PRIVACY POLICY

Last Updated: May 24, 2023

French Canadian (Translation)

Thank you for your interest in Walker & Co. Brands, Inc. (hereinafter, “Walker,” “we,” or “us”). This Privacy Policy sets forth the terms and conditions with respect to how we process personal information about you and other third parties. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information. This Privacy Policy applies to the personal information you provide us when you visit any of our websites (collectively, our “Websites“), purchase or receive products, goods, or services from Walker, apply for a job with Walker, or otherwise contact or engage with us. Our Websites include:

For purposes of this Privacy Policy, our Websites and all products, goods and services furnished by Walker shall be referred to collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND THE WALKER TERMS OF USE AND COOKIE POLICY, EACH BEING INCORPORATED INTO, AND FORMING AN INTEGRAL PART OF, THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AND THE WALKER TERMS OF USE AND COOKIE POLICY, THEN YOU SHOULD NOT USE WALKER’S SERVICES, AND YOU SHOULD LEAVE OUR WEBSITES IMMEDIATELY AND NOT PROVIDE WALKER WITH ANY PERSONAL INFORMATION.

1. Scope

This Privacy Policy applies to personal information that Walker receives during its business operations. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and is not otherwise subject to a data protection law, statute, or regulation. Walker may anonymize or de-identify personal information, and such anonymized or de-identified data is not subject to this Privacy Policy, and Walker may use such data for any purpose.

2. The Types and Categories of Personal Information We Collect

Walker collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to Walker, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

Personal Information
Category Description/Examples
Personal Identifiers Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer identification number.
Registration Data Information provided when you register for an account to use our Websites, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below) Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier,
an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Commercial Information Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.
Business Contact Data Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Health Data You may furnish us with health-related information in the event you, or a third party, has an adverse reaction to the use of our products or goods.
Marketing and Communications Data Information with respect to your marketing preferences and your subscriptions to our publications and alerts.
Internet and Electronic Network Data Data pertaining to your access or use of our Websites, including browsing history, search history, and information regarding your interaction with our Websites or advertisements embedded on our Websites or other third-party websites.
Your Feedback Information you provide about our Services, which may include data gathered from any Walker surveys or reviews submitted by you.
Visitor Information Information an individual provides when visiting any physical location or premises of Walker (e.g., visitor logs and registries, vehicle and parking information).
Video and Images In some circumstances, you may provide us images (e.g., your use of a product) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing.
Geolocation Data Information about the general city, state, or region in which a user of our Websites is located.
Data (For more information, see “Employment Applications and Talent Management” below) If you apply for a job with Walker, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.
Inferences Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.

3. Technical Data

When you access our Websites, we collect certain data automatically using technical means and tools. This data relates to your device and your experience on our Websites and other third-party websites, including the following:

Usage and Device Data. When you access and use our Websites, we automatically collect details of your access to and use of our Websites, including traffic data, usage logs and other communication data, and the resources that you access and use on or through our Websites (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. Our Websites may collect “diagnostic” data related to your user experience, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within our Websites. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of our Websites may become inaccessible or not function properly. In addition, our Websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of our Websites (e.g., recording the popularity of certain content and verifying system and server integrity). Our Websites may collect data about the advertisements you have seen or engaged.

For more information, see our Cookie Policy.

Site Monitoring. Please be aware that we use cookies and other tracking technologies within the Websites to monitor and record any and all activities and communications to, from, and on the Websites in order to safeguard, improve, and analyze usage of the Websites, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, the monitoring and recording of all such activities and communications. 

4. Sources of Information

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using our Websites, and from third parties. More specifically, we collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing purchases, signing-up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use our Websites (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising and research companies, our service providers, and third-party references.

5. How We Use Your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our Services, (ii) enable you to access and use our Services, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Services, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests (e.g., marketing), (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities, and (x) personalize our Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, Walker may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that Walker may contact you via any means, including SMS/text message and email, to furnish you information regarding a product order, shipping status, warranty-related information, and similar data and information pertaining to a commercial transaction.

