Effective date: July 1, 2022
Scope of Policy
We collect the following information:
- Contact and Account Information: Your name, addresses, telephone numbers, email addresses, date of birth, username, password and any other contact and/or Account information that you provide us either through our Website, our events or in-store;
- Service Provider Information: Information about the mobile or internet service provider you are using with your device to access the Website and/or send us messages, including name and IP address.
- Messages: The date, time and content of any messages you send to us;
- Payment Information: Credit/debit card and other billing information, including cardholder transaction data, card numbers, expiration dates, billing addresses and CVV codes;
- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
- Technical Information:
- IP address and other technical information collected from the servers utilized by you or your vendors, such as information and data that is automatically collected upon visiting the Website (i.e., webpage http headers (home server domain names, internet protocol address, operating system type, browser type and language) and information on what pages you access and other information about the way(s) in which you use the Website).
- Information provided on any application (including the App) or authorization, such as your location, your handset type, your UDID (unique handset code) and any other information you or your mobile device provides to us;
- Other: Other information you provide to us when you use the Website or otherwise interact with us.
- Information listed above which we aggregate and/or anonymize so that it is not linked to you.
How Information is Collected
We collect information through one or more of the following ways:
- the completion of electronic forms found on the Website or on a third party-hosted website, whether via computer or mobile device;
- the completion of paper forms provided to us;
- SMS (Short Message Service) messages sent via cell phone, or through email and other communications;
- telephone calls made to us, or vice versa;
- referring websites or third parties, including social media sites such as Facebook, Twitter, Tumblr, Instagram, Pinterest, YouTube, Google+ and others including by virtue of advertisements placed by us on websites maintained by those third parties;
- our affiliates;
- the maintenance and analysis of Website server logs;
- events that we host or by visiting our stores; and
- “cookies” (small text files placed by us on your computer(s)), single pixel GIF image files (also called “Web beacons”), Website server log analysis and other similar technological means. See “Use of Web Technologies” Section below.
Location information: We collect information about your location based on:
- derivations made from the IP address from which you connect; and
- if you consent (by accepting on your mobile operating system), the Global Positioning System (GPS) of your device when the App is running in the foreground (together, “Location Information”).
We (and our service providers) use your Location Information to provide you with customised nearby services or value-added services (including marketing) that we think you’d like. Where possible, we may also use Location Information to enhance or localise content and services that you use. If you do not wish to share your GPS location with us, you can switch off GPS functionality on your mobile device. If you otherwise wish to withdraw your consent to us using cell ID data and GPS data, email us at email@example.com.
Certain portions of the Website require that you register for an Account before being able to access them. On those portions of the Website that require registration, we collect information to create your account, as well as to determine specific content, products and services that will be of particular interest to you. By collecting and maintaining accurate information, we learn more about your interests and needs and are better able to provide you with such content and with offers for such products and services.
Use of Information Collected
We use the information we collect:
- to authenticate and verify individual identities, including requests to exercise your rights under this policy.
- to provide customized information and offers of products and services, including to enable third party services to display customized content and advertising provided by us.
- to manage and communicate with you about your account with us, including responding to your questions and providing customer or technical support.
- to provide information about our company such as newsletters or other communications, and to deliver advertising and promotional information from our partners and third party vendors.
- for the purposes of processing payments and fulfilling orders for products or services placed by you, processing your request to use our interest-free payment plans and order fulfillment and tracking.
- for statistical purposes.
- to publish feedback, personal testimonials, and other information in our editorial publications and online articles.
- to provide information about our company such as newsletters or other communications, and to deliver advertising and promotional information from our partners and third party vendors.
- to improve our technologies including for the purpose of enhancing your experience on the Website.
- to provide marketing messages, promotions, offers of products and services and other content which we think will be of specific interest to you, where you have consented (or not opted out, as applicable).
- to process applications if you apply for a job that we post on our Website.
- to manage and secure our operations including for detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; debugging to identify and repair errors with our Services; and auditing relating to interactions, transactions and other compliance activities.
- to enforce our agreements and policies
- to comply with our legal obligations.
We store or transfer your credit/debit card data in order to more easily provide services to you. If such credit/debit card and other billing information is collected and/or stored, such credit/debit card and other billing information will be collected and transferred over a secure connection in accordance with applicable regulatory requirements, and is used only for processing underlying transactions.
Where you have consented (or not opted out, as applicable), we add your information to our databases to contact you through future emails, postal mailings and SMS text-messaging regarding site updates, upcoming events, new products and services and/or the status of orders placed online. We do not currently use geolocation for purposes of tracking your location when you use the Website, but we reserve the right to do so in the future in order to better target product and service offerings and other information to you.
