Privacy Policy
Last Updated: April 26, 2024
This Privacy Policy does not apply to Personal Data collected when you purchase our products in store locations that are not official Sperry stores or on third-party websites where our products are available for sale. Also, this Privacy Policy does not pertain to the collection of Personal Data within an employment setting, such as information gathered from job applicants.
The term ‘’Personal Data’’ means any information about you through which you can be identified (including where you can be identified by combining the information with other information available to us) and includes the definitions of “personal data” and “personal information” used in applicable domestic and foreign data protection or privacy laws.
Local-specific amendments referred to in this Privacy Policy also apply to consumers in those territories and may in some cases set out different standards due to applicable local legislation. If so, the local-specific provisions will govern in the event of a conflict.
By using the Services, agreeing to our Terms of Use, or reaching out to us and sharing Personal Data, you agree to allow us (or our service providers acting on our behalf) to collect and use Personal Data as outlined in this Privacy Policy, along with the Terms of Use. We retain the right to revise this Privacy Policy at any time, in whole or in part, at our discretion and without prior notice. Should we make changes or amendments to this Privacy Policy, they will be posted on this page.
About Us
The Company owns the intellectual property rights to the Sperry brand, and we have partnered with The Aldo Group Inc. (“Aldo”) to provide the Services, including the day-to-day operation of the Sperry website and In-Store Services. While ABG is the “controller” of your Personal Data (or similar term under applicable law), Aldo carries out certain of the data processing activities described in this Policy on our behalf as our “processor” or “service provider” (as defined by applicable laws).
If you are accessing a Sperry website outside of the United States and Canada, please refer to the specific privacy policy that applies to your region, as posted on such site.
1. Section 1 – General Provisions
This section of our Privacy Policy describes the general provisions applicable to all our data processing activities, whether for your online activities, marketing activities or when you shop in our stores.
Information We May Collect
We collect Personal Data about you from a variety of sources, and the categories of Personal Data we collect depend on your activity and interactions with us.
Below is a summary of the categories of Personal Data that we may collect about you, along with the potential source(s) from which we collect them.
| Personal Data Categories | What does this Personal Data Category include? | Where can we collect this Personal Data Category from? |
|---|---|---|
| Basic Data | We collect information such as your first name, last name, middle name, maiden name, nickname, suffix, title, date of birth, birth year, age category, sex/gender. | Directly from you*, Automatically about your use of the Services**, Other sources*** |
| Contact Data | We collect contact information such as address type, primary (yes/no), street, number, city, zip/postal code, province, state, region, country, territory, email address, phone number, phone number type, primary phone number (yes/no). | Directly from you, Other sources |
| Identification Data | We may collect certain type of identification document (e.g., passport, national ID Card), document number, expiration date, date of issue. | Directly from you |
| Account Data | We collect certain account identifiers and other related data such as your Loyalty ID, username and password, answers to security questions. | Directly from you |
| Survey & Customer Input Data | We collect information such as your nationality, ethnicity, generation, marital status, family status, economic status, as well as product reviews, participation in polls or surveys, comments, requests and questions, or information included in the relevant chat, email, or other communication with us. We may also collect information about your favorite products, collection preference (e.g., Men’s / Women’s), your reactions to our marketing campaigns. | Directly from you |
| Purchase Data | We collect purchase and return history, transaction ID, shipping information, saved check-out information (cart items). | Directly from you |
| After-Sales Data | If you purchase a product and/or seek after-sale support, we may collect Personal Data such as customer ID, transaction number, ticket/case ID, tracking number ID, proof of purchase, date of purchase, and product name. | Directly from you |
| Communications | We may collect data on your language or communication language. | Directly from you |
| Image Data (this may be categorized as biometric data depending on the jurisdiction) | We may collect photographs taken at events, submitted by you or when you visit our stores, photographs associated with your social media accounts, or when you provide us with your images for specific Services (i.e., foot images) and their associated metadata. | Directly from you, Automatically about your use of the Services (provided, however, that we do not automatically collect Image Data for Online Services and Marketing Services) |
