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Privacy Policy

Last Updated: April 1, 2024

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This Privacy Policy describes how Hedley & Bennett, LLC, a Delaware limited liability company, and our brands and subsidiaries (“H&B”, “we”, “us”, or “our”) collect, use and share information about you. This policy applies to information we collect when you use our websites, apps, shop in our online stores or otherwise interact with us as described below (collectively, the “Site”). We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our websites or sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy. Capitalized terms not defined herein shall have the meanings ascribed thereto in our Terms of Service.

Acceptance Of These Terms

By using this Site, you signify your acceptance of this policy and any changes to this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Collection Of Information

Information You Provide to Us. We collect information you provide directly to us. For example, we collect information when you use our websites, shop in our online stores, call us on the phone, create an online account, join our subscription and loyalty programs, sign up to receive our emails, request a catalog, participate in a sweepstakes, contest, promotion or survey, communicate with us via third party social media sites, request customer support, apply for a job or otherwise communicate with us. The types of information we may collect include your name, email address, zip code, billing address, shipping address, phone number, payment card information, product preferences, demographic information and any other information you choose to provide (“Personal Information” or “Personal Data”). In some cases, we may also collect information you provide about others, such as when you purchase a gift card for someone and request that we deliver it electronically, create and share a “wish list” or decide to purchase and ship products to someone. We will use this information to fulfill your requests and may also use that information to send marketing communications to your contact, unless he or she has previously opted out of marketing communications from H&B.


Information We Collect Automatically. We automatically collect certain information about you when you access or use our websites or transact business with us, including: (i) information about your use of our websites, such as the type of browser you use, access times, pages viewed, your IP address and the referring link through which you accessed our websites; (ii) information about the transaction, such as product details and the date and location of the purchase/return; and (iii) we may use cookies, web beacons, also known as “tracking pixels”) and other tracking technologies to collect information about you when you interact with our websites or emails, including information about your browsing and purchasing behavior. We may combine this information with other information we collect about you and use it for various purposes, such as improving our websites and your online experience, understanding which areas and features of our sites are popular, counting visits, understanding campaign effectiveness, tailoring our communications with you, determining whether an email has been opened and links within the email have been clicked and for other internal business purposes.


Retention and Transfer of Personal Information. We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about our products and services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements. We will delete this information from the servers at an earlier date if you so request by unsubscribing, opting-out, or emailing us at customerservice@hedleyb.com. Personal Information may be transferred and stored to secure servers in the United States.

Use Of Information

We may use information about you for various purposes, including to: (i) facilitate and improve your online shopping experience; (ii) provide the products and services you request, process transactions and send you related information, including confirmations and receipts; (iii) respond to your comments, questions and requests and provide customer service; (iv) communicate with you about products, services, offers, promotions, rewards and events and provide news and information we think will be of interest to you; (v) manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages; (vi) personalize your online experience and provide advertisements, content or features that match your profile and interests; (vii) monitor and analyze trends, usage and activities; (viii) process and deliver contest, promotion and sweepstakes entries and rewards; (ix) link or combine with information we get from others to help understand your needs and provide you with better service; and (x) carry out any other purpose for which the information was collected. We are based in the United States and the information we collect is governed by U.S. law. By accessing or using our websites or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

Sharing of Information

We may share information about you as follows: (i) with vendors, consultants and other service providers who need access to such information to carry out work on our behalf; (ii) with our business partners and other third parties for purposes of sending their own direct mail; (iii) in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process or as otherwise required by any applicable law, rule or regulation; (iv) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third party; (v) in connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company; or (vi) with your consent or at your direction. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Advertising and Analytics

We engage third parties to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of our websites, such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our websites and other websites and better understand your online or offline activity. We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms.

Cookies

We use functional and analytical cookies to provide for the best user experience. We, as well as third parties, also use tracking cookies on our websites to show you customized advertisements and offers on our websites, as well as on third party websites and apps. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies, but note that doing so does not necessarily affect third party flash cookies used in connection with our websites. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites. In addition, many web browsers support Do Not Track technology. If you enable Do Not Track, Note, however, third-party companies may not recognize browser “Do Not Track” signals. If you would like to opt out of the collection and use of tracking data for ad targeting, please visit www.aboutads.info/choices/.

Links To 3rd Party Websites

Our Site may contain links to other websites. Our Privacy Policy does not apply to the practices of other websites and H&B is not responsible for the actions and privacy policies of third parties. We encourage you to be aware of when you leave our Site and to read the privacy policies of each website that you visit.

Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We use organizational, procedural, and technical safeguards to secure data in our possession, consistent with the sensitivity level of such data. When sensitive information (such as a credit card data) is collected on our Site it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol and may be processed by third parties using similar levels of protection. Regardless of the precautions we take, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect Personal Information, we cannot ensure or warrant the security of any information you transmit to us.

Children

We do not knowingly collect any Personal Information from children under the age of 16. We do not sell products for purchase by children and all children’s products we sell are for purchase by adults only.

Managing Your Privacy Rights and Choices

You may have certain rights identified below under applicable laws of where you reside with respect to your Personal Information. We have full discretion in choosing to voluntarily provide you with some or all of those rights regardless of the state in which you reside. Please refer to additional state-specific information below to determine the rights you have in the state you reside.

Depending upon the applicable law, access to your rights may be denied, such as: (a) when denial is required or permitted by law; (b) when granting access would have a negative impact on another's privacy; or (c) to protect our rights and properties.

The privacy rights you may have include the following:

  • Right to know and access your Personal Information. You may have the right to know what Personal Information we collect about you, including the categories of Personal Information, the sources from and purposes for which we collect it, and the types of recipients we disclose it to, and to request a copy of the specific pieces of Personal Information that we maintain about you.
  • Right to correct your Personal Information. Right to correct inaccurate Personal Information that we maintain about you.
  • Right to delete your Personal Information. You may request the deletion of their Personal Information that we have collected about you, subject to certain exceptions.
  • Right to opt out of “sales” or “sharing” for cross-context behavioral advertising or targeted advertising. You may request to opt-out of our sale of your Personal Information and sharing of their Personal Information for cross context behavioral advertising or targeted advertising. We share your Personal Information with third parties (such as marketing and advertising networks and social platforms) for behavioral advertising or disclose your Personal Information to other third-party partners in accordance with your privacy settings and/or consent. These types of disclosures of your Personal Information may be deemed a “sale” or “sharing” of your Personal Information under applicable privacy laws.
  • Right to non-discrimination. You have the right not to be subject to discriminatory treatment for exercising your rights under certain laws.


Exercising Your Rights and Choices

You may submit privacy rights requests and manage your privacy choices in several ways.

Submitting Privacy Rights Requests

You may request to access your Personal Information (both the categories of data we collect, which is laid out in this policy, and specific pieces of information), obtain an electronic copy of your Personal Information, correct your Personal Information if it is incomplete or inaccurate, or delete or restrict sharing of your Personal Information in certain circumstances, as provided by applicable law. You can exercise these controls and choose to opt in or out of services and communications by visiting your account preferences, contacting our customer service at customerservice@hedleyb.com, or following the instructions directly provided in the communications we send you.

  • Non-Discrimination. We will not discriminate against you for making these requests. If you request to delete your account, you can create a new account at any time.
  • Verification. We will verify your request either through a message sent to the email address associated with your account (so you must have access to this email account) or by asking you to provide information matching what we have for you within our systems. We will process your request based upon the Personal Information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.
  • Authorized Agents. You or your authorized agent may request to exercise your rights. Before we can act on a request from your authorized agent, we may require verification of your identity and proof from the authorized agent that they can act on your behalf. We may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
  • Contacting Us. If you have a request regarding your Personal Information that cannot be fulfilled from your account settings, please contact us by emailing your request to customerservice@hedleyb.com. In the subject line of your email, please write “Privacy Rights Request”.
  • Timing. We will use best efforts to respond to a verified consumer request within 45 days. If we require more time, we will inform you of the reason and extension in writing. You may only make a request for access or data portability twice within a 12-month period.
  • Denials and Appeals. If we deny your request, we will notify you and provide our reasons for the denial and instructions regarding the rights you may have under applicable laws to appeal the decision. If the appeal is denied, we will notify you of your rights under applicable laws to contact the Attorney General to submit a complaint.


Other Data Protection Rights

You may have the following data protection rights:

  • To access, correct, update or request deletion of Personal Information. We take reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a registered user, you can manage many of your individual account and profile settings within your account provided through the Site, or you may contact us directly by emailing us at customerservice@hedleyb.com. We will consider your request in accordance with applicable laws.
  • In addition, individuals who are residents of the European Economic Area (“EEA”) can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us at customerservice@hedleyb.com.
  • Similarly, if Personal Information is collected or processed on the basis of consent you can withdraw consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • EEA residents have the right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.


California Privacy Rights

Consumers residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”). If you are a California resident, these terms and conditions apply to you.

Categories of Personal Information Collected.