When you sign up for an account with us, we will send you a welcome email. We will also communicate with you in response to your inquiries, to provide any services you request, to provide newsletters or other updates that you request and to manage your account. In addition, when you register an Account with us, you can consent to our contacting you by email and to receiving our email subscriptions, editorial emails and advertorial emails (see below) from us. If, at any time, you no longer want us to contact you by email and/or receive our email subscriptions, editorial emails and advertorial emails, you can opt out of these functions by changing the preferences in your Account. You can contact customer service by email, telephone or postal mail at the contact information listed below to assist you with any such changes to your Account.
Sharing of Information Collected with Third Parties
We reserve the right to rent or sell the information we collect from you to third parties.
We also share your information with certain third parties in other circumstances, including when complying with legal process, preventing fraud or imminent harm and/or ensuring the security of our network and services.
We will share certain of your information with third parties for the purposes of fulfilling orders for products or services placed by you. We will share your credit/debit card data only with those directly involved in the processing of the underlying transaction, and who maintain appropriate security measures designed to safeguard such information.
We will also share certain of your information with third parties for the purposes of providing you with newsletters or other communications.
We will provide you with direct access to functionality from other third parties, including Facebook, Twitter, Instagram, YouTube, Pinterest, Spotify, advertising networks and others. The placement of social media widgets, or advertising units on the Website can permit these third parties to see information about you and your activities via cookies, web beacons and other technologies they place and/or access on your browser or device, even if you do not interact with them.
In the event that we go through a business transition, such as a merger, acquisition or sale of our assets, your personal information will likely be among the assets transferred. You will be notified of any such change in ownership or control of your personal information. We transfer your information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control.
We reserve the right to release information to law enforcement or other governmental officials as we, in our sole discretion, deem necessary to comply with applicable law.
Use of Web Technologies
We employ a software technology called tracking pixels (a/k/a web beacons/web bugs/clear gifs) that enables us to better manage the content on the Website by informing us what content is effective. Tracking pixels are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of visitors to a website. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are embedded invisibly on website pages and are about the size of the period at the end of a sentence. We do not tie the information gathered by tracking pixels to your personally identifiable information.
As is true of most websites, we gather information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track the movements of users around the Website and to gather demographic information about our user base as a whole.
What types of cookies and other Web Technologies do we use and how do we use them?
The types of cookies and similar technologies used by us and our partners in connection with the Website can be classified into one of five categories, namely ‘essential Website cookies’, ‘functionality cookies’, ‘analytics and performance cookies’, ‘advertising cookies’, and ‘ social media cookies’. Cookies do a lot of different tasks to ensure you enjoy your visit to our Website, for example, they are used to remember your preferences on our Website, to help you navigate between pages more efficiently, to enable you to log into your account more easily and to make sure the adverts you see on our Website are relevant to you and your interests. We have set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.
You can block these cookies and similar technologies by changing your browser setting. However, in relation to those that are essential for the operation or improve the functionality of the Website, this may impact your use of the Website.
|Type of cookie||What it does|
|Cookies necessary for essential Website purposes||These cookies are essential to provide you with the Website and any services available through this Website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.|
|Functionality Cookies||Functionality cookies record information about choices you’ve made and allow us to tailor the Website to you. These cookies mean that when you continue to use or come back to the Website, we can provide you with our services as you have asked for them to be provided. These cookies allow us to: Save your location preference if you have set your location on your homepage, if applicable, in order to receive a local weather forecast;Remember settings you have applied, such as layout, text size, preferences, and colors;Show you when you are logged in; andStore accessibility options.|
|Performance Cookies||We use performance/analytics cookies to analyze how the Website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Website.We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see https://analytics.google.com/analytics/web/#/report-home/a202563126w279692120p247264541. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.These cookies allow us to: Better understand our Website visitors so that we can improve how we present our content;Test different design ideas for particular pages, such as our homepage;Collect information about Website visitors such as where they are located and what browsers they are using;Determine the number of unique users of the Website;Improve the Website by measuring any errors that occur; andConduct research and diagnostics to improve product offerings.|
|Advertising and Targeting Cookies||As you use our Website, you will notice that it features advertising. We allow third party companies, including advertising companies, to place cookies on our Website.These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet.Cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.We can use information from one device to help personalize your experience on another device.|
|Social Media Cookies||On some pages of our Website, third parties that provide applications through our Website will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. [Some pages of our [Website] will also contain embedded content, such as video content from YouTube, and these sites will set their own cookies.]These cookies are used when you share an article using a social media sharing button on our Website (e.g., Facebook, Twitter, or Google Plus) as the social network that has created the button will record that you have done this. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via cookies.|
For US Users: Do Not Track
When you use the Website, you may have set your browser or other means used to access the Website to send “do not track” requests to us. At this time, we do not respond to such “do not track” requests, although we may choose to do so in the future.