| Surveillance & Security Data | We collect images from surveillance and security cameras at our stores; if such surveillance and security cameras are in use at our stores, and where legally required, we will ensure that signs are displayed at the entrance of the surveillance zone to alert employees, guests, and contractors their image may be recorded. | Automatically about your use of the Services |
| Device and Network Data | We collect technical data collected from your computer or mobile device, such as your IP address, longitude and latitude, browser type and version, operating system. | Automatically about your use of the Services |
| Log & Usage Data | We collect browser type and version, operating system and interface, used device, language preference, the website from which you are visiting us (referrer URL), webpage(s) you are visiting on the Online Services, date and time of your visit, IP address or part of IP address, your history navigation, your interaction with the live chat features including a recording of any such sessions (which may be shared with third parties), the pages you access before and after accessing the Services, search terms, search history, and frequency of use of the Services. | Automatically about your use of the Services, Other sources |
| Location Data | We may collect your approximate location information based on your IP address. | Automatically about your use of the Services |
| Marketing Data (Information collected when you subscribe to a newsletter or other marketing communication) | We may collect your email address, collection preference, consent to receive communications. | Directly from you |
| Third-Party Data | We may collect Personal Data about you from third-party partners or instruct such third-party partners to provide their own Personal Data about you to external platforms in order to enhance existing or new features on our or to perform brand monitoring. | Other sources |
| Social Media Data | We may collect information when you use the Online Services which is processed by external social media providers. | Other sources |
| Derived Data | We may collect information about you that is derived from other types of Personal Data we collect to draw inferences, including your preferences, interests, and other characteristics. | Directly from you, Other sources |
| As used in this table, we may collect Personal Data directly from you when you contact us by email or shop with us. As used in this table, we may collect Personal Data automatically about your use of the Services, including data collected from cookies and other similar. As used in this table, we may collect Personal Data about you from other sources, including commercially available sources, such as public data bases (where permitted by law) and analytics and marketing partners. |
|---|
How We Use Your Personal Data and the Legal Bases on Which We Use It
We may process your Personal Data for the purposes outlined below. Under certain data protection laws, we must have a legal basis to process your Personal Data. In most cases, the legal basis will be one of the following: your consent; the necessity to carry out a contract with you; a legal obligation; and/or our overriding legitimate interest.
| Processing Purpose | Categories of Personal Data Processed | Legal Basis |
|---|---|---|
| Identification and authentication: We use your identification details to verify or authenticate your identity when you use our Services and to ensure the security of your Personal Data. This allows us to comply with our contractual obligations to you. | Basic Data, Contact Data, Account Data, After-Sales Data | Contract, Consent |
| Operating the Services: We process your Personal Data to provide the Services you have requested. This allows us to comply with our contractual obligations to you | Basic Data, Contact Data, Account Data, Survey & Customer Input Data, Social Media DataImage Data, Purchase Data, After-Sales Data, Log & Usage Data, Device and Network Data | Contract, Consent |
| Improving our Services: We analyze information about how you use our Services to provide an improved experience for our customers of all our Services, including product testing and site analytics. It is in our legitimate business interests to use the data provided to us for this purpose, so we can understand any issues with our Services and improve them. | Basic Data, Account Data, Survey & Customer Input Data, Marketing Data, Third-Party Data, Derived Data | Legitimate Interests, Consent |
| Communicating with you: We use your Personal Data when we communicate with you, for example, if we are providing information about changes to the terms and conditions; if you contact us with questions; or for sending you newsletters and other publications. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Services. | Basic Data, Contact Data, Account Data, Survey & Customer Input Data, Communications | Legitimate Interests, Consent |
| Marketing: We use your Personal Data to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide more relevant and interesting advertising messages. Where required by law, we will obtain your consent before sending such marketing messages. | Basic Data, Contact Data, Communications, Survey & Customer Input Data, Marketing Data, Third-Party Data, Derived Data | Legitimate Interests, Consent |
