Guarding the privacy and safety of your data is very important to us. This Policy outlines what we collect about you, and how we use, share, and manage this data. It also outlines the choices you have about this data. Please read it carefully.
What We Collect and Why
We collect your data in several ways including when you choose to share it with us, when you shop with us or engage with our digital properties, and from our affiliates and partners. We intend to comply with applicable laws no matter how we obtain your data.
The table below describes what we collect, how we collect it and why.
|Identifiers – e.g. name, email address, physical address, phone number, on line identifiers (such as username or social handle), etc.||We may use this data in order to identify you, authentication of your account, deliver goods and services to you, market to you, personalize our goods and services to you, associate other data with you, analyze other data we collect, identify other potential customers (e.g. “look alike” customers), develop new goods and services, and for security and fraud prevention.||We obtain this data directly from you when you order goods or services and when you sign up for our services or marketing. We may also obtain your identifiers from affiliates (e.g. when you interact with their sites) and partners (e.g. to verify parts or all of your address).|
|Personal characteristics – e.g. clothing size, self-identified gender, age, etc.||We may use this data to personalize our goods and services to you, market to you, analyze other data we collect, identify other potential customers (e.g. determine how many customers are a certain size), and develop new goods and services.||We obtain this data directly from you when you order products and services (e.g. the size you select) and when you provide us that information (e.g. when you create an account).|
|Commercial information – e.g. payment information, purchasing history, product or service interests, product reviews, estimated income, etc.||We use this data to personalize our goods and services to you, market to you, analyze other data we collect, identify other potential customers (e.g. determine how many customers share product interests), and develop new goods and services.||We obtain this data from you when you order or browse products and services (e.g. purchase history) and when you provide us that information (e.g. product reviews). We may also obtain commercial information from affiliates (e.g. purchase history on their sites) and partners (e.g. estimated income).|
|Internet and network activity – e.g. IP address and location data, device ID, browse history, etc.||We may use this data in order to identify you, deliver goods and services to you, market to you, personalize our goods and services to you, associate other data with you, analyze other data we collect, identify other potential customers (e.g. “look alike” customers), develop new goods and services, and for security and fraud prevention.||We obtain this data directly when you interact with our websites, apps, and digital properties (such as in store WiFi). We may also obtain this information indirectly from cookies, tags and other digital tools, from affiliates (e.g. when you interact with their sites) and from partners.|
|Images, audio, video, social media posts, etc.||We may use this data in marketing when you allow us to do so (e.g. post a review), to measure your engagement with our brands (e.g. social posts), to deliver you services, develop new goods and services, and for security and fraud prevention.||We obtain this data directly from you when you post to our websites, apps, or social channels, or tag us on social. We may also obtain this information when you participate in our recorded events (e.g. concerts) or enter our stores (e.g. security video).|
|Education, professional, or employment related information||We may use this data to market to you, personalize our goods and services to you, associate other data with you, analyze other data we collect, identify other potential customers, and develop new goods and services.||We obtain this data when you provide it to us. We may also obtain this information from affiliates and partners (e.g. when working with a partner to market to a college’s students or alumnae).|
|Communications with you, e.g. email, chat logs, etc.||We may use this data to provide you goods and services, develop new goods or services, market to you, and for security and fraud prevention.||We obtain this data when you communicate with us.|
|Inferences drawn from other information||We may use inferences drawn from other data to identify you, deliver goods and services to you, market to you, personalize our goods and services to you, associate other data with you, analyze other data we collect, identify other potential customers, develop new goods and services, and for security and fraud prevention.||We may make inferences drawn from other information based on our own observation, analysis or algorithms. We may also obtain inferences from our affiliates or from partners (e.g. credit score).|
How We Protect Your Data
We need your help to keep your data safe! If your account requires a password and you give a friend your password, it is much harder for us to keep your data safe. You also should not use the same password across multiple websites or apps. That makes your data much less safe, and it’s very hard for us to protect you from someone else’s breach.
Bad guys are tricky! They may pretend to be us to trick you into giving them your data. Don’t get tricked, we will never ask you for your password, whether in email, on line chat, phone call, or in person.
ADS ON OTHER SITES We want to speak with you where it’s best for you. We may share your contact info with other companies so we can reach you on their sites or social channels. If you choose to give others your data directly (like Google or Facebook) their rules apply to that data, not ours. We sometimes buy ads on other sites. Even if we don’t share (or have) your data, you might see those ads. We can’t always control how they choose to place our ads.
MINORS Under age 13. We do not want to and do not knowingly collect any data from people under age 13. If we learn that we collected any such data, we will take all reasonable measures to delete that information and to not use it for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under 13, please contact us at the addresses listed below.
Under age 18. People under 18 years of age may have data that they provide to us through our website deleted by sending an email to email@example.com requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your data does not ensure complete and comprehensive removal of that data from all systems.
