Privacy Policy

This privacy policy (“Privacy Policy”) explains how (“Company,” “we,” “our,” or “us”) collects, uses, shares, and protects information when you (“you” or “your”) use our websites and any mobile or software applications where this Privacy Policy is posted or when you purchase goods or services from us (collectively, the “Website”). Please review this Privacy Policy. By using our Website, you agree to these privacy practices; if you do not agree to these terms or our Terms of Service, you may not use the Website.

What types of information do we collect?

“Information,” as used in this Privacy Policy, means personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user. Examples include a user’s name and email address.

Company collects the following categories of information about Website users:

Identifiers and Contact Information. We collect identifiers and contact information, such as your name, email address, telephone number, and postal address, when you use the Website, including if you purchase products, enroll in our PROMO RETAIL OUTLET VIP MEMBERSHIP, or use an account to access PROMO RETAIL OUTLET VIP MEMBERSHIP benefits. This information includes personal information described in California Civil Code §1789.80.
Transaction and Payment Information. The Website is hosted by Shopify Inc. If you make a purchase on the Website, we and/or Shopify will collect your order, payment, and shipping information, such as your credit card number, expiration date, CVV code, billing address, and shipping address, to process and fulfill your orders, including if you purchase products or enroll in our PROMO RETAIL OUTLET VIP MEMBERSHIP. For more information about charges for the PROMO RETAIL OUTLET VIP MEMBERSHIP, see our Terms of Service. Additionally, when you click on product links or place items in your shopping cart, we collect commercial information about your shopping preferences and consuming history and tendencies.
Internet, Device, and Network Activity Information. When you use the Website, we automatically gather information made available by your web browser, internet service provider, and device (such as your computer, phone, tablet, or smart watch), depending on your settings for each. For example, we may collect your IP address, information about the operating system or type of device used, the device ID associated with your device, the date and time you access the Website, and your log in attempts. We may also collect information about your browsing and search history and information regarding your interaction with a particular website, application, or advertisement, including the Website; and we may collect information regarding the websites, applications, or advertisements you visited immediately before and after your use of the Website.
Geolocation Information. We collect your approximate location from your IP address.
Public Content. We may collect public content (“Public Content”), such as when you post a review about our Website. Once you submit Public Content, neither you nor Company can control how it may be copied, shared, or used by third parties, even if you and/or Company later delete such Public Content. Accordingly, you should carefully consider what personal information you choose to include within your Public Content.
Other Information. We may collect other information from you, such as when you make a claim for a promotion run on the Website, when you request assistance through customer service, or when you voluntarily subscribe to newsletters or reminders. You will always be asked for your consent in advance of providing such other information. Further, we may collect protected class information, such as your gender or age, including if that information is ascertainable from your use of the Website or saved shopping preferences.

How and when do we collect information about you?

Company gathers the types of information referenced in Section 2 through the following sources and means:

When you enter or upload information to the Website. We collect information you provide, including when you make a purchase or save shopping or payment preferences.
When you communicate with us. We collect information from your communications, such as when you email us, contact customer service, or communicate via social media.
Through cookies, tracking tools, and other automated technologies. When you access the Website, your web browser automatically sends us device and internet connection information and certain internet activity information as described in Section 2. “Cookies” are files that are placed on your computer or other device by websites you visit. The primary purpose of a cookie is to identify you as a unique user of a website. Company uses cookies and web beacon technology to gather device and internet connection information, internet activity information, and geolocation information.
In particular, Company uses the following types of cookies, some of which are placed by third parties, to customize your shopping and checkout experience:

Type of Cookie Purpose of Cookie

Necessary

Necessary cookies are essential for the Website to display and perform properly and are used to identify you, prevent security risks, and allow you to perform account-related functions.

Preferences

Preferences cookies are used to store preferences set by you and each user for their account, such as your language preferences, and improve your experience using the Website.

Analytics and Performance

Analytics and performance cookies collect information on how you and other users interact with the Website. Often, this information is aggregated and used to improve the Website.

Advertising

We may also use advertising cookies and web beacons, including those placed by third parties such as Google and Facebook, to deliver personalized advertisements that may be of interest to you. We may also use a web beacon in email messages sent to track your response. Cookies and web beacons also help Company and third-party advertising partners ensure you do not see the same advertisements over and over and to block unwanted ads. We may use these tracking tools to better understand your behaviors and browsing activities.

We also use the Shopify platform. As such, we use Shopify cookies and other tracking technologies to provide and improve the Website. You can learn more about how Shopify gathers and uses personal information by visiting the Shopify Cookie Policy.