| Exercising our rights: We use your Personal Data to exercise our legal rights where it is necessary to do so, for example, to detect, prevent and respond to claims of fraud, intellectual property infringement claims or violations of law or our standards of conduct, or our terms of use. | Basic Data, Contact Data, Account Data, Communications, Surveillance & Security Data | Legitimate Interests |
| Complying with our obligations: We process your Personal Data to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, as required by law. | Basic Data, Contact Data, Account Data, Identification Data, Survey & Customer Input Data | Legal Obligation |
| Customizing your experience: When you use the Services, we use your Personal Data to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests. It is in our legitimate interests to provide you with a customized experience. | Basic Data, Account Data, Device and Network Data, Log & Usage Data, Survey & Customer Input Data, Marketing Data, Third-Party Data, Derived Data | Legitimate Interests, Consent |
| Creating custom audience lists: We generate custom audience lists using email addresses that are provided to us. This entails sharing hashed identifiers, such as email addresses, with social media platforms, which then compare them with associated user data. Through this procedure, we can display advertisements on these platforms that are more pertinent and tailored to your interests. | Basic Data, Account Data, Survey & Customer Input Data, Marketing Data, Third-Party Data, Derived Data | Legitimate Interests, Consent |
| Keeping our records accurate and up-to-date: This processing is necessary to comply with legal obligations and to serve our legitimate interests in efficient management and administration. | Basic Data, Contact Data, Account Data, Identification Data | Legal Obligation, Legitimate Interests |
To Whom We May Disclose Your Personal Data
We may disclose any of the categories of Personal Data described above to the following categories of persons:
– Our service providers, including vendors, consultants, and other service providers who perform services or functions on our behalf, for business purposes. For example, our service providers include companies that support us with marketing, sales, consulting, communications, software maintenance and support, web services, analytics, social media, market research, auditing, security, user verification, localization, and payment processing.
– Our group companies, as we work closely with other businesses and companies that fall under our group family. We may share certain information about, for example, browsing history on our websites for marketing purposes or internal reporting.
– Our business partners, in order to facilitate your relationship with us or for any of the purposes described in our or those business partners’ privacy policies. Such business partners may include:
- Advertising networks
- Data analytics providers
- Social networks
- Data brokers
- Joint marketing partners
– Law enforcement agencies, courts, other government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
– Potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell or transfer all or a portion of our assets or business.
In some cases, we may share your information with third parties who may use your information for their own purposes, including for purposes of marketing and advertising. These disclosures may be considered “sales” or “targeted advertising” under applicable privacy laws, even where no money is exchanged. For more information, please see the “Your Rights Over Your Personal Data” section or, if you live in California, the Disclosure of Personal Information subsection in the “Additional Disclosures for Residents of California” section of this Policy.
Additionally, there are cases where the recipients referred to above may be located outside the jurisdiction in which you are located. See the “International Data Transfers” section below for more information.
Your Rights Over Your Personal Data
Depending on where you reside, and subject to certain exceptions, you may have the following rights with respect to your Personal Data:
– Access: You may have the right to request that we confirm whether we process your Personal Data and that we provide you access to such Personal Data.
– Data Portability: You may have the right to request that we provide a copy of your Personal Data in a portable and, to the extent technically feasible, readily usable format. You may also have the right to have your Personal Data transmitted directly to another controller, where technically feasible.
– Correction/Rectification: You may have the right to request that we correct inaccuracies in the Personal Data that we process.
– Deletion/Erasure: You may have the right to request deletion of your Personal Data.
– Opt Out of Sales and Targeted Advertising: You may have the right to request that we not process your Personal Data for the purposes of targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects, as those terms are defined under applicable local law.
– Opt Out of Profiling: You may have the right to request that we not process your Personal Data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects.