Mobile Messaging Program. In the event you opt in to our Mobile Messaging, we will collect and use your mobile telephone number to maintain and administer our Mobile Messaging Program. With your permission, we may send text messages about our store, new products, and other updates, including “Checkout/Abandoned Cart Reminders,” and we use cookies, pixels, tags, and other webhooks to track your shopping behavior and trigger the Checkout/Abandoned Cart Reminders messaging system. Please review the Walker Terms of Use for more information about these Mobile Messaging Program, including information on how to unsubscribe or update your personal information therein and your responsibilities and liabilities related thereto.

6. Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing our Websites, conducting surveys and marketing on our behalf, processing transactions, and performing analyses to improve the quality of our Services. For example, Walker uses SquareUp to assist with our e-commerce platforms, Zendesk to assist with our customer support functions, and Adobe Sign to facilitate the signature and execution of legal contracts and other documents.

Payment Card Transactions. All payments for purchases made through our Websites are completed using a third-party vendor’s online payment system. Walker does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information. Walker currently uses Braintree as our payment gateway and processor and Bill.com to provide cloud-based software to automate and assist with our financial operations, including paying invoices and receiving payments. If you have any questions about payments or would like to dispute a charge, you can contact us at [email protected]

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials. For example, Walker uses JCS for order fulfillment services, and Code3, RetentionScience and MailChimp to support our marketing and digital advertising programs.

Marketing Partners. We have partnered with third-party service providers with whom we share Online Identifiers concerning your use of the Site, which are derived through the cookies, pixels, and tags that we (or our partners) embed on our Site. These third-party service providers may consolidate your personal information with other data in order to create profile and marketing leads for their own clients. If you would like to opt out from this information sharing, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” or a “Do Not Sell/Share My Personal Information” link) on the footer of the Site to set your cookie and tracking preferences.

Business Restructuring. Circumstances may arise where for strategic or other business reasons Walker decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of Walker’s assets.

Disclosure for Other Reasons. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, Walker may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.

In the event that you facilitate a transaction with Walker, or request information from or otherwise engage with us, and such activities require Walker to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct Walker to intentionally disclose your personal information to the service provider or third party, provided Walker has determined, in its reasonable judgment, that either (i) the service provider or third party will not sell the personal information or (ii) disclosing the personal information is required or permitted by law.

Notwithstanding the foregoing, with respect to text messaging originator opt-in data and consent, such information will not be shared with any third parties, except to our service provider managing our text messaging enrollment process and/or to comply with legal and regulatory requirements.

7. Social Media

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on one of these platforms for customer support or otherwise, we may contact you via the social media’s direct message tools. Those communications are governed by this Privacy Policy as well as the policies and terms of the relevant social media platform. The information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. Our Websites includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on our Websites. These features may collect your IP address and which site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

8. Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, our Websites may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

9. Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

Walker is based in the United States, and the personal information that we collect and process is retained and stored in the United States. Walker uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. You hereby acknowledge that your personal information must be transferred to, and stored in, the United States and in other third countries, as described herein, in order for Walker to provide you the Services.

10. Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO OUR WEBSITES AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT CAUSED BY A THIRD PARTY THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

11. No Data Collected from Children

Our Websites are not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under eighteen (18) years of age. If you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including our Websites) or with providing us with your personal information, unless you provide us written and verifiable authorization from your parent or legal guardian permitting you to do so.

12. Publicly Posted Information; Product Reviews

Our Websites may provide you with the ability to submit a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”) or provide other information on our Websites which may be posted to a publicly available portion of our Websites. Any information or content you post in a Product Review will be available to other users of our Websites and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review that you wish to remain confidential. Any third party with access to your information via our Websites will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on our Websites is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available.

13. Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to Walker if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO WALKER, YOU EXPRESSLY REPRESENT AND WARRANT TO WALKER THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE WALKER WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT WALKER’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY WALKER FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO WALKER.

14. Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. You have the ability to update your personal information at “checkout” when you purchase a good or product. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address) and you must do so when such changes are warranted. If your account does not contain such features, then you must directly notify Walker of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.

15. Email Marketing and Your Rights

You have the right to opt out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify Walker, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.

