Last updated: June 1, 2020.
- Our social media pages on third-party social media platforms (collectively, our “Social Media Pages”);
- Offline business interactions you have with us.
Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.”
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
- Postal address (including billing and shipping addresses);
- Telephone number;
- Email address;
- IP address (we may also derive your approximate location from your IP address);
- Account information, such as username and password; and
- Payment card data.
COLLECTION OF PERSONAL INFORMATION
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
- We collect Personal Information through the Services, for example, when you sign up to receive updates, special promotions or newsletters from us, register an account to access the Services, visit our stores, attend one of our events, contact customer service, place an order over the phone, or make a purchase.
- From Other Sources
- publicly available databases;
- joint marketing partners, when they share the information with us; and
- surveys in which consumers elect to participate.
- We receive your Personal Information from other sources, for example:
USE OF PERSONAL INFORMATION
We and our service providers use Personal Information for the following purposes:
- Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments, or complaints.
- To complete your transactions, verify your information, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials.
- To send you marketing related emails, with information about our services, new products, and other news about our company.
- We will engage in this activity with your consent or where we have a legitimate interest.
Analyzing Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
- We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
Allowing you to participate in sweepstakes, contests or other promotions.
- We may offer you the opportunity to participate in a sweepstakes, contest, or other promotion.
- Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
- We use this information to manage our contractual relationship with you
Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
DISCLOSURE OF PERSONAL INFORMATION
We disclose Personal Information:
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email/FFL delivery, auditing, and other services.
- To third party sponsors of sweepstakes, contests, and similar promotions.
By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
OTHER USES AND DISCLOSURES
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- This may include laws outside your country of residence.
- To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is necessary or appropriate.
- These can include authorities outside your country of residence.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- Browser and device information;
- Information collected through cookies, pixel tags and other technologies;
- Demographic information and other information provided by you that does not reveal your specific identity; and
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
COLLECTION OF OTHER INFORMATION
We and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device.
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Through cookies.
- Through pixel tags and other similar technologies.
- Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- Physical Location.
- We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
USES AND DISCLOSURES OF OTHER INFORMATION
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from receiving marketing-related emails from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by using the opt-out mechanism contained in each such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the California Consumer Privacy Act of 2018 (“CCPA”).
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
- The criteria used to determine our retention periods include:The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
THIRD PARTY PAYMENT SERVICE
ADDITIONAL INFORMATION REGARDING THE EEA
You may also lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.
ADDITIONAL INFORMATION REGARDING CALIFORNIA
Pursuant to the CCPA, we are providing the following chart detailing which categories of Personal Information about California residents (other than employees, job applicants, contractors, dependents or beneficiaries) we collect, disclose, and/or sell.
|Category of Personal Information||Collected?||Disclosed?||Sold?|
|A. Identifiers, such as name, contact information, IP address, and other online identifiers.||Yes||Yes||Yes|
|B. Financial information, including payment card number.||Yes||Yes||No|
|C. Commercial information, such as transaction information and purchase history.||Yes||Yes||No|
|D. Internet or network activity information, such as browsing history and interactions with our website.||Yes||Yes||Yes|
|E. Geolocation data, such as device location.||Yes||Yes||Yes|
|F. Audio, electronic, visual, similar information, such as call and video recordings.||Yes||Yes||No|
|G. Professional or employment-related information.||Yes||Yes||No|
|H. Characteristics of protected classifications under California or federal law, such as sex, age, and marital status.||No||No||No|
|I. Biometric information, such as fingerprints and voiceprints.||No||No||No|
|J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.||No||No||No|
|K. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.||No||No||No|
In addition to the Personal Information listed above, we also collect and disclose the following Personal Information from employees, independent contractors, owners, directors, officers and job applicants, as well as their emergency contacts, dependents and beneficiaries, for purposes of operating, managing, and maintaining our business, managing our workforce (including recruitment), and administering benefits:
|Category of Personal Information||Collected?||Disclosed?||Sold?|
|A. Identifiers, such as Social Security numbers and other government-issued ID numbers;||Yes||Yes||No|
|B. Personal information, as defined in the California customer records law, such as health and health insurance information||Yes||Yes||No|
|C. Characteristics of protected classifications under California or federal law, such as race, religion, national origin, disability, request for leave, citizenship and immigration/work authorization status;||Yes||Yes||No|
|D. Professional or employment-related information, such as information relating to references, CV, details of qualifications, human resources data and data necessary for benefits and related administration services; and||Yes||Yes||No|
|E. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.||Yes||Yes||No|
As described in detail above, under “Collection of Personal Information,” we collect this Personal Information from you and from other categories of sources, such as our joint marketing partners. Also as described in detail above, under “Use of Personal Information,” we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.
As described in detail above, under “Disclosure of Personal Information,” we share Personal Information with other entities such as our affiliates and third-party service providers.
Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, to administer offers and events, for our employment and vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products, services, and offers; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
We share Personal Information with our affiliates, service providers, third-party sponsors of sweepstakes, contests, and similar promotions, and our business partners.
If you are a California resident, you may request that we:
- (1) Disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting or selling (if applicable) Personal Information about you; and
- The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information (if applicable);
- The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
- (2) Delete Personal Information we collected from you.
- (3) Opt you out of any future “sale” of Personal Information about you.
To make a request for the disclosures or deletion described above, please contact us in accordance with the “Contacting Us” section above. We will respond to your request consistent with applicable law.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
If you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by contacting us in accordance with the “Contacting Us” section above. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.