– Withdraw Consent: Where you have previously given your consent to the processing of your Personal Data, you may have the right to withdraw your consent at any time.
– Object to Processing: You may have the right to object to our processing of your Personal Data.
– Restrict Processing: You may have the right to restrict our processing of your Personal Data.
– Lodge a Complaint: We are committed to working with you to obtain a fair resolution of any complaint or concern about our processing of your Personal Data. However, you may have the right to lodge a complaint with the appropriate data protection authority.
You may opt out of sales and/or targeted advertising by clicking here and following the instructions: [LINK: Do Not Sell or Share My Personal Information]. Where required, we also honor requests to opt-out submitted via privacy preference signals recognized under applicable local law, such as the Global Privacy Control (GPC).
You may submit requests to exercise your other rights by contacting us at the information provided in the “Contact Us” section below. Please include the phrase “Personal Data Privacy Request” in the subject line. In order for us to verify your request, we need to verify your identity, so the request should include your name, address, and email address, along with a clear indication of the right(s) you wish to exercise. Please note that we may require additional information from you in order to honor your requests.
Depending on where you reside, you may also use an authorized agent to act on your behalf to submit requests to exercise your rights. We will honor a request from an authorized agent provided that (i) you provide written authorization to the authorized agent to act on your behalf and we can verify your identity, and (ii) the agent submits proof of authorization. Authorized agents may use the same methods noted above to submit requests on your behalf.
You may also have the right to appeal a refusal to take action on your request. You can submit an appeal using the same information provided in the “Contact Us” section below.
How We Handle “Do Not Track” Requests
We do not currently respond to web browser “Do Not Track” requests. For more information about these signals, please visit www.allaboutdnt.org.
International Data Transfers
Depending on your location, your Personal Data may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for Personal Data under the laws of your country.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to help protect your Personal Data. For more information on the appropriate safeguards in place, please contact us using the details below.
Information Security and Retention
We implement technical and organizational measures designed to ensure a level of security appropriate to the risk to the Personal Data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Data. We evaluate these measures on a regular basis to help safeguard Personal Data we process.
We will retain your Personal Data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your Personal Data for a period of time that enables us to:
- Comply with record retentions requirements under applicable law
- Meet our legal obligations including financial, accounting, tax, or export obligations
- Defend or bring any existing or potential legal claims
- Maintain business records for internal purposes, such as in connection with analyses or audits
- Enforce security standards and protect against unauthorized access or fraud
- Resolve or otherwise address any complaints or queries relating to the Services
We will delete your Personal Data when it is no longer required for these purposes. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the data.
Section 2 – Online Services & Marketing Services
This section of our Privacy Policy contains additional provisions applicable to our Personal Data processing activities for Online Services and Marketing Services.
What are Cookies and Similar Technologies?
Like many other websites, when you visit us online or otherwise engage with us digitally, we and our third-party partners use cookies and other automated tools to collect information about how you interact with our Services. Those automated tools may also gather data regarding your activities across different digital services provided by us or others, spanning over time.
The tracking tools and technologies that we or our third-party partners may use include:
- Cookies. A cookie is a small text file that is placed on your browser or your computer when you use the Online Services. Cookies may store information such as your IP address, device ID or other identifiers, your browser type, and information about the content you view and interact with. They do not affect your device but are widely used to make websites work properly or work more efficiently. Some of the cookies we use are essential for the Online Services to work. We also use some non-essential cookies to make informed decisions about improvements to the Online Services and their content.
- Web beacons; Pixels. Web beacons and pixels are small electronic images embedded in websites and emails to gather data on user interaction with content. They assist us in assessing the efficacy of our communications and marketing endeavors and in evaluating user engagement with our Online Services and Marketing Services. Additionally, web beacons may be employed by certain third-party providers to monitor activity on our Online Services, including the pages visited, links clicked, and the content you viewed.
- Server logs. Server logs are records which are generated by a server and collect information about various log activities such as the device, browser, operating system, and network you use to access our Online Services.