Company also uses Facebook cookies and tools, such as lookalike audiences, custom audiences, and for retargeting and to deliver personalized advertisements to you. You can learn more about how Facebook gathers and uses personal information via cookies, including how to set your cookie preferences within Facebook, by visiting the Facebook Cookie Policy. We may also use Google cookies and tools, such as Google Analytics, on our Website to collect usage data, analyze how users use the Website, and provide advertisements to you on other websites. For more information about how to opt out of this practice, visit the Google Analytics Opt-Out Add On page.

You can change your cookie settings in your internet browser and use preferences or settings on your device to manage your privacy controls. However, if you disable cookies or other tools, some of the features of the Website may not function correctly. For more information, see https://www.allaboutcookies.org/; and to learn more about targeted advertising, including how to revoke consent and disable tools and how to opt out of third-party cookies and collection of mobile device IDs, see below and the links here and here.

From third parties. Company may collect transaction and payment information as well as other personal information from service providers (such as payment processors and shipping providers) as is necessary to complete Website transactions.

How do we use your information?

Company may use the information identified in Section 2 for certain “business purposes” that are necessary to provide the Website and for certain “commercial purposes,” meaning a use that advances our business interests, such as marketing the Website.

Importantly, when you provide your name along with contact and billing information, which may include sensitive personal information such as your credit card number and code, such as to make a purchase on the Website, we only use and disclose that information as necessary and reasonably expected to provide the products or services requested by you.

The following are the business purposes for which we may use your information:

To process and fulfill your orders, including for billing and fulfillment purposes related to your purchases of products on the Website and the PROMO RETAIL OUTLET VIP MEMBERSHIP.
To personalize your user experience, such as by using cookies to allow you to set personal preferences when using the Website, and to make it so you don’t have to re-enter the same information when you visit the Website several times in a short timeframe.
To communicate with you, such as by responding to your requests, sending you marketing emails with information that may be of interest to you (see below for more information), notifying you about your purchases, logistics, deals, and promotional offers, and sending you any applicable updates to our Terms of Service or this Privacy Policy.
To improve the Website and related goods and services, including by considering analytics, demographics, and user feedback to improve or repair the Website.
To secure the Website and related purposes, such as by detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and identifying and prosecuting those responsible for that activity.

The following are the commercial purposes for which we may use your information:

To advertise to you, for example, using information gathered through cookies and web beacons, including those placed by third parties, to deliver advertisements specific to your personal interests. You can learn more about retargeting practices, including how to revoke your consent, by visiting these websites or contacting us:

www.youronlinechoices.com/uk/your-ad-choices

www.networkadvertising.org/choices

www.aboutads.info/choices

To advertise public content to others, such as by sharing your reviews about us.

We may also use your information, combined with that of other users, to create deidentified “Aggregate Information,” which is statistical information about all users or a subset thereof and is pseudonymized and deidentified, i.e., cannot be used to identify or relate back to you. Aggregate Information may be used by Company for the purposes listed above. We may also use Aggregate Information to develop use cases that compare average industry trends.

In other words, we process your data when necessary to perform our responsibilities under a contract with you (e.g., providing and processing payments for the products you have ordered), if we need to comply with a legal obligation, if necessary for the purposes of legitimate interests unless they are overridden by your interests or rights, to protect the vital interests of users, or when we have your consent to do so, which you may withdraw by contacting us as outlined below.

How do we disclose your information?

Company may disclose your information with the following third parties for the business and commercial purposes that are indicated:

Service Providers. Company shares your personal information with service providers, such as payment processors, couriers and fulfillment sources, shipping providers, customer service and support contractors and agencies, and marketing agencies, to complete and fulfill your orders, operate the Website, communicate with you, and so forth.
Affiliated Entities. Should Company be subject to an acquisition, merger, sale or other change of control or business entity status, or a bankruptcy, we reserve the right to transfer or assign your information as part of that acquisition, merger, sale, or bankruptcy. Company may also share your information with any affiliated entities, which are businesses that are directly related to us and have common ownership, where your information is still treated in accordance with this Privacy Policy.
Government Officials and Other Parties. To comply with our legal obligations, we may disclose your information in response to subpoenas, court orders, and other valid legal processes. We may also disclose personal information when we believe it is necessary to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals.
Advertising Partners. We may disclose information as needed to advertising partners. For example, we may share information gathered through cookies and tracking tools to allow a third party to advertise our products to you after you leave the Website.
Other Users. We may share your Public Content, such as reviews and comments about the Website and our products, including by reposting your reviews on the Website, in our advertising, and through our social media accounts.

