Thank you for visiting the DuoBoots (the “Company”, “we”, “our”) website (the “Website”) to look at our fabulous footwear and other products we sell (the “Products”). The Company respects your right to privacy. This policy summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.
It is the Company’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners and others who share their personal information with us.
General Principles of Company’s Collection, Use and Disclosure of Personal Information
To the extent required by applicable law, whenever the Company collects personal information, the Company will:
Personal Information the Company Collects
The Company collects the following types of personal information when you access our Website, order a Product, enter contests or sweepstakes, fill out surveys, and/or send us feedback:
Information You Provide – Personally Identifiable Information
The Company collects personal information you provide to us. “Personal Information” means any information that identifies or can be used to identify a natural person, including but not limited to: (i) contact information, such as your name, company name, job title, shipping address, home address, e-mail address, and phone number; (ii) additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, and demographic information; (iii) comments, questions, requests and orders you may make; (iv) financial information needed to process payments if you make purchases, such as credit/debit card or account information or tax identification number; (v) log-in information, including, if applicable, social media account information for login purposes; and (vi) information you submit to us when you order Products including, but not limited to your preferred methods of communication, your Product type preferences and Products you are interested in. If you contact our Customer Service representatives by telephone, e-mail, fax or letter, we may keep a record of your correspondence or comments. If you report a problem with the Website, we may collect such information in a file specific to you. If you contact us through our feedback area or by calling one of our customer service representatives, we may ask for your name, e-mail address and order information in order to send you a reply.
Updating Personally Identifiable Information
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us; for example: your email address or shipping address changes.
You have the ability to access and edit the Personal Information that you have provided to, or on, the Website. During the online ordering process, you can review, change or delete the information that you have submitted. You may change any of your Personal Information in your account online at any time. We encourage you to promptly update your information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past purchases, you cannot delete information associated with past purchases.
Also, as a security measure we "back up" the data stored on our systems, and such prior information cannot be completely removed from our databases. As a result, you should not expect that all of your Personal Information will be completely removed from our backed-up databases.
Failure to Provide Personal Information
Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a Product you have ordered from us or an order you have placed with us, but we will notify you if this is the case at the time.
Information Automatically Gathered from Your Device – Non-Personally Identifiable Information
“Non-Personal Information” means non-identifiable, aggregated information and data that does not by itself identify a specific individual including, but not limited to technical data transmitted by your device and aggregated use of the Website. The Website gathers certain information about you based upon where you shop on it in several ways. This information is compiled and analyzed on both a personal and an aggregated basis.
Device and browser information.
The Company may collect Non-Personal Information about your device, such as device type, browser type, Uniform Resource Locator ("URL") of the website from which you came from, your Internet Protocol ("IP") address used to connect your computer to the Internet, your operating system, and device identifier. The Company collects this information automatically from your device and web browser through Cookies and similar technologies.
A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol ("TCP/IP") network, such as the World Wide Web. Networks like the World Wide Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet, browse and shop.
Information about how you interact with us.
The Company may collect Non-Personal and Personal Information about your usage of Company Internet Sites and Apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, Company promotional emails opened, and dates and times of interactions. The Company collects this information using Cookies and similar technologies.
The Company may collect location information, including precise, real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. The Company Apps will NOT access precise, real-time location information from your device unless you grant permission to do so.
Product and Product-related information.
The Company may collect Product and Product-related information, including but not limited to: Products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
If you choose to submit a Product Review on the Website, we may ask you for information such as your name and city of residence, which may be used in connection with your review (taken together, the “Product Review Information”). By submitting the Product Review Information, you consent to our use, modification, reproduction, transmission, publication and display of such Product Review Information on the Website and also in connection with the promotion, marketing and advertising of our products and services; however, we are under no obligation to post any Product Review Information.
The Company shares information with third party companies including, but not limited to, credit/debit card processing centers, third-party technical, payment and delivery services, advertisers and advertising networks, hosting services, data processors, analytics providers, search information providers, credit reference agencies, and shipping carriers employed by the Company to perform functions on its behalf including order fulfillment, postal and email delivery, and credit processes.