- Application software. Software utilized within our mobile and other connected-device applications, which gathers data regarding your interactions with the Online Services.
The Types of Cookies We Use
Generally speaking, we use first and third-party session and persistent cookies. The cookies set by us are called “first-party cookies” and the cookies set by our third-party partners and service providers are called “third-party cookies.”
Session cookies are temporary cookies that remain on your device until you close your web browser. Many session cookies are essential to make our websites work correctly, as they typically enable you to move around our Online Services and use our features.
Persistent cookies remain on your device after you close your browser or until you manually delete it (in the former case, how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings). Persistent cookies help us recognize you as an existing user of our Online Services, so that it’s easier and more convenient for you to return to, or to interact with, our Online Services without signing in again. In addition, persistent cookies also help us recognize you when you view a resource belonging to our Online Services from another website or app (such as an advertisement) and help us record information about your web browsing habits during the lifetime of the persistent cookie.
Below is a detailed list of the cookies we use on the Online Services:
– Strictly Necessary Cookies
These cookies are necessary for the Online Services to function and cannot be switched off in our systems. They are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the site will not work.
– Performance Cookiess
Where you have permitted the use of performance cookies, we collect statistical information about how our Online Services are used. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the Online Services. They help us to know which pages are the most and least popular and see how visitors move around the Online Services. If you do not allow these cookies, we will not know when you have visited the Online Services and will not be able to monitor the Online Services’ performance.
– Functional Cookies
Functional cookies are used to create technologically advanced and user-friendly websites that adapt automatically to your needs and preferences. These cookies enable the Online Services to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
– Targeting Cookies
These cookies may be set through the Online Services by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.
Certain features on the Online Services (for example, links to third-party websites), may be offered by third parties or direct you to third parties when you use such features. These third parties may collect Personal Data about you when you use such features. Please be aware that the Company is not responsible for the way in which these third parties handle your Personal Data. We advise you to read the privacy and cookie notices of these third parties to understand how and why they use of your Personal Data, including their use of cookies and tracking technologies.
If you access our Online Services by clicking through from another website, certain information you provided to that website, such as the search terms used to reach our Online Services, may be transmitted to us and we may collect such information in line with this Privacy Policy. You may review the privacy policy of any such website through which you accessed our Online Services to understand the information collected by those third-party website operators.
How You Can Manage Cookies
When you first visit the Online Services, you will be presented with a banner that offers you a choice about whether to accept or reject different types of non-essential cookies. You can change your cookie preferences at any time by clicking on the “Cookie Preferences” button in the footer of this Site.
You can also change your cookie settings via your browser settings. You can find information on how to manage cookie settings on certain browsers via the following links
If you change your cookie settings in your browser or change your cookie preferences directly via the Online Services, your experience with the Online Services may be affected.
How We Use Your Personal Data for Digital Marketing and the Legal Bases on Which We Use It
We may process your Personal Data in connection with digital Marketing Services for the purposes outlined below, to the extent permitted by applicable law.
| Processing Purpose | Categories of Personal Data Processed | Legal Basis |
|---|---|---|
| Personalized Experience: We may use your Personal Data to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide more relevant and interesting advertising messages. Where required by law, we will obtain your consent before sending such marketing messages. | Basic Data, Contact Data, Communications, Survey & Customer Input Data, Advertising Preference Data | Legitimate Interests, Consent |
Section 3 – In-Store Services
This section of our Privacy Policy contains additional provisions applicable to our Personal Data processing activities for In-Store Services.
Collection of Surveillance & Security Data
Surveillance & Security Data is collected to view and recorded individuals at our stores. Where CCTV is used at our stores, and where legally required to do so, we will ensure that signs are displayed of the surveillance zone to alert employees, gest and other visitors that their images may be recorded.
