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Privacy Policy

Privacy Notice

We at Rauch Brands, including our Christopher Radko, kat + annie, and Jay Strongwater brands, are committed to protecting the privacy and security of personal information and transparency about how we use personal information (also known as personal data). This Privacy Notice sets forth our policies and practices for collecting and using personal information regarding our websites (“Services”). This notice does not address our use of personal information outside the context of these Services.

Within the context of the Services, this notice explains how we use and disclose personal information. It also discusses how you can control certain uses and disclosure of personal information. We will update this notice from time-to-time, or as our privacy practices change, to ensure it accurately describes how we use your information. When we do so, we will update the dates above. We recommend that you review this notice from time-to-time for the latest information. If we change our practices in a material way, we will provide appropriate notice to you, usually through an e-mail message or through a banner or pop-up within our Services.

If you have any questions regarding this notice or our use of your information, please contact us using one of the methods detailed below.

1.         How we use and share personal information

We use and share personal information as described in the following table and the text that follows it.

Categories of individuals

Categories of personal information

Purposes

Methods of collection

Categories of third-party recipients (see below)

Lawful bases for processing (GDPR jurisdictions)

All Service users

· Activity information

· Interest information

· Non-precise geolocation information

· Personalization

· Service analysis

· Network advertising

· Directly from individual

· Indirectly by monitoring individual’s activities or behavior

· Web storefront providers

· Analytics providers

· Advertising networks

· Our legitimate interests

Service users who subscribe  to send marketing related e-mail messages

· E-mail address

· Marketing

· Directly from individual

· Service providers who assist us in conducting e-mail marketing campaigns

· Consent

Service users who place orders

· Personal contact information

· Shipping information

· Order information

· Payment data

· Order processing

· Personalization

· Marketing

· Service analysis

· Customer support

· Directly from individual

· Indirectly by monitoring individual’s activities or behavior

· Web storefront providers

· Payment processors

· To fulfill our contract with you

· Our legitimate interests

Registered service users (i.e. users who create an account for us to retain  information about them between visits)

· Personal contact information

· Access credentials

· Order information

· Order processing

· Personalization

· Marketing

· Service analysis

· Customer support

· Directly from individual

· Indirectly by monitoring individual’s activities or behavior

· Web storefront providers

· Our legitimate interests

Prospective customers, including individuals who react to online advertisements

· Interest information

· Marketing

· Indirectly by monitoring individual’s activities or behavior

· From third-party sources

· Analytics providers

· Advertising networks

· Our legitimate interests

 

Please be aware that we use third-party tracking technologies to share information with third parties for analytics and network advertising purposes, as described in the table above.

2.         Personal information disclosure and sharing

In addition to the sharing with the third parties described in the table above, we may also share your information with:  

  • Service providers. We share your personal information with third parties that provide services to us. We engage these kinds of third parties with contracts that require them to use your personal information only for the purpose of delivering the services for which we have engaged the third-party and as required by law. These kinds of third parties provide business, professional, administrative, or technical support functions for us, such as payment processing, billing, data storage, quality assurance, and marketing.

 

  • Legal compliance recipients. We disclose personal information to the courts, the government, law enforcement agencies, litigants, and similar recipients when required by law.

 

  • Successors. We may disclose personal information associated with a part of our business to a buyer, potential buyer, or other successor to our business.

 

We also may disclose personal information with third parties with your consent or at your direction.

3.         Personal information security and retention

We use reasonable administrative, technical, and physical safeguards to protect personal information in our possession. While we make every effort to help ensure the integrity and security of our network and systems, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be completely secure, accurate, complete, or current. 

We retain personal information for as long as is necessary for the purposes for which we use it, or for so long as required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when we determine how long to retain personal data:

  • Retention periods established under applicable law
  • Industry best practices
  • Whether the purpose of processing is reasonably likely to justify further processing
  • Risks to individual privacy in continued processing
  • Applicable data protection impact assessment
  • IT systems design considerations/limitations
  • The costs associated with continued processing, retention, and deletion

4.         International orders and users

For customers who reside outside of the United States, including in Canada, your personal information will be processed in the United States, where our servers are located.  When you use our Services, your information is protected by this privacy notice. In accordance with our terms of service, you agree to the processing of your personal information in the United States.

5.         Children’s privacy

We are very concerned about the safety of children using the Internet. We do not knowingly collect any personal information from those under the age of 16.

If we discover (or are informed) that we have collected personal information from a visitor under the age of 16, we will promptly delete such information.

6.         Your California Privacy Rights

If you are a California resident, you may have certain rights as a consumer regarding your personal information conferred under Cal. Civ. Code § 1798.100, et seq., known as the California Consumer Privacy Act (CCPA).

A.                 Collection of Personal Information

The following tables shows the categories of personal information we have collected in the last 12 months and indicates whether each category of personal information has been shared for a business purpose or sold to a third party.

Category

Collected

A. Identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Yes

C. Protected classification characteristics under California or federal law.

No

D. Commercial information.

Yes

E. Biometric information.

No

F. Internet or other similar network activity.

Yes

G. Geolocation data.

No

H. Sensory data.

No

I. Professional or employment-related information.

No

J. Non-public education information

No

K. Inferences drawn from other personal information.

Yes

B.                  Disclosure of Personal Information

In the past twelve months, we have sold or shared information for cross-contextual behavioral advertising purposes to third parties as described in the table below.