We collect the Personal Information detailed in the “Collection of Information” section above. This information includes the following categories of Personal Information as defined under California law:

  • Identifiers
  • Personal Information described in California Section 1798.80(e)
  • Characteristics of protected classifications under California or federal law
  • Commercial Information
  • Internet or other electronic activity information
  • Geolocation data
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Inferences
  • Sensitive Personal Information, specifically: (a) log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, (b) precise geolocation information; and (c) Personal Information collected and analyzed concerning a consumer’s health.

Categories of Personal Information Disclosed for Business Purposes.

The Personal Information we process varies based upon our relationship and interactions with you. We may disclose the categories of Personal Information described above for the business purposes outlined in “Use of Information” section above. The recipients to whom we may disclose your Personal Information (and that may have received such information during the last 12-months) for business purposes include: our affiliates and subsidiaries; order processing, fulfillment, shipping, and logistics vendors; payment processors and financial institutions; analytics and research vendors; information technology vendors; fraud prevention and security vendors; vendors supporting legal, compliance, accounting, audits and other internal functions; and certain marketing and advertising vendors.

Categories of Personal Information Shared with Third Parties.

We share your Personal Information with third parties (such as marketing and advertising networks and social platforms) for behavioral advertising or with other third-party partners in accordance with your privacy settings and/or consent. While we do not sell your Personal Information, these types of disclosures of your Personal Information may be deemed a “sale” or “sharing” of your Personal Information under California privacy laws. California privacy laws define a “sale” as disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising or with affiliates and business partners. H&B does not disclose, sell, share, or rent your Personal Information to third parties in exchange for money or compensation. Further, we do not “sell” or “share” sensitive Personal Information, nor do we “sell” or “share” any Personal Information about individuals who we know are under the age of 16. Below is an overview of categories of third parties with whom we share your information and the categories of Personal Information they receive:

CCPA/CPRA Choices and Control

California residents have the following rights with respect to their Personal Information:

  • To know what Personal Information is collected
  • To access Personal Information
  • To correct Personal Information
  • To delete Personal Information
  • To opt-out of the “sale” of Personal Information
  • To opt-out of “sharing” of Personal Information for cross-context behavioral advertising
  • To limit the use of sensitive Personal Information
  • To non-discrimination

These rights are further detailed in Managing Your Privacy Rights and Choices above. California residents may exercise their privacy rights by following the instructions below.

Submitting a CCPA/CPRA Request

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of a California resident who wishes to make a request.

We may not be able to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will ask you for the email information that you used to interact with us or sign up for a loyalty, email or to make purchases to help verify your identity or authority to make the request and confirm that your information is in our system. Information provided to submit a request will only be used for request purposes.

California consumers may make requests by either:

  • Emailing your request to customerservice@hedleyb.com. In the subject line of your email, please write “CCPA Rights Request”; or
  • Mailing us a letter to the address listed below in our Contact Us section.

Notice of Financial Incentive Programs.

We offer consumers the ability to become a member, which provides certain perks, rewards, and exclusive offers. We may also provide consumers with price discounts and coupons, as well as access to programs, such as sweepstakes, contest, or other similar promotional campaigns. These programs may be considered “financial incentives” programs under California law.

For our programs, follow the directions provided with the program announcement to learn the terms of such programs and opt-in.

When you sign up for one of these programs, we may ask you to provide your contact details (such as email address and/or phone number), collect information about your activities on our Site and your purchases, and draw inferences about your preferences, and collect other categories of Personal Information about you. The value of your Personal Information to us is reasonably related to the value of the perks, rewards, exclusive offers and discounts, or other benefits that are provided as part of the applicable program. We estimate the value of Personal Information by considering factors, including but not limited to, expenses related to the collection, storage, and retention of Personal Information in the context of the program and the expenses related to the administration of the program. The overall value of Personal Information to us is depends on what offerings you take advantage of and whether you opt-out of any offerings.

Your participation in any financial incentive program is optional, and you may withdraw from the program at any time:

  • For marketing-based incentives, you may unsubscribe by following the instructions in the communication.
  • For membership-based incentives, you may delete your account through your account settings or via email to customerservice@hedleyb.com. Please use the include “Financial Incentive Program Opt-Out” in your request.

Shine the Light Notice. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain Personal Information are entitled to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, contact us through the contact information in the Contact Us section below, and include in your request a current California address and your attestation that you are a California resident.

Contact Us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us at: (i) by mail at Hedley and Bennett, Inc., 3864 S. Santa Fe Ave., Vernon, CA 90058; or (ii) by email at customerservice@hedleyb.com.