When The Company May Share Your Personal Information
The Company will not disclose your Personal Information except as described here:
The Company may also share your Personal Information with third parties we hire to perform services for us. These third parties are required to use the Personal Information we share with them only to perform services on our behalf and to treat your Personal Information in compliance with all applicable privacy and data protection laws.
The Company may share your Personal Information with third-party marketers, but only as permitted by law, and will provide you with an opportunity to opt-out of such information sharing.
We may share your Personal Information with third parties when we have a good faith belief that disclosure is necessary: (i) to comply with applicable law, regulation, government requests, court order, judicial proceedings, or other legal process such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements) or as evidence in litigation in which we are involved; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, illegal definition violation of our policies, contracts or agreements, violation of law, or other misuse of Company Internet Sites, Apps, products or services; (iii) to protect the Company’s rights or property or yours or others’ health, safety, welfare, rights, or property; or (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
The Company may share your Personal Information with third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of the Company or a Company business unit, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
The Company may share your Personal Information, at any time, and for any reason, with your permission or at your request.
The Company may share Non-Personal Information including, but not limited to anonymized or aggregated information, internally and with third parties for any purpose. Such Non-Personal Information will not identify you individually.
How The Company Uses Your Personal Information.
The Company may use your Personal Information to:
Develop and manage our relationships with you and our Business Partners. This may include: (i) delivering services or carrying out transactions that you or our Business Partners have requested; (ii) providing information about Company Products, services, and transactions, and advertisements, that may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in interacting with the Company by learning more about you, how you use and interact with the Company Internet Sites, Apps, Products, and services; and (iv) planning, managing, and performing under our contractual relationships with our Business Partners.
Communicate with you. This may include: (i) informing you of Company Products, services, and promotional activities that may be of interest to you; (ii) providing information about relevant Company Products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, or production information, warranty or recall information, or information about Product or service improvements; and (iii) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
Provide and improve our Internet Sites, Apps, Products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new Company Internet Sites, Apps, Products and services.
Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of the Company Internet Sites, Apps, Products or services; and (v) protecting the Company’s rights or property, or yours or others’ health, safety, welfare, rights, or property.
The Company may also use your Personal Information for other uses consistent with the context in which the information was collected or with your consent.
The Company may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and Product-development purposes. Such information will not identify you individually.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We may disclose your Personal Information for any purpose with your consent.
By using our Website, you agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a Session Cookie in your browser (a temporary Cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
We may use third-party advertising companies to serve ads when you visit the Website. These third parties may be members of industry self-regulatory groups such as the Network Advertising Initiative (NAI) and Digital Advertising Alliance (DAA). The websites for these groups provide more information on interest-based online advertising and how to opt out of receiving interest-based online ads from participating companies.
These companies may use information about your visits to the Website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See the Section regarding Cookies for further information.
Information from Business Partners and other Third Parties
The Company collects Personal Information through our Business Partners. This information may include contact information, such as name, job title, address, e-mail address, and phone number.
The Company may also obtain Personal Information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third-party sources with information that we collect from you or your device, as described above.
These third parties may be members of industry self-regulatory groups such as the Network Advertising Initiative (NAI) and Digital Advertising Alliance (DAA). The websites for these groups provide more information on interest-based online advertising and how to opt out of receiving interest-based online ads from participating companies.
The Company also allows selected third parties, including analytics and advertising services, to place Cookies on our Internet Sites. These third parties may collect information about your online activities over time and across third-party websites.
A "Cookie" is a small text file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, holding items in your shopping cart, and sometimes providing you with advertising which is tailored to your interests.
Company Internet Sites use "Session Cookies." A Session Cookie does not identify you personally and expires after you close your browser. For example, when you use the Company Product Catalog, we place a Session Cookie to note what pages you have viewed. We can use this information to provide you recommendations of other Products that may be of interest.
Company Internet Sites also use "Persistent Cookies." These Cookies do not expire when you close your browser. Persistent Cookies stay on your computer until you delete them or they expire. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits. For example, after you make a purchase, if you decide to make another purchase, your shipping address may have been retained and will only need to be confirmed.