We take reasonable precautions to protect the confidentiality and security of your personally identifiable information by using industry recognized security safeguards. Unfortunately, no method of transmission over the Internet is completely secure. Therefore, while we strive to protect your personally identifiable information within industry standards, we cannot guarantee its absolute security.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personally identifiable information. Our security procedures mean that we will occasionally request proof of identity before we disclose personal information to you. You are responsible for protecting against unauthorized access to your password and to your computer/mobile device. We ask you not to share your password with anyone.
Our employees are trained and required to safeguard your information. Our internal controls limit access to personally identifiable information based on job functionality.
No Information Collected from Children
The content and services provided by us or our affiliates, sponsors and advertisers, including without limitation the Website, are not intended for anyone under the age of 18 and you should not access such content or services if you are under the age of 18. No information is knowingly collected or retained from children under the age of 13, nor is any such information knowingly used for any marketing or promotional purposes whatsoever, either inside or outside the Website. No part of the Website is designed to attract anyone under the age of 13. Children are not eligible to use any services provided by us and we ask that children under the age of 13 not submit any personal information to us or visit the Website.
Third Party Ad Server Networks
To opt out of third-party tracking on our Website use the following tools
You can opt out of the Ad Tech Network by clicking http://www.youronlinechoices.com/opt-out-interface.
If you would like to opt out of having interest-based information collected during your visits to our Website or other sites, both the National Advertising Initiative (the “NAI”) and the Digital Advertising Alliance (the “DAA”) offer opt out tools to assist you in managing your choices. Click http://www.networkadvertising.org/choices/ to visit the NAI opt out page and click http://www.aboutads.info/choices/ for the DAA opt out page.
You can visit http://www.networkadvertising.org/understanding-online-advertising/ to learn more about interest-based advertising and your choices regarding having this information used by third parties and your “opt out” choices. Opting out through the DAA or the NAI only means that those DAA or NAI members will no longer be able to deliver targeted content and/or ads to you, which will affect our Website as well as other unaffiliated websites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit these opt out pages, or you subsequently erase your cookies, use a different computer or change web browsers, your opt out choices could not (or could no longer) be effective.
If you want to be removed from our marketing list and do not want us to send you email, postal mail or other messages about our products and services, you can opt out. To do so, please send an email to firstname.lastname@example.org, with the word “REMOVE” in the subject line.
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of such residents’ personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please email us at email@example.com.
Manage Accurate Information
EE is based in the United States, with our servers and offices headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Website, an Account, or any services provided by us will be processed and transferred to, and be subject to the laws of, the United States. The privacy and data protection laws in the United States will be different from similar laws in your country of residence. By using the Website or an Account, or by providing us with your information, you consent to the collection, transfer, storage and processing of information to and within the United States. If our cookies or other software detects IP addresses located in a country outside the United States, we reserve the right to deny access to any and all of our services.
If you are in the EU, you have certain additional rights and protections under the law regarding the collection and processing of your personal data.
Legal Basis for Processing
If you are in the EU, we will collect and process your personal data:
- To perform our responsibilities under our contract with you (e.g. processing payments for and fulfillment of the goods you have ordered);
- When we have a legitimate interest in collecting and processing your personal data in order for us to run a successful commercial organization (e.g. to communicate with you about updates regarding your order, to advertise products to specifically tailored for you, and send you updates to this policy);
- Where you have given your consent (e.g. to market products to you, to use Location Information) – please note that you can withdraw your consent at any time by emailing firstname.lastname@example.org; or
- To comply with our legal or regulatory obligations.
We share your information with selected recipients. These categories of recipients include:
- cloud storage providers including Amazon Web Services located in Virginia, and which currently stores your personal data in Virginia, to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
- IT Services providers (including Segment, located in the United States), that provide us with SaaS services, who we use to store our customer relationship management information, etc.;
- provided you have consented, advertisers and advertising networks including Google and Facebook located in California, and which store your personal data in California, that require the data to select and serve relevant adverts to you and others;
- analytics and search engine providers including Google and Heap located in California and which currently store your personal data in California that assist us in the improvement and optimisation of the website; and
Data Subject Requests
If you are a user in the EU, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You also have the right to data portability, and to restrict certain processing of your data in certain circumstances. You also have the right to complain to your data protection authority if you have any complaints about how we process your personal information.
