Last Updated: September 4,
2020
STORENAME - Privacy Policy
This Privacy Policy describes how STORENAME, Inc. and its
subsidiaries and affiliates (“STORENAME,” “we,” “us,” and/or “our”) handle
personal data we collect online (through our websites) and offline (through
customer support channels, our retail locations, and in-person promotional
activities). We call all of these the “Services”. This Privacy Policy explains
the types of personal data we collect and process, how we may use and share the
data, and the choices that are available to you with respect to our handling of
your personal data.
Information We Collect
We
collect personal data from you when you provide it to us directly and through
your use of the Site. This information may include:
•
Information you provide to us when you use our Site (e.g. your name, contact
details, gender, product reviews, and any information which you add to your
account profile);
•
Transaction and billing information, if you make any purchases from us or using
our Site (e.g. credit/debit card details and delivery information);
•
Records of your interactions with us (e.g. if you contact our customer service
team, interact with us on social media);
•
Information you provide us when you enter a competition or participate in a
survey;
•
Information collected automatically, using cookies and other tracking
technologies (e.g. which pages you viewed and whether you clicked on a link in
one of our email updates). We may also collect information about the device you
use to access our Site;
•
Other information necessary to provide the Site, for example we may access your
location if you give us your consent.
If
you also shop in one of our stores, we may combine information you give us
in-store (e.g. if you make a purchase or join our mailing list in-store) with
the information above.
Information we collect by
automated means
When you visit our sites, interact with our communications,
or visit our stores, we collect certain information automatically. To collect
this information, we may use cookies, web beacons, and similar technologies. A
“cookie” is a text file that websites send to a visitor‘s computer or other
internet-connected device to uniquely identify the visitor’s browser or to
store information or settings in the browser. A “web beacon,” also known as a
pixel tag or clear GIF, is used to transmit information back to a web server.
We may also collect information about your online activities over time and
across third-party websites. The information we collect automatically may
include:
●
URLs that refer visitors to our
websites;
●
Search terms used to reach our
websites;
●
Details about the emails we send,
such as opens, clicks, and unsubscribes;
●
Details about the devices that are
used to access our websites (such as IP address, browser information, device
information, and operating system information);
●
Details about your interaction with
our websites (such as the date, time, length of stay, and specific pages
accessed during your visits to our websites, referral activity, and which
emails you may have opened);
●
Information about activity in our
stores, such as through closed circuit TVs for security monitoring or
geofencing to identify traffic in our stores; and
●
Usage information (such as the number
and frequency of visitors to our websites).
We may associate this information with your STORENAME account
if you have one, the device you use to connect to our Services, or email or
social media accounts that you use to engage with STORENAME.
For more information about how we use cookies check out our
cookies policy
How We Use Your Information
Depending
on how you use our Site, your interactions with us, and the permissions you
give us, the purposes for which we use your personal data include:
•
To fulfil your order and maintain your online account.
•
To manage and respond to any queries or complaints to our customer service
team.
•
To personalise the Site to you and show you content we think you will be most
interested in, based on your account information, your purchase history and
your browsing activity.
•
To improve and maintain the Site, and monitor its usage.
•
For market research, e.g. we may contact you for feedback about our products.
•
To send you marketing messages and show you targeted advertising, where we have
your consent or are otherwise permitted to do so.
•
For security purposes, to investigate fraud and where necessary to protect
ourselves and third parties.
•
To comply with our legal and regulatory obligations.
We
rely on the following legal basis, under data protection law, to process your
personal data:
•
Because the processing is necessary to perform a contract with you, or take
steps prior to entering into a contract with you (e.g. where you have made a
purchase with us, we use your personal data to process the payment and fulfil
your order).
•
Because we have obtained your consent (e.g. where you contact us with a query,
where you add optional information to your account profile, or if you consent
to receive marketing from us).
•
Because it is in our legitimate interests as an e-commerce provider to maintain
and promote our services. We are always seeking to understand more about our
customers in order to offer the best products and customer experience. We use
information about you to tailor your view of the Site, to make it more interesting
and relevant in respect of the products and offers on view.