Although you are not required to accept Cookies when you visit a Company Internet Site, you may be unable to use all of the functionality of the site if you reject certain Cookies.
In addition, your browser may allow you to adjust settings to accept or reject Cookies, or to alert you when a Cookie is placed on your computer.
Do Not Track Browser Settings.
Some browsers may transmit "Do Not Track" ("DNT") signals to the websites you visit. Because there is no common agreement about how to interpret DNT signals, the Company currently does not take action in response to them.
Security of Your Personal Information
Your Personal Information will generally be stored in the Company’s databases or databases maintained by our service providers. Many of these databases are stored on servers located in the United States. The Company takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within the Company.
The Company maintains reasonable safeguards to protect the confidentiality, security and integrity of your Personal Information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.
Links to Third-Party Internet Sites and Plugins
The Company Internet Sites and Apps may contain links to websites or mobile apps that are not operated by Company and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook “Like” button. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, Apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, Apps, and social media platforms you visit before using them or providing personal information.
Retention of Your Personal Information
How long we keep your Personal Information will vary and will depend upon the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.
Persons Under 16
Our Website is a general audience website, which is not directed to, and should not be used by, children or other minors under the age of sixteen (16) and we do not knowingly collect or solicit Personal Information from such individuals except as permitted by applicable law. You are prohibited, without our prior written consent, from providing the Company with any Personal Information on children or other minors under the age of sixteen (16), unless such disclosure of personal information is necessary to facilitate an applicable business transaction or otherwise related to our Products or services, and you have the lawful ability to make such a disclosure to the Company. If a parent or guardian becomes aware that his/her child has provided us with Personal Information without their consent, he/she should contact us immediately. If we become aware that a person under 16 years of age has provided us with Personal Information, we will delete such data from our databases. The meaning of “children” is subject to the laws and regulations in the jurisdiction in which you are located.
ADDITIONAL INFORMATION FOR EU RESIDENTS
Data controller and contact information
By visiting the Website, you are accepting and consenting to the practices described in this Policy. If you submit Personal Information to us it will be maintained in accordance with the Data Protection Law. The Data Protection Law shall mean the Data Protection Act 2018 (DPA), the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, until such time as the GDPR is no longer directly applicable to the UK, and then in accordance with the provisions of any successor legislation to the GDPR or the DPA.
For the purpose of the Data Protection Law, the data controller is World Wide Duo Boots LLC, trading as DuoBoots. World Wide Duo Boots LLC, is incorporated and registered in the State of New Jersey, USA with Company Number 0450483602. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us at email@example.com in the first instance.
The Company’s lawful basis for processing your personal Data
Processing on the basis of legitimate business interests.
When we process personal Data on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting Company Internet Sites, Apps, Products, and services; (ii) communicating with current and potential customers, other Business Partners, and their individual points of contact; (iii) managing our relationships with our customers and other Business Partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information with affiliates of the Company, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our Products, services and employees, including fraud protection.
Processing on the basis of performance of a contract.
Examples of situations in which we process personal Data as necessary for the performance of a contract, including, but not limited to, e-commerce transactions, in which you purchase a Product or service from the Company, on your own behalf, through a Company Internet Site or App.
Processing on the basis of consent.
Examples of processing activities for which the Company uses consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing personal Data on Company Internet Sites or Apps through Cookies and similar technologies when consent is required by applicable law.
Processing because the Company is under a legal obligation to do so.
Examples of situations in which the Company must processes personal Data to comply with its legal obligations include: (i) the payment of taxes and other government levies; (ii) providing your personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (iii) retaining business records required to be retained by applicable laws; and (iv) complying with court orders or other legal process.
Additional information about the retention of your personal Data
To determine the period for which your personal Data will be retained in accordance with this Policy, the Company considers criteria such as: (i) any applicable legal requirements to retain Data for a certain period of time; (ii) any retention obligations related to actual or potential litigation or government investigations; (iii) any retention requirements in relevant agreements with our Business Partners; (iv) the date of your last interaction with the Company (including with Company Internet Sites, Apps, communications, etc.); (v) the length of time between your interactions with the Company; (vi) the sensitivity of the Data; and (vii) the purposes for which the Data was collected.
