Effective Date: August 21, 2020
COLLECTION AND USE OF PERSONAL INFORMATION
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.
Sources of Personal Information
We collect your Personal Information from the following sources:
- From You. When you provide it to us directly, such as when you make a purchase through the Services; and
- Automatically Collected. Through logging and analytics tools, cookies, and as a result of your use of access to the Services.
Use of Personal Information
We collect and process your Personal Information for our business purposes, which include the following:
- Fulfill orders placed through the Services (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations);
- Communicate with you;
- Screen for potential risk or fraud;
- Provide you with information or advertising relating to our products or services; and
- Improve and optimize our Services (for example, by generating analytics about how our customers browse and interact with the Services, and to assess the success of our marketing and advertising campaigns).
We will not use the Personal Information we collected for material different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.
Sharing of Personal Information
We share Personal Information with the following categories of third parties:
- Service Providers. We share your Personal Information with our service providers, such as Shopify and Google Analytics.
- Third Parties. We share your Personal Information with other third parties. For example, we use certain advertising and tracking technologies on our Site, and those technologies share data collected with the technology providers. We may also share your Personal Information to comply with applicable laws and regulations; to respond to a subpoena, search warrant or other lawful request for information we receive; or to otherwise protect our rights.
Processing of Personal Information
Within the last twelve (12) months, we have collected, used, and shared Personal Information as follows:
|#||Category of Personal Information Collected||Collected (Yes/No)||Sources of Collected Personal Information||Purposes for Using Personal Information (See #1-5 above)||Categories of Third Parties with whom Personal Information is Shared|
|1.||Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers||Yes||You, Automatically||1-5||Service Providers, Third Parties|
|2.||Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e))||Yes||You, Automatically||1-4||Service Providers, Third Parties|
|3.||Characteristics of protected classifications under California or federal law||Yes||You||1, 4, 5||Service Providers, Third Parties|
|4.||Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Yes||You, Automatically||1-4||Service Providers, Third Parties|
|5.||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement||Yes||Automatically||1-5||Service Providers, Third Parties|
|6.||Geolocation data||Yes||Automatically||1, 3-5||Service Providers, Third Parties|
|7.||Audio, electronic, visual, thermal, olfactory, or similar information||Yes||You||1-2, 4-5||Service Providers, Third Parties|
YOUR CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to email@example.com, and are free of charge. However, we do not disclose personal information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
The CCPA provides California residents with the following rights. For more information about how to exercise your CCPA rights, see SUBMITTING A VERIFIED CONSUMER REQUEST below.1. Right to Know: You have the right to request that we disclose certain information to you about the Personal Information we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:
- The categories of Personal Information collected about you;
- The categories of sources from which we collected your Personal Information;
- The categories of Personal Information that we have sold or disclosed about you for a business purpose;
- The categories of third parties to whom your Personal Information was disclosed for a business purpose;
- Our business or commercial purpose for collecting or selling your Personal Information; and
- The specific pieces of Personal Information we have collected about you.
2. Data Portability: You have the right to request a copy of Personal Information we hold about you.
3. Right to Deletion: You have the right to request that we delete the Personal Information we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:
- Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with a legal obligation.
- Otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
5. Right to Opt-Out/In: You have the right to opt-out of the sale of your Personal Information. You also have the right to opt-in to the sale of Personal Information. Please see our “Notice of Right to Opt-Out” by clicking on this “Do Not Sell My Personal Information” link for more information about your opt-out/in rights.
6. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you my receive a different price or rate for goods or services or a different level or quality of goods or services.
Some of our Services, however, may require your Personal Information. If you choose not to provide your Personal Information that is necessary to provide any aspect of the Services, you may not be able to use those Services.
SUBMITTING A VERIFIED CONSUMER REQUEST
To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.
To exercise your California privacy rights described above, please submit a verifiable request to us by:
Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your Personal Information.
You may only make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We will need to verify your identity with appropriate verification information.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.
Consumer Request by an Authorized Agent
If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require an email be sent to firstname.lastname@example.org, along with all of the below items:
- To verify your authorization to request on behalf of a California resident, provide one or more of the following: (1) California Secretary of State authorization, (2) written permission from the California resident, or (3) power of attorney.
- Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.
- To verify the identity of the California resident for whom the request is being made, provide appropriate verification information.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.
We will acknowledge receipt of the request within ten (10) days of its receipt. We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
SALE OF PERSONAL INFORMATION
We do not and will not knowingly sell the Personal Information of minors under the age of 16 without affirmative authorization.
DO NOT TRACK
NOTICE OF FINANCIAL INCENTIVE
From time to time, we may offer a financial incentive in the form of a discount to our customers in exchange for the collection of Personal Information. For example, customers who sign up for Alex Mill news receive a discount promotional code off their first purchase. You can opt-in to receive this discount by entering your email address and selecting your interest (“Women’s” or “Men’s”) when prompted on the Site. You can withdraw your consent from the financial incentive at any time by clicking on the “Unsubscribe” link at the bottom of our marketing communications.
We may update this California Notice from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. Any such updates will be effective upon our posting of the revised California Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this California Notice, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised California Notice will constitute your acknowledgement of the amended California Notice.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at email@example.com or by mail using the details provided below:
[Re: Privacy Compliance Officer]
Alex Mill Company LLC, 270 Lafayette St, Suite 1005, New York NY 10012, United States