Who May Have Access to Your Information
Third-Party Service
Providers:
We may use third party service providers acting on STORENAME’s behalf to
perform some of the services described above. For example, we share certain
information with service providers who assist with the processing of credit
cards and payments, hosting, managing and servicing our data, distributing
emails, conducting research and analysis, advertising, analytics, or
administering certain services and features. We also may share information
about you with our professional advisors, including accountants, auditors,
lawyers, insurers and bankers, if needed. These service providers may change
over time, but we will always use trusted service providers who we require to
take appropriate security measures to protect your personal data in line with
our policies. We only permit them to process your personal data for specified
purposes and, as appropriate, in accordance with our instructions and the
provisions of this Policy and applicable law.
Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services and serve
advertisements on our behalf across the internet and in mobile applications.
They may use cookies, web beacons, and other technologies to collect
information about your use of the Services and other websites and applications,
including your IP address, device ID, web browser, mobile network information,
pages viewed, time spent on pages or in apps, links clicked, and conversion
information. This information may be used by STORENAME and others to, among
other things, analyze and track data, determine the popularity of content,
deliver advertising and content targeted to your interests on our Services and
other websites, and better understand your online activity. For more
information about interest-based ads, or to opt out of having your web browsing
information used for interest-based advertising purposes, please visit
www.aboutads.info/choices. European users may opt out of receiving targeted
advertising through the European Interactive Digital Advertising Alliance.
We may also work with third parties to serve ads to you as
part of a customized campaign on third-party platforms (such as Facebook or
Google). As part of these ad campaigns, we or third-party platforms may convert
information about you, such as your email address, into a unique value that can
be matched with a user account on these platforms to allow us to learn about
your interests and to serve you advertising that is customized to your
interests. Note that the third-party platforms may offer you choices about
whether you see these types of customized ads.
Your Rights and Choices
Managing or deactivating your
STORENAME account
You may review, update, or modify your account information,
including profile, contact, payment and shipping information, at any time by
logging into your STORENAME account. You may also deactivate your STORENAME
account by emailing gTeam@STORENAME.com.
Opting out of email marketing
You may unsubscribe from our promotional emails at any time
by following the instructions included in those emails. If you opt out of
receiving such communications, note that we may continue to send you
non-promotional emails (such as order confirmation emails or emails about
changes to our legal terms).
Restricting cookies
Most web browsers are set to accept cookies by default. You
can usually choose to set your browser to remove or reject browser cookies.
Please note that if you choose to remove or reject cookies, this could affect
the availability and functionality of our websites.
Children
Our Services are not designed for children. If you have
reason to believe that a child has provided personal data to us, please contact
us.
INFORMATION
SECURITY
We work hard to keep your data safe. We use a
combination of technical, administrative, and physical controls to maintain the
security of your data. This includes using Transport Layer Security (“TLS”) to
encrypt many of our Services. No method of transmitting or storing data is
completely secure, however. If you have a security-related concern, please
contact us.
Data Transfers and Privacy Shield
STORENAME is headquartered in the United States, and we have
operations and entities in the United States and other countries. As such, we
may transfer your personal data to, or store or access it in, jurisdictions
that may not provide equivalent levels of data protection as your home
jurisdiction. We will take steps to ensure that your personal data receives an
adequate level of protection in the jurisdictions in which we process it.
When we transfer personal data from the European Union, the
United Kingdom or Switzerland to the United States, we do so in reliance on an
approved data transfer mechanism, such as the Standard Contractual Clauses
adopted by the European Commission. We also comply with the EU-U.S. Privacy
Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by
the U.S. Department of Commerce regarding the collection, use, and retention of
personal data transferred from the European Union and Switzerland to the United
States, respectively (collectively, the “Privacy Shield Principles”). STORENAME
has certified to the Department of Commerce that it adheres to the Privacy
Shield Principles. To learn more about the Privacy Shield program, and to view
our certification, please visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, we are
committed to resolving complaints about our processing of your personal data.