Where we use providers based in the US, we may transfer Data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal Data shared between Europe and the US.
All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology via Shopify Payments. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
Unfortunately, the transmission of Data via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Website; any transmission is at your own risk. Once we have received your Data, we will use strict procedures and security features to try to prevent unauthorized access.
We will only retain your Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal Data, we consider the amount, nature, and sensitivity of the personal Data, the potential risk of harm from unauthorised use or disclosure of your Data, the purposes for which we process your Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your Data: Please see the “Request erasure” Section below for further information.
In some circumstances we may anonymise your Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Individual Rights
In accordance with the applicable laws in the European Union, you have the following Rights with respect to your personal Data, which apply differently in different circumstances: the Right of confirmation, the Right of access, the Right to rectification, the Right to erasure, the Right to restriction of processing, the Right to data portability, the Right to object to processing, and the Right to withdraw consent. Most of these Rights are not absolute. Below we describe these Rights in more detail and provide information on how you can exercise them. If you make a request to exercise your Rights, we will respond within one (1) month, but have the right to extend this period by two (2) additional months, where necessary. If we extend the response period, we will let you know within one (1) month from your request.
Right of Confirmation.
You have the right to ask the Company to confirm whether or not we process your personal Data. If we confirm we process your personal Data, you have the right to request access to your personal Data (commonly known as a “Data Subject Access Request”) that we process.
Right of Access.
If we confirm we process your personal Data, you have the right to request access to your personal Data (commonly known as a “Data Subject Access Request”) that we process and the following information: the purposes of the processing; (ii) the categories of personal Data we process; (iii) the recipients or categories of recipients of your personal Data; (iv) the envisaged retention period of the Data where possible, or the criteria we use to determine the retention period; (v) your Right to request rectification or erasure of your personal Data, or restriction of the processing of such Data; (vi) your Right to file a complaint with a supervisory authority; (vii) if we have not collected the Data from you, any information we have available about the source of the Data; and (viii) whether we use your personal Data to make any automated decisions that have legal or other similar significant effects on you.
Right to rectification.
You have the right to have the Company correct your personal Data if your personal Data is inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal Data about you completed, including by providing a supplementary statement to the Company.
Right to object to processing for the Company’s legitimate business interests.
You have the right to object to the Company processing your personal Data when that Data is processed on the basis of the Company’s legitimate business interests. The Company will honor your objection and stop processing the relevant personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or (ii) we need to continue processing your personal Data to establish, exercise, or defend a legal claim.
Right to object to processing for direct marketing.
If the Company processes your personal Data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, the Company will stop processing your personal Data for direct marketing purposes.
Right to restrict processing.
You have the right to request the Company restrict the processing of your personal Data in the following circumstances: (i) for the period of time the Company needs to verify the accuracy of your personal Data when you contest its accuracy; (ii) when the processing of your personal Data is unlawful and you oppose the erasure of the Data, and instead request that the Company restrict the use of the data; (iii) when the Company no longer needs your personal Data for the purposes of processing, but you need the Data to establish, exercise, or defend a legal claim; or (iv) for the period of time the Company needs to verify if the Company has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal Data for the Company’s legitimate business interests.
If following your request, the Company restricts the processing of your personal Data, the Company will store your Data, and otherwise process it only with: (i) your consent; (ii) to establish, exercise, or defend a legal claim; (iii) to protect the rights of another natural or legal person; or (iv) for reasons of important public interest of the European Union or a Member State. The Company will also inform you before lifting the restriction of processing.
Right to erasure.
The Right to erasure is also called the “Right to be forgotten.” You may ask the Company to delete your personal Data. This Right not absolute. The Company is required to delete your personal Data upon your request only in the following circumstances: (i) your personal Data is no longer necessary for the purposes for which the Company collected or processed them; (ii) if the Company processes your personal Data on the basis of consent, you withdraw your consent, and no other legal ground exists for the Company to continue processing your personal Data; (iii) if the Company processes your personal Data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for the Company to continue processing your personal Data; (iv) if the Company has processed your personal Data unlawfully; or (v) the personal Data must be erased to comply with a legal obligation under European Union or Member State law to which the Company is subject.
