DATE: January 1, 2020
Arlana’s Gourmet Cookies, and its affiliates ("we", "us", or "our") are committed to maintaining your confidence and trust as it relates to the privacy of your information. Please read below and learn how we collect, protect, share and use your information, including, without limitation, on our websites, interactive features, applications, and social network pages ("Platforms").
INFORMATION WE COLLECT ON OUR PLATFORMS
We collect, receive, and develop several categories of personal information about you, depending on the nature of your interactions with us. For example:
We collect Contact Information.
We may collect contact information and identifiers such as your name, email, telephone number, social media account handles, username, password, and home address.
We collect Demographic Information.
We may collect information such as your gender, birth date, and age.
We collect Location Information.
We collect information about your general location, using your zip code and IP address.
We collect Internet and Network Activity Information.
Whenever you visit or interact with the Platforms, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Platforms are accessed and used ("Usage Information"). Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features or applications on the Platforms, interaction with friends and group activities.
We automatically collect your IP address and other unique identifiers ("Device Identifier") for the device (computer, mobile phone, tablet or other device) you use to access the Platforms. A Device Identifier includes a number that is assigned to your device when you access a website or its servers, and we may identify your device by its Device Identifier.
Cookies; Pixel Tags.
The technologies used on the Platforms to collect Usage Information, including Device Identifiers, may include but are not limited to: cookies (data files placed on a device when it is used to visit the Platforms), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). For more information about these technologies email us at .
We collect Payment Information.
We collect your credit card and other payment details if you make a purchase on certain of our Platforms.
We collect Purchase and Preference Information.
We may collect information about your purchase history, shipping instructions, and product preferences. We may also collect information about other transactions and preferences.
We collect Employment-Related Information.
When you apply for a job, we collect information you submit as part of your application and resume. This might include your work experience and previous employment, your education, your eligibility to work in the United States, languages you speak, and your salary expectations. It might also include information about non-compete or non-solicitation agreements you may have signed, or your relationship to any of our current employees. Certain job applications may ask additional questions specific to the position. If you apply for a job, you may choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.
We collect and develop Inferences.
Using the other pieces of personal information collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.
HOW WE USE THE INFORMATION WE COLLECT
We use the categories of personal information referenced above for the following purposes:
We use information to provide you with services and respond to your questions and requests.
We use Contact Information, Internet and Network Activity Information, Location Information, Payment Information, Purchase and Preference Information, and Inferences to provide you with certain services and provide access to certain areas and features of the Platforms (such as your favorite products); verify your identity; and communicate with you about your activities on the Platforms and, in our discretion, changes to any of our policies. We use Contact Information, Purchase and Preference Information, Location Information, and Payment Information to process purchase transactions. We may also use Location Information for the purpose of providing you with certain services. Cookies may also use personal information to associate you with social networking sites like Facebook and Twitter and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites.
We use information for marketing purposes.
For example, we may use personal information like Contact Information, Demographic Information, Location Information, Internet and Network Activity Information, Purchase and Preference Information, and Inferences to tailor content, advertisements, and offers we serve you. This information helps us keep our Platforms fresh and interesting to our visitors and allows us to tailor content to a visitor's interests (such as allowing us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information). To learn about your choices for these communications, read the “Your Privacy Rights, Choice and Access” section below.
We use information to improve our products and services.
For example, we use all categories of personal information to make our Platforms, products, and services better.
We use information to comply with our obligations, administer our Platforms, and for internal operations.
We may use all categories of personal information to, among other things, administer the Platforms, help diagnose problems with our servers, analyze trends, track users' web page movements, help identify you, and gather broad demographic information for aggregate use. We, or our vendors, may place cookies or similar files on your device for analytics and security purposes, and to facilitate site navigation. A pixel tag may tell your browser to get content from another server. We may also use personal information to comply with our license obligations.
We use information for security purposes.
