Privacy Policy
UPDATES TO THIS NOTICE
We may update this Notice from time to time to provide clarification or notice of changes to our practices. All such changes will be effective upon posting the revised Notice on the Website and we will revise the “Last Updated” legend at the top of this Notice. Your continued use of the Website constitutes your acceptance to such changes. We encourage you to check back from time to time to ensure continuing familiarity with the most current version of the Notice.
Information You Give Us
Much of the Website is accessible without providing any Personal Information. However, you may be required to provide Personal Information, such as your name and contact information, when you are requesting to set up an account, place an order or take advantage of certain features of the Website (such as online surveys, promotions, contests and sweepstakes, product registration or to sign up for newsletters). If you do not provide your Personal Information, you will not be able to use these areas or features of the Website. If you apply to join our team, we may also collect your Social Security or Social Insurance number, driver’s license number, passport number, and professional or employment-related information.
Information Collected Automatically
We may collect this information using cookies, web beacons, pixel tags and related technologies. “Cookies” are small identifiers sent from a web server that are stored on a computer’s hard drive to identify the browser during interaction on websites or storing information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
Using the information collected about you over time, we may engage in interest-based advertising, or “online behavioral advertising”, which includes ads presented to you after you leave our Website that encourage you to return. These ads may also include offers we think are relevant to you based on your shopping habits or online activities, and they may be served on websites or applications. We may serve these ads, or third party advertisers and ad networks such as Google AdWords and Facebook or other social media providers may serve you these ads. Many of these third parties have opt-out mechanisms for their ad cookies. For more information about your choices, please see the “Your Choices” section below.
We may allow third party advertising networks to collect information from the Website for targeting advertising purposes, including online behavioral advertising. Please see the “Advertising Networks” and “Your Choices” sections below for further information. To the extent these tracking technologies are deemed to be a “sale”/ “sharing” under California law, you can refer to the “California Rights and Choices” section to understand how to opt-out of these technologies. Please note, some features of our websites may not be available to you as a result.
HOW WE MAY USE THE INFORMATION WE COLLECT
We use Personal Information for a variety of purposes, including without limitation:
- for our business purposes, such as establishing and managing your customer account, providing products and services you request (such as processing and shipping orders and sending order and shipping confirmations), processing and collecting payments and providing customer support, communicating with you and responding to your inquiries and requests, and to send you important administrative communications regarding the Website;
- to offer our products or services and/or the products or services of others to you, to contact you about selected products, services, and events and other information we think may interest you, or to communicate with you about special events, programs, surveys, contests, sweepstakes, and other offers or promotions;
- to create a more personalized user experience and to target and deliver content (including interest based advertising and promotional messaging) correlating to our users’ interests based on the ways in which our users interact with the Website, third party websites and advertisements;
- to administer your participation in special events, programs, surveys, contests, sweepstakes, and other offers or promotions;
- to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, and the Website;
- to perform data analyses, including market and consumer search, trend analysis, demographic analysis, and financial analysis, which may be performed using data sets created or derived from Personal Information;
- to diagnose technical and service problems or to administer the Website; and
- to comply with applicable legal requirements, to enforce our policies and terms of service and to protect the Website and its users.
HOW WE SHARE INFORMATION
- Service Providers. We may engage third parties, including Affiliates, to provide certain services on our behalf including website development, order fulfillment, payment processing and collection, website hosting, data storage, administration of surveys, sweepstakes, contests or other promotions, and e-mail administration.
- Advertising Networks. We may work with advertising networks that deliver targeted advertisements to consumers and generate statistics and metrics related to the delivery of such advertisements. Advertising networks collect information about the websites that you visit and the advertisements that you interact with using tools such as cookies, web server logs and web beacons. This information is used to serve you targeted ads based on your inferred interests and preferences as well as for auditing, research and reporting to us, our Affiliates and other advertisers. This data collection takes place both on this Website and on third-party websites that participate in the advertising networks. When you visit websites or view or interact with an advertisement, the possibility exists that the advertiser will make the assumption that you are interested in the subject matter of the advertisements.
We may share non-personally identifiable data, including anonymized data derived from Personal Information collected from the Website, with third parties, including our Affiliates, dealers, marketing businesses and lead generation businesses, for any purpose.
YOUR CHOICES
Accessing and Modifying Your Personal Information. Subject to applicable laws, you may request correction, updating and deletion of the information contained in your online account through the “My Account” page on the Website or by contacting us in writing as specified in the “How to Contact Us” section below. Please note that we may retain some Personal Information for archival and record retention purposes.