Company does not sell consumers’ personal information for money. However, please note that the California Consumer Privacy Act (“CCPA”) defines “sale” of “information” very broadly to cover many common business activities, even when the information is partially de-identified and is not exchanged for money. As outlined above, the Website uses cookies and other tracking tools, including those placed by, and where information is shared with, third parties. The primary purpose of this practice is to deliver personalized advertisements that are specific to your interests and to avoid displaying repetitive or irrelevant advertisements to you. Although Company’s practices may not constitute a “sale” of personal information, you have the right to direct us to not use your information for these practices. You may do so by disabling cookies and other tools or visiting informational websites, as outlined above, or contacting us.

How do we protect your information?

We maintain safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the internet can be 100% secure. As a result, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from our Website, and you do so at your own risk. The security of your personal information also depends on you. You should protect and refrain from sharing your sensitive personal information and immediately notify us or impacted third parties of any suspected data breach, including any unauthorized logins to your account or misuse of your account credentials.

How long do we keep your information?

We retain your information as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or a valid court order. If you request deletion of your information, your request will be processed according to the timeframes indicated therein and/or pursuant to any applicable legislation.

Do we transfer your information to a different country?

If you are visiting the Website, your connection will be through and to servers located in the United States, and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States. By using the Website, you authorize and consent to the transfer of personal data to the United States and its storage and use as specified above when you provide such information to us.

Privacy Rights

Process for Making a Request

To make a privacy request regarding your personal information, please contact us as outlined below with your name and either your email address or physical address associated with your use of the Website. If you are making a privacy request through an authorized agent, please also provide the agent’s name and email address and statement of authorization. If we need additional information to verify your identity or process your request, we will promptly respond to you. Under certain privacy laws, consumers have specific privacy rights, as outlined below.

California Residents

California residents have the following rights under California privacy laws:

Right to access and correct your personal information;
Right to request disclosure of the categories of information collected about you, the categories of sources from which the information is collected, the business or commercial purpose for collecting or selling information, the categories of third parties with whom we share your information, and specific pieces of information we have collected about you;
Right to opt out of certain privacy practices, including any sale of information;
Right to request deletion of personal information collected about you; and
Right to no discriminatory treatment (and Company will not discriminate against you, for example, by charging you a different price for exercising your rights).

In addition, under California’s “Shine the Light” law, California residents who provide information to the Website may request certain information regarding our disclosure of your information to third parties for their direct marketing purposes.

Nevada Residents

Nevada consumers have the right to request that Company not sell their personal information for monetary consideration to certain other parties.  This right applies even if their personal information is not currently being sold.  If you wish to make a request, please contact us.

European Economic Area Residents

Residents of the European Economic Area have the right to access information we hold about you and to ask that your information be corrected, updated, or erased, and the right to object to, or request that we restrict, certain processing of your information. You also have the right to lodge a complaint with the data privacy authority where you live, see e.g., this website.

How do we protect the privacy of children?

Company does not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected such information, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to third parties.

How can you receive and opt out from marketing communications?

By providing your email address to Company through the Website or an email initiated by you, you consent to receive emails from us, including information concerning your account and advertising messages. Depending upon your location, we may obtain additional consent from you if required. Providing consent to promotional emails is NOT a condition of purchasing any of our products. You can unsubscribe to advertising emails at any time by clicking the unsubscribe link within the email, or by contacting us as outlined below. Please note that, even if you unsubscribe from advertising emails, we will still send you any necessary, non-promotional emails about your purchase, account, or updates to our Privacy Policy and Terms of Service.

Links to third-party websites.

Our Website contains links to websites operated and maintained by third parties. We do not make any guarantees, promises, or warranties regarding any third-party websites or content, we do not control third parties and have no responsibility for third parties, and your use of such third-party websites is at your own risk. This Privacy Policy does not apply to such third-party websites. The Website contains a “share” feature, which allows you to share content through your social media accounts. If you use this feature, you will be redirected to the third-party social media platform, which we do not control. You should always read the privacy policy of a linked website before disclosing your information.

Do Not Track (“DNT”)

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked. We do not respond to DNT requests.

How will you know when we change the Privacy Policy?

Each time you use the Website, the then-current version of this Privacy Policy, which will be posted on the Website, will apply. If you continue to use the Website after a new version is posted, you are consenting to the modified terms. Depending upon your location, we may obtain additional consent from you if required. Further, unless we receive your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy and not to information collected under any earlier version.

How can you contact us regarding this Privacy Policy?

Company controls the information and data provided to and collected by us. If you would like to access, correct, amend, or delete any personal information we have about you, make a complaint, or simply want more information, please contact us. When you contact us, your information may be collected, used, and shared in connection with your request.

Customer support inquiries and returns should be directed through the CONTACT US form.