EU, UK and Swiss individuals with inquiries or complaints regarding our
compliance with the Privacy Shield program should first contact us. We have
further committed to refer unresolved Privacy Shield complaints to JAMS, an
alternative dispute resolution provider located in the United States. If you do
not receive timely acknowledgment of your complaint from us, or if we have not
addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to
file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, you may be able to invoke binding
arbitration to resolve your complaint. STORENAME is subject to the
investigatory and enforcement powers of the Federal Trade Commission.
If we share personal data transferred to the U.S. under the
Privacy Shield with a third-party service provider that processes such data on
our behalf, then we will be liable for that third party’s processing in
violation of the Privacy Shield Principles, unless we can prove that we are not
responsible for the event giving rise to the damage.
European Residents
Data Subject Requests
If you are a European Resident, you have the right to access
personal data we hold about you and to ask that your personal data be
corrected, updated, or erased. You may also have the right to object to, or
request that we restrict, certain processing. If you would like to exercise any
of these rights, you may submit a request here. If you have a STORENAME
account, you may also review, update, and delete certain personal data by
logging into your account.
Legal Basis for Processing
If you are a European Resident, we process your personal data
when:
●
We need to use your personal data to
perform our responsibilities under our contract with you (e.g., processing
payments for and providing the STORENAME products you have ordered).
●
We have a legitimate interest in
processing your personal data. For example, we may process your personal data
for performance marketing activities, to conduct data analytics and to provide,
secure, and improve our Services.
●
We need to do so to comply with a
legal obligation to which we are subject.
●
We need to do so to protect your
vital interests or those of others.
●
We have your consent to do so, which
you may withdraw at any time.
Data Subject Requests
If you are a European Resident, you have the right to access
personal data we hold about you and to ask that your personal data be
corrected, updated, or erased. You may also have the right to object to, or
request that we restrict, certain processing. If you would like to exercise any
of these rights, you may submit a request via email contact@STORENAME.com . If you have a STORENAME account,
you may also review, update, and delete certain personal data by logging into
your account.
Questions or Complaints
If you are a European Resident and have a concern about how
we process personal data that we are not able to resolve, you have the right to
lodge a complaint with the data privacy authority where you live. For contact
details of your relevant local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm or, if you are a resident of
Switzerland, https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/.
California Privacy Rights
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code
§ 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83)
afford consumers residing in California certain rights with respect to their
personal data. If you are a California resident, this section applies to you.
California Consumer Privacy
Act
The CCPA requires us to disclose the following information
with respect to our collection, use, and disclosure of personal data. In the
preceding 12 months, we have collected the following categories of personal
data: identifiers; commercial information; demographic information (note that
some demographic information may be considered characteristics of protected
classifications under state or federal law); internet or electronic network
activity; geolocation data; audio, electronic, visual, thermal, olfactory, or
similar information; inferences; and other categories of personal data that
relates to or is reasonably capable of being associated with you. For examples
of the precise data points we collect, please see “Information We Collect”
above. We collect personal data for the business or commercial purposes
described in the “How We Use Your
Information” section above. In the preceding 12 months, we have disclosed
the following categories of personal data for business to the following
categories of recipients:
|
Category of Personal Data |
Categories of Recipients |
|
Identifiers |
Advertising networks, marketing
partners, data analytics providers, market research platform, payment
processors, fulfilment partners, customer support partners, Internet service
providers, operating systems and platforms, other users, fraud prevention
partners, cloud service providers, technical maintenance and system security
providers |
|
Commercial Information |
Data analytics providers,
advertising networks, marketing partners, market research platform, payment
processors, fulfilment partners, customer support partners, and fraud
prevention partners, cloud service provider |
|
Characteristics of Protected
Classifications under state or federal law, such as age |
Advertising networks, marketing
partners, market research platform, other users, customer feedback platforms |
|
Internet or other electronic
network activity |
Advertising networks, marketing
partners, data analytics providers, Internet service providers, operating
systems and platforms, cloud service providers, fraud prevention partners,
technical maintenance and system security providers |
|
Geolocation data |
Advertising networks, marketing
partners, data analytics providers, Internet service providers, operating
systems and platforms |
|
Audio, electronic, visual, or
similar information |
Customer support partners, market
research platform, facility security partners |
|
Inferences |
Advertising networks, data
analytics providers, customer support partners, fraud prevention partners,
cloud service providers |
STORENAME does not sell your personal data. We do allow our
advertising partners to collect certain device identifiers and electronic
network activity via our Services to show ads that are targeted to your
interests. To opt out of having your personal data used for targeted
advertising purposes, please see the Advertising
and Analytics Services Provided by Others section above.