DO NOT TRACK Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, we do not recognize DNT.
Additional Rights and Disclosures for Virginia Residents
HOW TO APPEAL A DECISION PERTAINING TO A REQUEST Should we deem it necessary to refuse a request, our response will include our reason as well as instructions to appeal the decision. Per VA Law, you will need to appeal within a “reasonable period of time“ after receipt of the decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal. If the appeal is denied, you may contact the VA Attorney General to submit a complaint.
YOUR RIGHTS Our goal is to serve you. We know you want to control your data and you have the right to do so. Here is a list of the rights you have as a resident of Virginia: • You can ask whether or not we are processing your personal data and ask for a copy of your data or info about what we collect, why and who we share it with • You can ask us to correct your data or to delete some of it • You can ask us to transfer data you gave us to other companies • You can ask to opt-out of the processing of your personal data pertaining to targeted advertising; the sale of personal data; profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (see below for more information on your right to opt-out)
RIGHT TO OPT OUT If you are a Virginia resident, you have the right to opt out of the “sale” of your personal information to “third parties” Sale is defined very broadly. The law defines “sale” more broadly than you might think. It doesn’t just include the exchange of data for money. Instead, it covers any transfer of personal information to a “third party” in exchange for “monetary consideration” We do not transfer your information to third parties in exchange for money and we will not do so. However, we do transfer personal information to certain third parties in order to operate our business (for example, to market our products and services). It is possible that someone could claim that this transfer was in exchange for “monetary consideration.” We want to be careful with and respectful of your information. Therefore, if you opt out, we will not transfer your information to any “third party” except as explained below (and allowed by law).
Opting out may have impacts you don’t expect. Any transfer of data to a “third party” may be considered a “sale” of data. The law considers any other business a “third party” unless that business agrees to specific contractual provisions, aligning with the role and responsibilities of “processor” under Virginia Law. We try to get all of the businesses to whom we send information to accept the role of “processor” and agree to the respective responsibilities in our contract. But not everyone will or can agree to those terms. As a result, if you opt out of the “sale” of data, we will not be able to send data to some of our business partners. That may mean that, after you opt out, you may not receive all of the marketing and other information you are accustomed to receiving from us. In the extreme, if one of our critical partners cannot agree to the special contract language, and is considered a “third party”, it is possible that some features of our web site or other services may not work for you after you opt out.
In addition, if you opt-out, we may alert you if a transaction requires a transfer to a third party so that you can opt in if you would like to continue with the transaction
Minors. We do not “sell” the data of people under 16, and do not intend to collect data related to people who are under 13. Exceptions to the opt out. The law creates several exceptions that are important for you to be aware of.
We are allowed to transfer data to a “processor” even if you opt out. The law does not consider that kind of transfer to be a “sale.” A processor is a business that agrees not to use your information for any purpose other than providing the services specified in our contract. For example, we transfer data to business partners to provide data security and detect fraud. Those businesses are “processors.” Even if you opt out, we will continue to transfer data to our processors.
We are also allowed to transfer your data to a third party where you direct the transfer or direct us to interact with the third party. For example, if you direct us to use a specific payment method to pay for your order, even if you have opted out, we will still transfer the data necessary to process your order.Collecting information and using it ourselves is not a “sale.” Opting out of the “sale” of your data does not prevent us from continuing to collect and process your personal information. You can learn more about how and why we collect personal information at our Notice of Collection. The “opt out” only applies to “personal information.” This is information that is or is capable of being linked to you. We use anonymization and pseudonymization to protect privacy. That data is not “personal information” Opting out will not limit our transfer of that data to third parties.
Technical limitations on opt out. Please note that there are technical limits to our ability to identify data related to you and, if you opt out, to prevent the “sale” of that information to other parties. Where we can reasonably determine that information relates to you and you have opted out, we will not “sell” it to “third parties” (except as allowed by the law). However, we may not be able to determine that information relates to you. In that case, the information may be “sold” to a third party. Opting out is not unsubscribe. *Opting out of the “sale” of personal information will not prevent you from receiving marketing messages from us. If you wish to unsubscribe from our emails, please follow the unsubscribe link in one of our emails. If you wish to unsubscribe from text messages, please follow the unsubscribe process for the program you opted into.
*Opting-out multiple email addresses If you want multiple email addresses opted out, you must provide each address to us. This is because we have no reasonable way to use a single address you give us to link to other addresses you may have.
CONTACT US Our Data Protection Officer (DPO) is working hard to protect your data. Our DPO can help you with questions about this Policy or your data. If you want to contact our DPO, you can do so by email at firstname.lastname@example.org. You can also mail us at: Data Protection Officer, Uzo Art, 135 Erie St #305, Jersey City, NJ 07304.
If you don’t want us to send you marketing messages anymore, you can contact our DPO or just unsubscribe from the link in one of our messages. You can also contact our DPO to request a copy of this Policy in a different format.