How We Use Your Personal Data and the Legal Bases on Which We Use It
We may process your Personal Data for the purposes outlined below.
| Processing Purpose | Categories of Personal Data Processed | Legal Basis |
|---|---|---|
| Security-related purposes: To protect individuals as well as our property and assets, prevent, repress and prosecute crimes and offenses; To prevent or detect crime and protect buildings and assets from damage, disruption, theft, vandalism and other crime; For the personal safety of employees, guests and contractors and other members of public and to act as a deterrent against crime; To support any internal investigations in relation to the above; and For measurement and analysis of client’s movements. | Surveillance & Security Data | Legitimate Interests |
Section 4 – Local Requirements
Additional Disclosures for Residents of California
This section applies to the personal information of residents of California and supplements the other sections of the Privacy Policy.
In this section, the terms “personal information” and “sale” or “sell” have the same definitions as in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).
Collection and Use of Personal Information
We may collect personal information directly from you, automatically from your devices when using the Services, or from third-party sources, as described in the “Information We Collect” section above. We have collected the following categories of personal information about you in the past 12 months:
- Identifiers, such as name, postal address, email address, phone number, IP address, and account login credentials, or other similar identifiers
- Characteristics of protected classifications under California or federal law, such as racial/ethnic origin, sex/gender, and age
- Commercial information, such as products or services purchased, or other purchasing or consuming histories or tendencies
- Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website application or advertisement
- Geolocation data, such as approximate geolocation based on your IP address
- Audio, electronic, visual, thermal, olfactory, or similar information, such as your foot images or photos of you at events or in our stores
- Inferences drawn from other personal information, such as a profile reflecting your preferences, behavior, or interests
We also have collected “sensitive personal information,” as defined by the CCPA, in limited circumstances: when you complete a survey, you may choose to provide your race or ethnic origin or other protected class characteristics; when you create a Sperry account, we collect your username, password, and credentials to access that account; when you file an incident report in one of our stores, we may collect information about your health or physical condition as relevant to the incident; and when you indicate you are tax-exempt, we will ask for your tax ID or relevant information to support this status. Please note that we only use and disclose sensitive personal information for purposes permitted by California law.
For more information about the purposes for which we collect and use your personal information, please refer to the “How We Use Your Personal information and the Legal Bases on Which We Use It” and “How We Disclose Your Personal information” sections of this Policy.
Disclosure of Personal Information
We may disclose your personal information to third parties for the business purposes outlined in the “How We Disclose Your Personal information” section of this Policy. While we do not sell your personal information in exchange for money, our Online Services and Marketing Services use cookies and similar technologies in ways that are considered “sales” or “sharing” under the CCPA (and other U.S. state privacy laws) even though no money changes hands and no payments are made (see Section 2 above for more details about cookies and similar technologies).
In the preceding twelve (12) months, we may have “sold” or “shared” your personal information, or disclosed it for a business purpose, to the following categories of recipients:
| Categories of Personal Information | Categories of Service Providers to whom we Disclosed Personal Information for Business Purposes | Categories of Third-Parties to whom we Sold or Shared Personal Information |
|---|---|---|
| Identifiers | Advertising networks, Vendors and providers that help us provide the Online Services to you, Labelling and shipping service providers, Internet service providers, Data analytics providers, Law enforcement agencies, courts, other government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, Providers of operating systems and platforms, Payment processors, Banks, entities providing financing or provide identity and purchase verification for your purchases, Social networks, Marketing partner, Providers for text messaging | Advertising networks, Vendors and providers that help us provide the Online Services to you, Data analytics providers, Social networks, Data brokers, Joint marketing partners |
| Characteristics of protected classifications under California or federal law | Advertising networks, Vendors and providers that help us provide the Online Services to you, Labelling and shipping service providers, Internet service providers, Data analytics providers, Providers of operating systems and platforms, Payment processors, Banks, entities providing financing or provide identity and purchase verification for your purchases, Social networks, Marketing partners, Providers for text messaging | N/A |
