and other tracking technologies we use, and the choices and rights available to you, see the Your Privacy Choices and Rights section below.
Government Authorities, Regulators, and Similar Third Parties (collectively, “Government Entities”): We may communicate Personal Information to courts, government authorities, independent external advisors, and internal compliance and investigation teams if we believe such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process.

We also disclose the above information with the following categories of third parties:

Professional Advisors: We communicate information about you to our professional advisors, including accountants, auditors, lawyers, insurers, and bankers. We only permit these advisors to process your Personal Information for specified purposes and, as appropriate, in accordance with our instructions and the provisions of this CCPA Business Privacy Notice and applicable law.
Other Third Parties: In certain limited circumstances, we disclose your Personal Information to other third parties, including: (i) to comply with our obligations; (ii) to cooperate with law enforcement or national security investigations, requests and legal processes, such as court orders or subpoenas, as well as threats to the health or safety or any person or of our systems or services; (iii) protect your, ATW’s, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) assist with an investigation or prosecution of suspected or actual illegal activity; (v) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing, transition of service to another entity, or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings); and (vi) with you consent and at your direction. In certain circumstances and only as necessary in connection with business operations, work contact details may be provided to customers, potential customers, and other third parties, where the disclosure is required by role.
Aggregated or De-identified Information: We also process, use, and disclose aggregated or de-identified information that cannot be reasonably used to identify you. ATW will not attempt to re-identify such information, except as permitted by applicable law.

3. Cross-Border Data Transfers

ATW is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your Personal Information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of Personal Information in accordance with applicable law, such as by obtaining your consent, relying on adequacy decisions, or executing Standard Contractual Clauses.

4. Targeted Advertising and Analytics

We engage others to provide analytics services across the web and in mobile apps, serve advertisements, and perform related services. These entities may use cookies, pixels, web beacons, device identifiers, and other technologies to collect information about your use of our websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. ATW and others may use this information to, among other things, analyze and track data (including user engagement and other event activity), determine the popularity of certain content, and better understand your online activity.

For more information about the cookies and other tracking technologies we use, analytics practices, the choices and rights available to you, and opt-out options, see the Your Privacy Choices and Rights section below and the Targeted Advertising and Analytics section in the ATW Privacy Policy.

Google Analytics. We use Google Analytics to recognize you and link the devices you use when you visit our Sites or services on your browser or mobile device, log in to your account on our services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our service and to tailor our content to you. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) to inform, optimize, and display ads based on your past visits to the services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, go to the Google Analytics Privacy Policy or to Google Opt-Outs to learn about Google Analytics’ currently available opt-outs. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager or NAI’s online resources.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices.

5. Your Privacy Choices and Rights

The privacy choices you may have relating to your Personal Information are determined by applicable law.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies. You may stop or restrict the placement of cookies (small text file stored on your hard drive or in device memory that help us improve our websites and your experience), pixel tags and web beacons (electronic images that we use on our websites and in our emails to help deliver cookies, count visits, and understand usage), and other tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Website may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

Your Privacy Rights: If you are a Consumer who is a resident in California, subject to certain limitations, you may have some of the additional rights described below. If you would like to exercise any privacy rights granted to you under applicable law, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. Please note, to protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide information to allow us to reasonably verify you are the person about whom we collected Personal Information (or an authorized representative), or to answer questions regarding your employment and/or job application.

Right to Know and Access Personal Information: This includes a right to: (i) confirm whether we are processing your Personal Information; (ii) request to know more about the categories and specific pieces of Personal Information we collect, use, disclose, sell; and (iii) to access your Personal Information.
Right to Request Correction: This includes a right to request correction of your Personal Information where it is inaccurate or incomplete.
Right to Request Deletion: This right includes the right to request deletion of certain Personal Information, subject to certain exceptions prescribed by law.
Right to Non-Discrimination: For Consumers, you have a right to non-discrimination if you exercise privacy rights provided to you under law.

Authorized Agents: Only you, or an agent authorized to act on your behalf, may make a verifiable consumer request to exercise the rights described above related to your Personal Information. If we receive your request from an authorized agent and they do not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent, please contact us via the “Contact Us” section below for additional instructions.

Appeal: You may appeal a decision relating to your privacy rights request by contacting us at [email protected]. If you have concerns about the result of an appeal, you may contact the California attorney general.

California – Sales and Sharing of Personal Information

The CCPA requires that we provide transparency about Personal Information (as defined under applicable laws) we “sell” or “share” to residents in California who are Consumers. “Sale,” for the purposes of California law, broadly means scenarios in which we have disclosed Personal Information with third parties and/or affiliates in exchange for valuable consideration, while “sharing” means we have disclosed Personal Information to a third party for cross-context behavioral advertising. In addition, the CCPA has been interpreted to deem this “sharing” to also be a form of “sale.” In the preceding twelve (12) months, ATW has “sold” or “shared” your Personal Information to or with third parties for cross-context behavioral advertising, such as targeted advertising to you based on your Personal Information obtained from your activity across businesses, websites, apps and services other than our Services. See the Targeted Advertising and Analytics section above for more information about behavioral advertising.

You can opt out of such “sales” or “sharing” for targeted advertising via the Your Privacy Choices link on our webpage.

We do not have actual knowledge of any such activity involving the Personal Information of minors under 16 years of age.

6. Data Retention

We will retain your Personal Information for as long as reasonably necessary to carry out the purposes disclosed in this Privacy Notice.

7. Third Party Websites/Applications

Various resources and sites at ATW may contain links to third party websites/applications and other websites/applications may reference or link to ATW. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

8. Changes to Our Privacy Notice and Practices

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue your employment with or services to ATW after the new Privacy Notice takes effect. If at any point you do not agree to any portion of the Privacy Notice in effect, you must immediately contact Human Resources.

9. Contact Us

If you have any questions about our privacy practices or this CCPA Business Privacy Notice, please contact ATW by email at [email protected]. You can also contact us at 1-844-784-0309.