Category

If Sold or Shared, Categories of Recipients

Disclosed for a Business Purpose

A. Identifiers.

Third-party analytics providers and network advertisers

Service providers

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Third-party analytics providers and network advertisers

Service providers

C. Protected classification characteristics under California or federal law.

Not sold

Service providers

D. Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Third-party analytics providers and network advertisers

Service providers

E. Biometric information.

Not sold

Not used or disclosed

F. Internet or other similar network activity.

Third-party analytics providers and network advertisers

Service providers

G. Geolocation data.

Not sold

Not used or disclosed

H. Sensory data.

Not sold

Not used or disclosed

I. Professional or employment-related information.

Not sold

Not used or disclosed

J. Non-public education information

Not sold

Not used or disclosed

K. Inferences drawn from other personal information.

Not sold

Service providers

 

Please refer to section 2, above, for more information on our privacy practices with regard to service providers. Refer to section 6(C), below, for information regarding opting out of these practices.

 

C.                  Your Rights

If you are a California resident, California law permits you to request that we disclose certain information about our collection and use of your personal information including:

  • the “right to know,” meaning the right to request any or all of the following:
  • the specific pieces of personal information we collected about you;
  • the categories of personal information we collected;
  • the categories of sources used to collect the personal information;
  • the business or commercial purposes for collecting your personal information; and
  • the categories of third parties with whom we have shared your personal information
  • the right to request deletion of your personal information that we collected
  • the right to have someone you authorize make a request on your behalf
  • the right to opt-out of “sale” (as that term is defined in the CCPA)  or the sharing of personal information for cross-contextual behavioral advertising purposes
  • the right to make a request for the correction of errors or inaccuracies in your personal information
  • the right to restrict the processing of sensitive personal information (please note, however, that the only sensitive personal information that we collect and use in the context of our Services is your payment information and we use this information only as needed to process your orders).
  • the right not to be discriminated against for exercising any of these rights.

Exercising Your Rights

To exercise your rights to know (or for data portability), to deletion, or correction described above, please submit a request by contacting us through any of the means outlined below.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.

Your 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; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You do not need to create an account with us to submit a request to know or delete, but we consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

Opting out of the sale or sharing of personal information

If you are California resident, you have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”).

To exercise the right to opt-out, you (or your authorized representative) may visit this page. You may also use the  Global Privacy Control signal to indicate that you wish to exercise the right to opt-out. If we receive the signal, we will treat it as a request to opt out of both selling and sharing of your personal information for cross-contextual behavioral advertising purpose.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to comply with the request.

Restricting our use of sensitive personal information

Although you have the right to request that we restrict our processing of sensitive personal information to only that which is necessary to deliver our products and services to you, we already limit our processing of sensitive personal information in this way. If you have any questions or requests relating to this topic, please contact us at the information provided below.

Shine the Light

California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, entitles California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Any inquiries regarding personal information sharing with third parties may be directed to us at the contact information set forth below.

7.         Your Privacy Rights (for consumers in U.S. states other than California)

Depending on the law in the state where you live, you may have certain rights regarding your personal information under the law. To exercise your rights, please submit a request by contacting us through any of the means outlined below.

Your rights may include the following:

  • The right to opt-out of the use of personal data for targeted advertising, personal data sales, or profiling resulting in significant consequences
  • The right to confirm whether we process your personal data and to access a copy (from which we may, for security purposes, exclude certain personal data), including a copy that is in a portable data format
  • The right to the correction of inaccurate personal information
  • The right to the deletion of your personal information
  • The right to appeal the action we take in response to any request to exercise these rights

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.

Your 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; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Depending on the law in the state in which you live, you may also have the right to appeal using the contact information below. When you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accord with the timelines set forth in applicable law.

8.         Additional Information Regarding the Data Protection Laws of the European Union/European Economic Area, United Kingdom, and Switzerland

Under applicable data protection laws, you may have right to make certain requests with regard to your personal information, subject to exceptions and limitations set forth in those laws. To exercise any of these rights, please contact us using the information in section 9, below.

  • Access/Data Export. You may have a right to access the personal information we process and to request it in a common portable format of our choice.
  • You may request that we correct any personal information that you believe is inaccurate.
  • You may request that we delete your personal information. We may delete your data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you.
  • Restriction of Further Processing. You may request that we restrict the processing of personal information under certain circumstances. For example, you may make this request if you withdraw consent you gave us previously and we have no other legal basis for us to retain your personal information it, or where you object to our use of your personal information for particular legitimate business interests.
  • You may have the right under applicable law to object to any processing of personal information based on our legitimate interests. We may not cease or limit processing based solely on that objection, and we may continue processing where our interests in processing are appropriately balanced against individuals’ privacy interests. In addition to the general objection right, you may have the right to object to processing:
    • for profiling purposes;
    • for direct marketing purposes (we will cease processing upon your objection); and
    • involving automated decisionmaking with legal or similarly significant effects (if any).

You have the right to file a complaint with regulators about our processing of personal information. To do so, please contact your local data protection or consumer protection authority.

You may refer to the table in section 1, above, for more information about the lawful bases for our processing of personal information.

9.         Contacting Us

To exercise your rights or for other inquiries, please contact us at:

  • By e-mail: customerservice@jaystrongwater.com
  • By toll-free call: 1-800-640-0546
  • By postal mail at:
    120 Lakeside Avenue, Suite 200
    Seattle, WA 98122

 

 

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