- Whose Personal Information Do We Collect
The Company collects personal information from a range of individuals in the context of our business activities, including from the following: consumers and customers; individuals that use, or otherwise access, our Site; individuals who visit our premises or facilities; representatives of our suppliers, customers and other business contacts; contractors and similar types of workers; individuals related to, or otherwise affiliated with, our Company’s employees; and, individuals who contact us by any means.
- The Types and Categories of Personal Information We Collect
We may collect personal information under a broad range of circumstances. Generally, we collect the following types of information directly from you:
- Identity data, such as your name, title, company/organization name, e-mail address, telephone and fax numbers, physical address (including street, city, state, postal code, and/or country), and date of birth.
- Registration data, such as information provided by you when you register for an account to use our Site, including user names and passwords.
- Business contact data, such as information related to other 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 may conduct, or possibly conduct, business activities.
- Rewards Program data, including identity and registration data, and information pertaining to your involvement and transactions in the Rewards Program. For our Military Discount program, we will collect and retain information pertaining to your proof of military service (e.g., military email address or photo copy of a government/military ID).
- Marketing and communications data, including your marketing preferences and your subscriptions to our publications.
- Transaction data, including orders for our products and services and details of payments to and from you, including purchase history and preferences and (limited) payment card information.
- Your feedback, including feedback from you about our Site as well as our products and services generally, which may include data gathered from any Company surveys in which you participate.
When you do not provide personal information that the Company requests, we may not be able to provide you the requested service or complete a transaction, and you agree that the Company will not be liable or otherwise responsible for any actions resulting therefrom.
- How We Collect Personal Information
Most often, we obtain personal information directly from the individual. For example, when individuals undertake the following activities, we generally collect their personal information:
- Use or access our Site and/or complete one of our web forms.
- Contact our customer service centers or request information from us in any other way.
- Visit one of our premises.
- Submit an order to, or make a purchase with, the Company.
- Provide us personal or business contact information via a business card or through similar communications.
- Complete a survey or otherwise provide us feedback.
- Communicate with us via social networking websites, third party applications, or similar technologies.
- Visit one of our trade counters at an exhibition.
- How We Use your Information
The Company may use personal information for several business and administrative purposes, or to further our legal or other business interests. Generally, we use personal information for the following reasons:
- Services and transactions. We may use your personal information to deliver services to you or carry out transactions you have requested, including, but not limited to, providing information on the Company’s products or services you have purchased or otherwise use, processing product orders, handling warranty claims, answering customer service requests, and facilitating the use of our Site.
- Marketing. In accordance with applicable laws and regulations, we may use your personal information to inform you of our products or services which may be of interest to you, and to otherwise communicate with you about offerings, events, news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge by using the “unsubscribe” link in any e-mail marketing materials you receive from us.
- Enforcement and Business Interests. We may use the personal information we collect in order to detect, prevent and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse of our Site, products, or facilities. We may use personal information to administer and protect our business and our Site, including system maintenance, support, reporting and hosting of data. We may, in our sole discretion, use personal information to promote, defend or protect our legal, regulatory, or business interests.
- Sharing Information
We may share your personal information with selected third parties in accordance with applicable law, including as set out below.
- Service Providers. We may share your personal information with other companies with whom we have contracted to provide services on our behalf, such as hosting websites, conducting surveys, processing transactions, supporting our Rewards Programs, facilitating our marketing activities, analyzing our Site, and performing analyses to improve the quality of our business, Site, products and services. We may also disclose your personal information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, obtaining employment verification and background checks. The Company uses YotPo Ltd, and SquareUp to assist with our e-commerce platforms. The Company uses Zendesk to assist with our customer support functions and Lever to support our job recruitment platforms. We use Adobe Sign to facilitate the signature and execution of legal contracts and other documents.
- Distributors and Business Partners. We may share your personal information with third parties that distribute our products to you and engage in similar routine business functions. The Company uses JCS for order fulfillment services, RetentionScience and MailChimp to support our email and marketing programs, and Code3 to support our digital marketing activities.