The Company is not required to erase your personal Data to the extent that the Company needs to process them to: (i) exercise its right of freedom of expression and information; (ii) comply with a legal obligation under European Union or Member State law to which the Company is subject; or (iii) to establish, exercise, or defend a legal claim.
Right to data portability:
You have the right to receive personal Data you provided to the Company when: (i) the processing of the Data is based upon your consent or is necessary for the performance of a contract between you and the Company; (ii) the Company’s processing of your personal Data is carried out by automated means; and (iii) complying with your request will not adversely affect the rights and freedoms of others.
If you have the right to receive such personal Data and request the Company provide it, the Company will provide it to you in a structured, commonly used, and machine-readable format.
Right to lodge a complaint with a supervisory authority.
The Company will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live. The overall competent supervisory authority for the Company in Europe is:
Commission for the Protection of Privacy
Rue de la Presse 35, 1000 Brussels
Telephone: +32 (0)2 274 4800
Right to withdraw consent.
You have the right to withdraw your consent to our processing of your personal Data.
Exercise of your rights
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org
You will not have to pay a fee to access your Data (or to exercise any of the rights set forth above). However, we may charge you a reasonable fee, or refuse to comply with your request, if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Data (or to exercise any of your other rights). This is a security measure to ensure that your Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal Data to these websites.
In general, you can visit our Website without telling us who you are or providing us with any information. However, we may collect the IP (Internet Protocol) addresses of all visitors to our Website, and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to monitor and improve our Website and your experience with it.
Rakuten Advertising is a third party that may collect personal information when you interact to the Website, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please see the below links:
You can ask us to stop sending you marketing communications at any time by contacting us at email@example.com.
Privacy Notice for California Residents Pursuant to the California Consumer Privacy Act, as amended
Types of Personal Information we collect
Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, described, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and have collected within the last twelve (12) months), are detailed under the section titled Personal Information that the Company Collects, above.
Please note that, under the CCPA Personal Information does not include: publicly available information from government records and de-identified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by the applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).
Rights of California Residents
If you are a verified California resident, you may have, pursuant to the CCPA and the CalOPPA, the following rights with respect to your personal information collected by the Company, which apply differently in different circumstances: the right to access, the Right to information, the Right to deletion, the Right to correct personal information, the Right to limit the use/restrict the use of sensitive personal information, the Right to opt-out of “sharing” of personal information and the Right to non-discrimination. You may also have the right to appeal the denial of any of these rights by submitting a form that will be provided to you if we deny a data request. Depending on your data choices, certain services may be limited or unavailable. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you are a verified California consumer and make a request to exercise your rights, we will respond within forty-five (45) days, but we have the right to extend this period by forty-five (45) additional days where necessary. If we extend the response period, we will let you know within forty-five (45) days from your request.
Right to Access
You have a right to ask the Company to provide the categories and specific pieces of personal information that we retain about you through your account with us or, at your option, by mail or in a readily usable electronic format. The Company is obligated to respond to no more than two (2) Right-to-Access requests in a twelve (12)-month period. The Right to Access does not apply to information collected by the Company for a single transaction unless you have opted in to allow us to use your Personal Data from a single transaction.
In order to exercise your Right to Access, you may email firstname.lastname@example.org for further instructions.
Right to Information
You have the right to ask the Company to disclose to you: (i) the categories of personal information the Company has collected about you in the twelve (12) months preceding the request and the specific pieces of that personal information, (ii) the categories of sources from which the personal information was collected (iii) the business purpose or commercial purpose for collecting or selling the personal information, (iv) the categories of third parties with whom or which the personal information is shared, (v) the categories of personal information the Company has sold about you and the categories of parties to whom or which the Company sold each category of personal information, and (vi) the categories of personal information that the Company has disclosed about you for a business purpose.
In order to exercise your Right to Information, you may email email@example.com for further instructions.