Communication Preferences. You may choose not to receive marketing and promotional email communications from us by clicking on the opt-out mechanism contained in such emails (also referred to as “unsubscribe”). You may still receive service-oriented, administrative communications from us, as you cannot opt-out of receiving such administrative communications. Please note that opting out of receiving marketing or promotional email communications will affect only future communications from us. If we already provided your information to a third party before you changed your preferences or updated your information, you may have to directly contact the relevant third party to communicate your choice to them in accordance with their policies.
Social Media. Some social media providers allow you to control the interest based advertisements that you see through their platforms. Please review the privacy policy of the applicable social media provider and the settings section of your social media account.
Please be aware that if you do not allow us to collect and use your information, portions of the Website’s features and functionality will not operate correctly and we may not be able to provide you with certain services.
We reserve the right to retain and use any Personal Information reasonably necessary to comply with our legal obligations, such as documenting our business activities and for archival and record retention purposes, resolve disputes, and enforce our legal agreements and policies.
DO NOT TRACK
We are not currently aware of a worldwide, uniform or consistent industry technology standard or definition for responding to, processing, or communicating “Do Not Track” signals. Accordingly, our website is unable to respond to “Do Not Track” requests from browsers. ADDITIONAL NOTICE FOR CANADIAN RESIDENTS
Where personal information is processed with your consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as described below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain parts of our Services.
We protect personal information using safeguards that are appropriate to the sensitivity of the information. These safeguards may include measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. We limit access to personal information to our employees and service providers who require access in connection with their role or function. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information.
Personal information is maintained on our servers or those of our service providers and is retained as long as necessary for the fulfilment of the purposes for which it was collected, in accordance with prudent business practices on general document retention, or as otherwise required by law.
Some of our service providers may be located outside of Canada, including in the United States. While outside of your jurisdiction of residence, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access your information in certain circumstances.
HOW TO CONTACT US
Additional Notice for California Consumers
This portion of our Privacy Policy applies to residents of the State of California only.
HOW WE COLLECT, USE, AND SHARE PERSONAL INFORMATION
1. Personal Information Collected on California Consumers in the Last Twelve Months
We collect information from users directly, advertising networks, data analytics providers, and others as described in our Privacy Policy, for the purposes described below. The “Personal Information” (defined under California law) we have obtained on California residents within the last twelve months includes the following:
A. Identifiers such as name, postal and email addresses, unique personal identifier, online identifier, token identifier, Internet Protocol (IP) address, account name, or social media handle when you request to create an account, purchase our products, interact with us on social media, or sign up to learn more about our products and services. We may also collect employee ID and forms of government identification such as Social Security number, driver’s license number, passport number, state ID number, national identity card details, or national identification number when you apply for a position with us.
B. The following categories of Personal Information described in California Civil Code § 1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers”; (2) credit card number, debit card number or other payment information when you purchase our products; and (3) other information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household, as described herein. From applicant and employees, we may also collect date of birth or birthday; F.
C. The following categories of protected classification characteristics under California or federal law: gender, race, color, religion, marital status, medical condition, mental health condition, disability status, national origin including nationality, residency, and citizenship status, sexual orientation; military and/or veteran status; requests for leave related to a family member’s health, or an employee health condition such as pregnancy; and age or age range (40 years and older)
D. Commercial information such as records of products or services purchased, or obtained, or considered from us.
E. Internet or other similar network activity information, including, but not limited to, browsing history on our websites, search history, preferences related to digital communication, and information on a consumer’s interaction with our websites or applications.
F. Geolocation data such as physical location or movements if you use our app or website.
G. Audio information, including recordings of when you called into our support line; video information in the form of CCTV at our local storefronts; visual information such as photographs; and electronic information in the form of Internet or other electronic network activity information as described above.
H. Inferences drawn from the information we collect when you visit the Website to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.I. Professional or employment information, including: employment history; educational background and
K. Sensitive Personal Information such as account login credentials, government-issued identifiers that you provide in connection with employment applications as described in I and J, precise geolocation data as described in F, financial information discussed in B under certain circumstances, and contents of any emails between consumers and stores, to the extent these may be received by us when we are not the intended recipient of such communications. We do not collect sensitive personal information for the purpose of inferring characteristics about consumers or employees.
To the extent we or our third-party service providers collect additional categories of information beyond those discussed above, additional notice will be provided, and we or our third-party service providers will ask for your consent before collecting such additional categories of personal information, as required by law.
Please note that Personal Information does not include publicly available information from government records, deidentified or aggregate consumer information, and Personal Information protected by certain other sector-specific federal or California statutes.