You have the right to object to our processing of your personal data at any time, and you can withdraw your consent to marketing at any time.
To make any of these requests please email email@example.com. We will respond as soon as practicable and no later than one month after receipt of your request. We will request proof of identification to verify your identity.
We reserve the right to deny or restrict fulfillment of your request in certain cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing or your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.
Questions or Complaints
In the event that you have a concern about our collection and processing of your data, please contact us first at firstname.lastname@example.org and we will do our best to fix it. You also have the right to lodge a complaint directly with your local supervisory authority.
We will retain your information as long as needed to enable you to access the Website or otherwise interact with you, and for as long as you or we can bring a legal claim.
After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.
The table below explains the categories of information that we have collected in the past 12 months, the sources of that information, the purpose for that collection and the categories of third parties with whom we share that information.
|Category||Purpose of Collection||Disclosed to Third Parties|
|User provided information (e.g. identifiers, such as, first name and last name, email address, phone number)||We use this information to provide the services you request, fulfill your orders, answer and manage your questions or complaints, provide you with information you request, for advertising and marketing purposes, run analytics, statistics and research and to tailor your experience on our services.||We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, logging and operations providers. We may also disclose this information to third parties for advertising and marketing purposes.|
|Location Information (geolocation information and commercial information)||We use this information to provide you customized services near you and value-add services near you (including marketing).||We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, logging and operations providers.|
|Survey responses||We use your survey responses to improve our services and better understand your preferences.||We may need to disclose this information to service providers such as our cloud storage providers, data analytics and survey processing providers.|
|Website and Account usage information (e.g. order history, wait lists, pages viewed, and customer service inquiries)||We use this information to better understand how you use the service and to customize your experience on our services.||We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, logging and operations providers.|
|Device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information)||We use this information to protect the security of your account and remember your personalized settings. We may also use certain device level information for advertising and marketing purposes.||We may need to disclose this information to service providers such as our cloud storage providers, data analytics providers and advertising partners.|
|Inferred Data (e.g. inferred user information, preferences or tastes)||We may use this information to provide you with recommendations and customize your experience, optimize or improve our services, and run analytics, statistics and research.||We may need to disclose this information to service providers such as our cloud storage, data analytics, logging and operations providers.|
|Audio and Visual Information (the public spaces in our physical locations are protected by CCTV.)||We may use this information for the purpose of preventing crime and for your safety and the safety of our employees.||We may need to disclose this information to service providers such as our security and CCTV providers or to law enforcement.|
The CCPA has defined a “sale” to include any transfer of personal information by us to another entity for anything of value. For these purposes, in the past 12 months, we have “sold” (for the purposes of the CCPA) the following categories of personal information:
- device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information);
- commercial Information (e.g., purchases, wait lists and pages viewed);
- inferred Data (e.g. inferred user information, preferences or tastes); and
- location Information (geolocation information and commercial information)
to third parties for a business or commercial purpose.
As applicable under the CCPA, from January 1, 2020, if you are a California resident, you may make requests to us as set out below. We will review all requests received and determine the extent to which and how to respond. We will not discriminate against any California resident who makes such requests.
Right to access/know
You may request from us a list of: (i) the personal information that we have collected about you; (ii) the categories of third parties to whom we have disclosed your personal information; and (iii) the categories of third parties to whom we have sold your personal information. You have the right to up to two (2) access requests each twelve (12) months.
Right to delete your personal information
You may request to delete your account and your personal information.
Right to opt-out from the sale of your personal information
You may request, at any time, to direct us to stop “selling” (for the purposes of the CCPA) your personal information.
You may contact us to make the requests described above by using the appropriate mechanisms to contact us defined in the Contact Us section below. We will not use the information you provide as part of your request for any other purpose other than to fulfill your request.
To ensure the privacy and protection of individuals, we are required to verify or otherwise authenticate your request(s). To verify your request for access or deletion of your personal information, we may request that you log into your account and make a request.
You may also submit such requests through an authorized agent. To designate an authorized agent, please send us a notarized power of attorney / notarized letter authorizing said agent. Requests from agents that do not submit such proof that they have been authorized by you to act on their behalf will be denied.
If you are a user of this service and a California resident under the age of 18, you may request to have your posted content or information removed from the publicly-viewable portion of this web site by logging into your account and removing your posted content or information from the webpage where it is posted, or contacting us directly. Content or information may not be removed from our systems or databases. In certain situations, content or information cannot be removed.
As a California resident, you may contact us with any questions or to request a list of third parties to whom we may disclose your information for such third parties’ marketing purposes and the categories of Information we may disclose.
See the Contact Us section below to make such requests.
By email: email@example.com