Right to Deletion
You have the right to ask the Company to delete personal information it has collected about you. The Right to deletion does not apply when the Company needs the personal information: (i) to complete a transaction with you, provide a good or service requested by you, or otherwise perform a contract with you; (ii) to detect or prevent security incidents or illegal activity; (iii) to identify and correct errors that impair existing functionality; (iv) for the exercise of a legal right or to ensure another person can exercise his or her legal right; (v) to comply with the California Electronic Communications Privacy Act; (vi) to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest if deletion of the personal information is likely to make the research impossible or seriously impair it; (vii) solely for internal uses that are reasonably aligned with expectations based on your relationship with the Company; (viii) to comply with a legal obligation; or (ix) for lawful internal uses that are compatible with the context in which the Company obtained the information.
In order to exercise your Right to deletion, you may email firstname.lastname@example.org for further instructions.
Right to Correct
You can update certain information related to your stored preferences and your use of our Website.
In order to exercise your Right to correct, you may email email@example.com for further instructions.
Right to opt-out of sharing of personal information for cross-context behavioral advertising
You will be opted in by default to the sale (as defined under the CCPA) or sharing of Personal Information. You can opt out of the sale or sharing of Personal Information at any time in the following ways. If you are a registered user, your opt out selection will be associated to your registered account and will follow you across devices when logged in. If you do not have an account or are using the Website without logging into your account, you will have to opt out from each browser or device where you access the Website.
In order to exercise your Right to opt-out of sharing of personal information for cross-context behavioral advertising, you may email firstname.lastname@example.org for further instructions.
Right to limit/restrict the use of sensitive personal information
You have the Right to limit or restrict the use of sensitive personal information. The categories of data that we collect and disclose for a business purpose include “sensitive personal information” as defined under the California Privacy Rights Act. We do not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.
In order to exercise your Right to limit or restrict the use of sensitive personal information, you may email email@example.com for further instructions.
Right to Non-Discrimination
We will not discriminate against any consumer for exercising their rights under the CPRA.
Right to data portability
You have the right to receive Specific Pieces of Personal Information we obtained from you. "Specific Pieces of Personal Information" does not include data generated to help ensure security and integrity or as prescribed by regulation. If you have the right to receive such Specific Pieces of Personal Information and request the Company provide it, the Company will provide it to you in a structured, commonly used, and machine-readable format.
How we collect information
Depending upon the nature of your interaction with us, we may collect the above detailed information from you, as follows: (i) directly from you, for example, when you place an order on our Website; (ii) automatically, when you visit our Website; and/or (iii) from third-party business partners such as analytics providers.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
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 and Selling Data
The CCPA defines the terms “sell” and “sale” broadly to include the sharing of Personal Information with third parties for something of value, even if no money has been exchanged. We do not sell Personal Information as the term “sell” is used in every day speech. However, we do “sell” Personal Information as the term is defined in the CCPA.
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
We share your Personal Information with the following categories of third parties:
Disclosures of Personal Information for a business purpose or for selling purposes
In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:
Category A: Identifiers
Category B: Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial Information
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Virginia Consumer Data Protection Act (VCDPA) Notice
Disclosures about the use of your Personal Information
We collect and use your Personal Information as described above.
The Section above titled “Information Sharing” describes how we share or disclose your information with vendors.
In the past twelve months, we have disclosed the following categories of personal data for our business purposes to our advertising, analytics and technology vendors:
Identifiers such as an online identifier or IP address;
Commercial information relating to your use of the Website;
Internet or other electronic network activity information relating to your use of the Website;
Identifiers such as name or email address; and
Residents of Virginia have the following rights: the right to access your data, obtain a portable copy of your data, correct data, or delete data related to your stored preferences and your use of the Website. We may require information to authenticate your identity. The information regarding these Rights is listed under the Rights of California Residentssection above.
Additionally, VCDPA provides Virginia residents with the Right to opt-out of the processing of your personal data for targeted advertising. In order to exercise your Right to opt-out, you may email firstname.lastname@example.org for further instructions.
Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Appeal a Case with regard to your Request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us at email@example.com within 45 days after we notify you of a rejected request, to initiate an appeal of this decision. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied, you may contact the Office of the Virginia Attorney General by these means:
Office of the Attorney General | Virginia.gov
202 North Ninth Street
Richmond, VA 23219