2. Our Use of Personal Information for Business Purposes in the Last Twelve Months
We use the Personal Information we collect, identified in each of the above categories, for the business purposes disclosed within the Privacy Policy. These business purposes include the following:
A. Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
B. Helping to ensure security and integrity while using Personal Information as may be reasonably necessary and proportion, including detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
C. Debugging to identify and repair errors in our systems;
D. Short-term, transient use including contextual customization of ads that is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience;
E. Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying identity information, processing payments, providing advertising or marketing services, sending you relevant offers for products and services via [email, phone, text messaging or push notification on your phone], and other services;
a. Profiling and Automated Decisionmaking. Except to the extent Personal Information is used by third-party ad networks for online behavioral advertising, neither we, nor our third-party service providers on our behalf, engage in profiling or automated decisionmaking activities that produce legal and/or similarly significant effects upon you.
F. Conducting internal research to develop and demonstrate technology;
G. Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
H. Preparing statistics and performing analysis to support our operations;
I. Conducting marketing and surveys regarding our target market and products;
J. Receiving and responding to inquiries; and
K. Managing our employment relationships, including onboarding new employees for training and development, payment and reimbursement, the enrollment in and administration of benefits, providing reasonable accommodations and leaves of absence, monitoring performance and enforcing corporate policies, and compliance with applicable laws.
We will not use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you with notice.
3. Sharing of Personal Information in the Last Twelve Months
Within the last twelve months, we have disclosed Personal Information identified in categories [D, E, and H] identified above to advertising networks, social networks, and data analytics providers for monetary or other valuable consideration as a data “sale” and/or the “sharing” of personal information for cross-context behavioral advertising under California law. Please note that we do not “sell” your Personal Information to third parties for money. These disclosures may have involved sharing information with certain technology providers that provide certain services to us, including delivering advertisements that we believe may be of interest to you. We do not and will not knowingly “sell” the Personal Information of minors under the age of 16, or “share” the Personal Information of minors under the age of 16 for cross-context behavioral advertising, without affirmative authorization.
Within the last twelve months, we have disclosed Personal Information identified in all or substantially all the above categories only (i) at your express request, or (ii) to other businesses, service providers, or third parties for various business purposes. For more information on the service providers with whom we share information, please see “How We Share Your Information” above. When we disclose Personal Information for a business purpose, we execute a contract that describes the purpose and requires the recipient to keep Personal Information confidential and not use it for any purpose except performing the contract.
We do not disclose Personal Information of individuals we know to be under the age of 16 to other businesses or third parties for consideration or for cross-context behavioral advertising.
4. Retention of Personal Information
We retain and use your Personal Information only for as long as necessary to carry out the purposes described in the Privacy Policy, and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
CALIFORNIA RIGHTS AND CHOICES
If you are a California resident, you have certain rights related to your Personal Information. Except as otherwise provided by applicable law, you may exercise the following rights for purposes of the Personal Information covered by our Privacy Policy.
1. Right to Know / Portability
You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:
- the categories of Personal Information we have collected about you;
- the categories of sources from which the Personal Information is collected;
- our business or commercial purpose for collecting Personal Information;
- the categories of third parties with whom we share Personal Information; and
- the specific pieces of information we have collected about you.
2. Right to Deletion
You have the right to request deletion of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- debug products to identify and repair errors that impair existing intended functionality;
- exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act;
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- comply with a legal obligation; or
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
3. Right to Correct Inaccurate Information
You have the right to request that we correct Personal Information we maintain about you that is inaccurate.
4. Right to Opt-Ou
Additionally, we will process opt-out requests submitted by a consumer’s opt-out preference signal as required by applicable law. The technical specifications of a consumer’s opt-out preference signal determine how we process such signals. For example, if an opt-out preference signal is associated solely with a user’s browser, the opt-out will be applied to the browser. As of the “Last Updated” date of this Privacy Policy, our processing of opt-out preference signals can be considered “frictionless” under California law.
You can learn more about how you can use an opt-out preference signal by visiting the California Attorney General’s CCPA page and consulting the section titled “Requests not to Sell Personal Information (Right to Opt-Out of Sale).” You can also consult information published by the California Privacy Protection Agency (CPPA) about how you can use opt-preference signal.
5. Right to Limit the Use of Sensitive Personal Information.
We do not use or disclose sensitive personal information for purposes that, under applicable law, require us to offer consumers or employees a “Right to Limit” the use or disclosure of sensitive personal information.
6. Right to Non-Discrimination For Exercise of a California Privacy Right
We will not discriminate against you because of your exercise of any of the above rights, or any other rights under the CCPA. This means that we may not deny you goods or services, charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the CCPA.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information
8. Verifiable Request
As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information listed on our online form to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
9. Agent Authorization
You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent. An agent may be an individual, or a business entity registered with the California Secretary of State. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your own identity directly in response to a request, even if you choose to use an agent, to the extent permitted by law.