- Business Restructuring. Circumstances may arise where the Company decides to sell, buy, divest, merge or otherwise reorganize our business in some countries. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.
- Disclosure for Other Reasons. We may disclose personal information if required or authorized to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property or, in urgent circumstances, to protect the personal safety of any individual. We may share your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, and business interests. We may also disclose your information upon your express consent.
In the event that you facilitate a transaction with the Company, or request information from, or otherwise engage with us, and such activities require the Company (in our reasonable judgment) to share your personal information with a service provider or other third party, you hereby direct the Company to intentionally disclose your personal information to the service provider or third party as described herein provided the service provider or third party does not, in its reasonable judgment, sell the personal information, unless that disclosure would be consistent with the law.
- Legal Basis for Data Processing
In order to comply with certain applicable data privacy laws, the Company is required to set forth the legal basis for the processing of personal information. In accordance with the purposes for which we collect and use personal information, as set out above, the legal basis for the Company’s processing of personal information will generally be one of the following, which are not mutually exclusive: for the performance of a contract that we have in place with you or other individuals, or to take steps at your request prior to entering into a contract; to support the Company or our third parties’ legitimate business interests (e.g., maintaining and promoting our business by providing customers with feedback opportunities, website security and auditing); to comply with our legal obligations; and, with your consent.
- Links to Other Websites
- Data Retention and Localization
We are committed to protecting the security of your personal information. We 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, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks, and you provide us with any information and data at your own risk. The Company shall not be liable or otherwise responsible for any data incidents 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 user ID and password to access the Site, you are responsible for maintaining the security and confidentiality of those log-on credentials and not revealing them to others. You must contact us immediately if you have to reason to believe that your user ID or password to our Site have been compromised.
- No Data Collected from Children
Our Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under sixteen (16) years of age with or without consent from their parents or guardians. If you are under the age of sixteen you are prohibited from using our Site or with providing us with your personal information, unless you can demonstrate affirmative authorization from your parent or legal guardian to do so.
- Cookies, Analytics, and Ads
We use different analytic tools which serve the purpose of measuring, analyzing and optimizing our Site’s performance, marketing, and providing you with customized advertisements that could be of particular interest to you. More specifically, we use tools and programs from the following sources:
- Google Analytics, Google Tag Manger, Google Ads, and Doubleclick. To see how you can opt-out of certain Google features and to better understand Google privacy practices, visit: Google Analytics Opt Out Link.
- Facebook. To find out more about the privacy settings by Facebook and the options to change them, please see Facebook Privacy Settings Link (you must be logged into your Facebook account).
- Pinterest. We use Pinterest cookies and online tools to deliver ads to you and to find other people who might be interested in our products and show them online ads relating to our products on Pinterest. To be clear, your information will be shared with Pinterest for online behavioral advertising, and you can opt-out of online behavioral advertising through Pinterest’s personalization settings or as described below. To learn more, please visit your Pinterest privacy notices at https://help.pinterest.com/en/article/personalization-and-data and here https://help.pinterest.com/en/article/personalized-ads-on-pinterest.
You can find more information about cookies, behavioral advertising and online privacy at www.allaboutcookies.org. For some of our service providers that participate in the Digital Advertising Alliance (DAA), you can exercise your choice to opt-out of interest-based advertising at http://optout.aboutads.info. You may also opt-out of receiving interest-based ads from many third party websites and applications through the Network Advertising Initiative’s (NAI) Opt Out Tool which is available at http://www.networkadvertising.org/choices. Certain types of mobile devices have a identifier that provides organizations with the ability to serve targeted advertising directly to a specific mobile device, and you may (depending on the device) be able to limit advertising, reset the advertising identifier, and turn-off your device’s tracking features within your device’s settings. For more information see http://youradchoices.com/appchoices.