| Commercial information | Advertising networks, Vendors and providers that help us provide the Online Services to you, Labelling and shipping service providers, Internet service providers, Data analytics providers, Providers of operating systems and platforms, Payment processors, Banks, entities providing financing or provide identity and purchase verification for your purchases, Social networks, Marketing partners | N/A |
| Internet or other electronic network activity information | Advertising networks, Vendors and providers that help us provide the Online Services to you, Internet service providers, Data analytics providers, Providers of operating systems and platforms, Payment processors, Banks, entities providing financing or provide identity and purchase verification for your purchases, Social networks, Marketing partners, Providers for text messaging | Advertising networks, Vendors and providers that help us provide the Online Services to you, Data analytics providers, Social networks, Data brokers, Joint marketing partners |
| Approximate geolocation data (based on your IP address) | Law enforcement agencies, courts, other government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, Vendors and providers that help us provide the Online Services to you, Payment processors, Banks, entities providing financing or provide identity and purchase verification for your purchases, Advertising networks, Data analytics providers, Providers of operating systems and platforms, Marketing partners | Advertising networks, Vendors and providers that help us provide the Online Services to you, Data analytics providers, Social networks, Data brokers, Joint marketing partners |
| Audio, electronic, visual, thermal, olfactory, or similar information | Law enforcement, government authorities, and others as deemed reasonably necessary to comply with applicable law or investigations | N/A |
| Inferences drawn from other personal information | Advertising networks, Vendors and providers that help us provide the Online Services to you, Data analytics providers, Marketing partners, Providers for text messaging | Advertising networks, Vendors and providers that help us provide the Online Services to you, Data analytics providers, Data brokers, Joint marketing partners |
| Sensitive personal information | Vendors and providers that help us provide the Online Services to you, Data analytics providers, Providers of operating systems and platforms, Marketing partners | |
Children’s Privacy
Our Online Services are general audience sites, and it is our intention that they should only be used only by persons over the age of 16. We do not knowingly sell or share the personal information of anyone under the age of 16.
Retention of Personal Information
We will retain your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
- Comply with record retentions requirements under applicable law
- Meet our legal obligations including financial, accounting, tax, or export obligations
- Defend or bring any existing or potential legal claims
- Maintain business records for internal purposes, such as in connection with analyses or audits
- Enforce security standards and protect against unauthorized access or fraud
- Resolve or otherwise address any complaints or queries relating to the Services
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the information.
California Privacy Rights
Under the CCPA, if you are a California resident, you may have the right to:
Right to Know: You have the right to request to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information that we have collected about you.
- Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
- Right to Correct: You have the right to request that we correct personal information that we maintain about you.
- Right to Opt-out of Sales/Sharing: You have the right to opt-out of the sale or sharing of your personal information by us.
- Right to Limit: You have the right to limit our use or disclosure of your sensitive personal information to certain purposes.
- Right to Non-discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.
We also honor requests to opt-out submitted via privacy preference signals, such as the Global Privacy Control (GPC). The signal applies to the browser. To confirm which extensions and browsers are supporting the GPC browser signal, please consult: https://globalprivacycontrol.org/
You may submit a request to know, delete, or correct by submiting an email. Please include the phrase “Personal Information Privacy Request” in the subject line. In order for us to verify your request, we need to verify your identity, so the request should include your name, address, and email address, along with a clear indication of the right(s) you wish to exercise. Please note that we may require additional information from you in order to honor your requests.
You may also use an authorized agent to act on your behalf to submit requests to exercise your rights. We will honor a request from an authorized agent provided that (i) you provide written authorization to the authorized agent to act on your behalf and we can verify your identity, and (ii) the agent submits proof of authorization. Authorized agents may use the same methods noted above to submit requests on your behalf.
Section 5. Changes to This Privacy Policy
If we update this Privacy Policy, we will notify you by posting a new version of the Privacy Policy on this page. If we make any revisions that materially reduce the privacy protections related to your personal information, we will give you the opportunity to consent to such changes before applying them to that information.