Subject to certain limitations, California consumers have the
right to (1) request to know more about the specific pieces and categories of
personal data we collect, use, and disclose, (2) request deletion of their
personal data, and (3) opt out of any “sales” of your personal data that may be
occurring, and (4) not be discriminated against for exercising these rights.
You may make a request to know more about or delete your personal data by
emailing privacy@STORENAME.com. Additionally, access requests can be made by
calling 1-855-929-2179. We will verify your request by contacting you after
receiving your request to verify your identity. Please note that we may retain
certain information as required or permitted by applicable law. If you request
to delete your personal data, certain of our products and services may no
longer be available to you.
If we receive your request from an authorized agent, we may
ask for evidence that you have provided such agent with a power of attorney or
that the agent otherwise has valid written authority to submit requests to
exercise rights on your behalf.
We offer various financial incentives. For example, we may
provide discounts or other benefits to customers who sign up to receive our
marketing emails. When you participate in a financial incentive, we collect
personal data from you, such as identifiers like your name and email address.
You can opt into a financial incentive by following the sign-up instructions,
and you have the ability to opt-out of the incentive by contacting us. In some
cases, we may provide additional terms and conditions for a financial
incentive, which we will provide to you when you sign up. The value of your
personal data is reasonably related to the value of the offer or discount
presented to you.
Shine the Light
California law permits residents of California to request
certain details about how their information is shared with third parties for
direct marketing purposes or to opt out of such sharing. We do not share your
personal data with third parties for their own direct marketing purposes.
Links to Other Websites and Third-Party Content
We may provide links to third-party websites, services,
plug-ins and applications, such as Facebook and Google, that are not operated
or controlled by STORENAME. This Privacy Policy does not apply to such
third-party services, and we cannot take responsibility for the content,
privacy policies, or practices of third-party services. We encourage you to
review the privacy policies of any third-party services before providing any information
to or through them.
The Services may offer social sharing features and other
integrated tools (such as the Facebook "Like" or "Share"
button or the Twitter “Tweet” button) which let you share actions you take on
our Services with other media. Your use of such features enables the sharing of
information with your friends or the public, depending on the settings you
establish with the entity that provides the social sharing feature. For more
information about the purpose and scope of data collection and processing in
connection with social sharing features, please visit the privacy policies of
the entities that provide these features.
Data Retention
Our retention periods for personal data are based on business
needs and legal requirements. We retain personal data for as long as is
necessary for the processing purpose(s) for which the data was collected, and
any other permissible, related purpose. For example, we may retain certain
transaction details and correspondence until the time limit for claims arising
from the transaction has expired. When we no longer need to use your personal
data, it is removed from our systems and records or anonymized so that you can
no longer be identified from it.
Changes to Our Privacy Policy
We may change this Privacy Policy from time to time. If we do
so, we will post the updated policy on our sites and will indicate when the
Privacy Policy was last revised. If we make any material changes, we will
provide you with additional notice. You should periodically review our current
Privacy Policy to stay informed of our personal data practices.
Contacting STORENAME
If you
have questions about this policy, or need help exercising your privacy rights,
please contact our Data Protection Officer at data-protection-office@STORENAME.com.
STORENAME, Inc. 233 Spring Street, Floor 10 New York, NY
10013 Privacy@STORENAME.com
Customers in the EU may contact: Phase EU Limited 5 New
Street Square London, United Kingdom, EC4A 3TW Privacy@STORENAME.com