- Your Rights and Responsibilities
You are permitted, and hereby agree, to only provide personal information to the Company 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 any individual’s data privacy rights or privileges. If you provide the Company with any personal information about a third party, you expressly represent that you have the full right and authority to submit the information to the Company.
Depending on the jurisdiction in which you reside or the Company operates, you may have certain data protection rights. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request, where permitted by law. The rights afforded under data protection laws are not absolute, and the Company may be permitted to refrain from undertaking any action or changing its data processing activities, in response to a data request you submit to us.
Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option of not receiving such communications from us in the future. California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties with whom we have reason to believe use such information for their own direct marketing purposes.
California Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), certain California residents may have additional data privacy rights, such as the right to be notified about what personal information is collected about you, and our intended use and purpose for collecting your personal information. In some circumstances, California residents have the right to know and access the categories or specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months; the categories of sources from which the personal information is collected; and, the business or commercial purpose for which your personal information was collected, used, disclosed, or sold. In addition, certain California residents have the right to request the Company transfer, to the extent feasible, personal information in certain forms and formats. California residents have the right to request that we (and any applicable service provider) delete/erase your personal information under certain circumstances.
In some circumstances, certain California residents have the right to opt-out of the sale of their personal information. The Company does not sell your personal information to third parties for profit. However, (as describe above) we do use third party website analytical tools and features, marketing partners, and other service providers, and such relationships may involve the disclosure of your personal information in a manner that may constitute a “sale” of personal information under the CCPA.If you would like to opt-out of the disclosure of personal information in these circumstances, please click on the “Do Not Sell My Personal Information” link on the applicable Site or contact us in accordance with the instructions set forth below. Our Site is not directed to, and should not be used by, minors under the age of sixteen (16) and therefore the Company does not knowingly “sell” (as defined by the CCPA) the personal information of minors under sixteen (16) years of age without affirmative authorization.
California residents have the right not to be subject to discrimination for asserting their rights under the CCPA. If you make, or an authorized agent on your behalf makes, any request related to your personal information under the CCPA, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required under the law before addressing your request. The Company may require you to match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, 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.
Do Not Track. 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 even are aware of them. We currently do not take action in response to these signals.
Text/SMS Message Consent; Opt-Out and Notice Obligations. You may, in your sole discretion, provide the Company with your mobile telephone number in order to receive text messages from us, such as messages and alerts related to our products, events, and/or promotions. By providing us with your mobile telephone number, you (i) expressly represent that you are the owner of, and have the authority to provide, the mobile telephone to us for these purposes, and (ii) hereby consent to receive from us automated marketing text messages at the mobile telephone number so provided. You further acknowledge that your consent to receive automated marketing text messages from us is not, in any form or manner, contingent upon, or required to make, a purchase for goods or services. Standard text/SMS message and data rates will apply and you should check the rates of your mobile carrier prior to providing us with your mobile telephone number. You can opt-out from further text marketing communications by texting STOP to the SMS number used by us to contact you or by contacting us directly in accordance with the “Contact Us” section listed below. We may share your mobile phone number with service providers with whom we contract to assist us with our marketing activities, but we will not share your mobile phone number with third parties for their own marketing purposes without your consent. Because text messages are distributed via third party mobile network providers, we cannot control certain factors relating to message delivery. Depending on your mobile carrier, it may not be possible to transmit the text message to you or your mobile device successfully; nor is our content available on all carriers. We do not claim or guarantee availability or performance of this service, including liability for transmission delays or message failures. Without limiting any of the foregoing, you hereby agree that you will immediately and without delay (and within 72 hours) notify the Company in the event you no longer are the owner of any mobile telephone number provided to the Company or have the authority to use any such mobile telephone number to receive text messages.
- Changes to the Policy
- Contact Us
Email: [email protected]
Mail: Walker & Co. Brands, Inc.
ATTN: Data Privacy
2870 Peachtree Rd NW #402
Atlanta, GA 30305
- Effective and Amendment Date