For example, we may use all categories of personal information to protect our company, our customers, and our business partners. We also may use personal information to protect our Platforms or our services, as well as to detect and investigate activities that may be illegal or prohibited (such as cyberattacks or fraudulent transactions).
We use information for hiring purposes.
For example, we use Contact Information and Employment-Related Information to review your job applications and contact you about employment opportunities. We may use certain Employment-Related Information for other statistical or analytical purposes in accordance with applicable law.
We use information to verify requests made pursuant to this Privacy Notice.
We will use certain pieces of personal information to verify your identity if you make requests pursuant to this Privacy Notice. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.
We may use information as otherwise disclosed or permitted by law, or as we may notify you.
We collect personal information about you from various sources, directly and indirectly, including from the following sources:
We collect personal information directly from you.
For example, we may collect Contact Information, Demographic Information, and Location Information if you enter a promotion or sign up for our email newsletter. We collect Contact Information if you create an account on certain of our Platforms, and we collect Payment Information and Purchase and Preference Information if you make a purchase. We collect Contact Information and Employment-Related Information if you apply for a job. We also collect any personal information you provide if you make a request or contact us.
We collect personal information from your devices.
We use tracking tools like browser cookies and web beacons to automatically collect information about you (including Internet and Network Activity Information, Demographic Information, Purchase and Preference Information, Inferences, and Location Information). We collect this information when you interact with our Platforms, our ads, or our emails that we or vendors send to you.
We receive personal information from vendors we hire to work on our behalf.
For example, vendors that host or maintain our Platforms and send emails for us may give us Contact Information, Demographic Information, Internet and Network Activity Information, Location Information, Payment Information, Purchase and Preference Information, and Inferences. Our employment and recruiting vendors give us Contact Information and Employment-Related Information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with Contact Information, Demographic Information, Internet and Network Activity Information, Location Information, Payment Information, Purchase and Preference Information, and Inferences.
We may receive information about you from other sources, including third parties.
For example, if you are on another website and you opt-in to receive information from us, that website will submit to us your Contact Information and other personal information you provide so that we may contact you as requested. You may also choose to participate in a third party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on a third party website) through which you allow us to collect (or the third party to share) information about you, including Contact Information, Internet and Network Activity Information, Location Information, and other information such as lists of your friends, "likes", comments you have shared, and groups. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their "connections" or information about you is otherwise accessible through your "connections" web page, profile page, or similar page on a social networking or other third party website or interactive service.
We may combine information.
We may supplement the information we collect about you through the Platforms with information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you.
SHARING OF INFORMATION
Except as described here, we will not provide any of your personal information to any third parties without your specific consent. We may share non-personal information, such as aggregate data and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy Notice and in the following circumstances:
We may share each category of personal information within Arlana's Gourmet Cookies. This includes our subsidiaries, affiliates, and brands.
Third Parties Providing Services On Our Behalf.
We may share each category of personal information with third parties that perform functions on our behalf such as service providers that host or operate our Platforms, analyze data, or provide customer service; and third parties that administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance, including placing our ads on other platforms. Some transfers of your personal information to our vendors may be viewed as a “sale” under certain state laws.
Business Partners and Marketing Companies.
We may share Contact Information, Internet and Network Activity Information, Demographic Information, Purchase and Preference Information, Inferences, and Location Information with our sponsors, partners, advertisers or other third parties to provide you with product information and promotional and other offers. These third parties may co-sponsor or participate in our promotions, contests, and sweepstakes. These may be “powered by” partners or our partners on co-branded sites. We may also share the above categories of personal information with companies that help us with our marketing efforts, including social media platforms, advertising networks, and ad tech companies. Some transfers of your personal information to our business partners and marketing companies may be viewed as a “sale” under certain state laws.
Your Agreement To Have Your Personal Information Shared.
With A Successor To All Or Part Of Our Business.
If we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, any or all categories of personal information may be sold or transferred as part of that transaction. We may also share personal information with others as they conduct due diligence as part of our corporate changes.