16. SMS/Text Marketing and Your Rights

Walker offers a Mobile Messaging Program in which we send participants text messages related to our Services, marketing programs, and discounts. By participating in the Mobile Messaging Program, you agree to receive autodialed or prerecorded marketing mobile messages and you understand that you are not required to make any purchase from us to participate in our Mobile Messaging Program. Message and data rates may apply to such communications. For more information about the Mobile Messaging Program, please see the Walker Terms of Use. You hereby agree to immediately notify Walker, in writing, in the event you no longer own, license, or use the telephone number that you used to enroll into our Mobile Message Program.

17. Canada Privacy Rights

Walker will collect, store, use, and process “personal data” (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”)) in accordance with this Privacy Policy and Walker’s obligations under PIPEDA and other applicable Canadian provincial laws (collectively, “Canadian Data Protection Law”). Pursuant to Canadian Data Protection Law, you have a right to request access to your personal data and to request that inaccurate personal data be corrected. If you have submitted personal data to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal data, we will require that you verify our request via email and request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee to access your personal data, provided however, we advise you of any such fee in advance. Your right to access personal data is not absolute, and we may not be able to allow you to access all of your personal data in certain circumstances (e.g., if it contains personal data of other persons or the data is subject to legal privilege). In the event that we cannot provide you with access to, or correct, your personal data, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or email), please follow the applicable opt-out instructions listed above (see “SMS/Text Marketing and Your Rights” and “Email Marketing and Your Rights”) or contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

18. California Privacy Rights

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Right Act of 2020 (“CCPA”), California residents are entitled to certain data privacy right:

Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) [email protected] or (mail) Walker & Co. Brands, Inc., ATTN: Privacy Champion, 2870 Peachtree Rd NW #402, Atlanta, GA 30305. An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information, Walker will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, Walker will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the “sharing” of their personal information. Walker uses third-party analytical and targeted advertising features on our Websites and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Websites) to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.

Children. The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore Walker does not knowingly sell or share the personal information of minors under sixteen (16) years of age.

Limit Use of Sensitive Personal Information. Walker does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.

19. Nevada Privacy Rights

Walker does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.

20. Virginia Privacy Rights

Data Privacy Rights. Pursuant to the Virginia Consumer Protection Act, Virginia residents are
entitled to certain data privacy rights:

Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) [email protected] or (mail) Walker & Co. Brands, Inc., ATTN: Privacy Champion, 2870 Peachtree Rd NW #402, Atlanta, GA 30305.

Privacy Request Verification Process. If you make any request related to your personal information, Walker will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, Walker will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. None of Virginia’s privacy rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the Virginia Consumer Protection Act, please see: https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.

Privacy Requests Appeals Process; Complaints. If you would like to appeal a decision Walker has made with respect to your privacy request, please email [email protected] with the subject line “PRIVACY REQUEST: APPEALS” and describe the nature of your request, and the reason requesting an appellate review. Virginia residents may file privacy complaints with the Virginia Attorney General (https://www.oag.state.va.us/contact-us/contact-info).

Opt-Out Rights / The Sale of Personal Information. Virginia residents have the right to opt out of the “sale” of their personal information. However, Walker does not sell your personal information to third parties for or monetary consideration, and therefore we do not provide opt- out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Virginia residents have the right to opt out of having their personal information used for targeted advertising purposes. Walker uses third-party analytical and targeted advertising features on our Websites and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Websites) to set your cookie preferences.

Opt-Out Rights / Profiling. Virginia residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Walker does not engage in such activities.

21. Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

22. Persons with Disabilities

Walker strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

23. Rewards Programs and Financial Incentives

We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. Walker may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy.

California Rewards Program Rights. Pursuant to the CCPA, you may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of the value of your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personal information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good-faith effort often involving (i) the categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value described herein is not intended to waive, nor should it be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

24. Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. Walker uses Lever to support our job recruitment platforms. We may share your personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

25. Events and Video Teleconferencing

Walker hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

26. Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy signifies your consent to this Privacy Policy and any amendments hereto, which shall supersede and control over any previous privacy terms and conditions. We may, in our sole discretion, provide you direct communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

27. Contact Us

We have appointed a Privacy Champion to oversee compliance with this Privacy Policy. If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact our Privacy Champion at the following: (email) [email protected] or (mail) Walker & Co. Brands, Inc., ATTN: Privacy Champion, 2870 Peachtree Rd NW #402, Atlanta, GA 30305.