To Comply With The Law, Or To Protect Ourselves, Our Customers, And Others.
We may share personal information for other reasons we may describe to you from time to time as permitted by law.
YOUR PRIVACY RIGHTS, CHOICE AND ACCESS; AND YOUR CALIFORNIA PRIVACY RIGHTS
You may always direct us not to share your personal information with third parties, not to use your personal information to provide you with information or offers, or not to send you newsletters, emails or other communications by: (i) sending us an email at ; (ii) calling us at 844.384.4407; or (iii) following the removal instructions in the communication that you receive. Your opt-out request will be processed within 30 days of the date on which we receive it.
You can control certain cookies and tracking tools we use. For details, see the “Advertising/Behavioral Targeting; How to Opt Out” section below.
If you wish to modify, verify, correct, or delete any of your personal information collected through the Platforms, you may contact us at the above telephone number or email. In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted through the Platforms. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. It may not always possible to completely remove or delete all your information from our databases without some residual data because of backups and other reasons. We will retain your information (including geo-location data) for as long as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at the above telephone number or email. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not control certain privacy settings and preferences maintained by our social media partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site. We do not respond to "do not track" signals communicated to us by a browser.
Your California Privacy Rights.
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at , call us at 844.384.4407. Indicate in your letter or email subject line that you are a California resident making a “Shine the Light” inquiry.
If you reside in California, you have the right to make the following more specific requests with respect to your personal information:
Access – You have the right to request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we shared the personal information, and the specific pieces of personal information we collected about you over the past 12 months.
Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
Opt Out – You can request to opt-out of the sale of your personal information by visiting our Do Not Sell My Personal Information page. For purposes of this Privacy Notice, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration.
We will not discriminate against you because you exercised any of these rights.
California residents can exercise these rights by emailing us at , by calling us at 844.384.4407. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate consumer requests.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.
For purposes of exercising these rights, please note the following regarding how we collect and use your personal information as described in this Privacy Notice:
We may collect, and use for our business and commercial purposes, the following categories of personal information as set forth in applicable California law: Identifiers; payment information; Internet or other electronic network activity information; demographic information; characteristics of protected classifications under California or federal law; commercial information; professional or employment information; inferences; and geolocation data.
We may disclose each of the foregoing categories of personal information for a business purpose to the extent permitted by applicable law.
We may “sell” the following categories of personal information: Identifiers; Internet or other electronic network activity; demographic information; commercial information; inferences; and geolocation data. California law defines “sell” broadly. Certain sharing of information might qualify as a “sale” under California law, even if the information is not exchanged for money.
ADVERTISING/BEHAVIORAL TARGETING; HOW TO OPT-OUT
We may use third party ad network providers to help present ads on the Platforms, as well as other service providers to evaluate and provide us with information about the use of the Platforms and viewing of our content. To learn more about the tools we use and how you can control certain tools by emailing us at , by calling us at 844.384.4407.
The Platforms are not directed to children under 16. We do not knowingly collect, use or disclose personally identifiable information from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her personal information without the parent/guardian's consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.
SECURITY OF YOUR INFORMATION
We take information security seriously and use certain reasonable security measures to help protect your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.
The Platforms may contain links to other sites that we do not own or operate. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to your device, they may independently collect data or solicit personal information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms (including those linked to through an email or social networking page).
The Platforms may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Privacy Notice.
CONSENT TO PROCESSING AND TRANSFER OF INFORMATION
The Platforms are governed by and operated in, and in accordance with the laws of the United States. We make no representation that the Platforms are governed by or operated in accordance with the laws of any other nation. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are in Mexico, the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Platforms, or providing us with any information, you (a) acknowledge that the Platforms are subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.
We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes, we will notify you by either email (sent to the e-mail address you have provided) or by means of a notice on our Platforms prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
If you have any questions or concerns about this Privacy Notice, the practices of the Platforms, or your experiences with the Platforms, please contact us at emailing us at .