WEBSITE PRIVACY POLICY
Last updated: Jan 2023
1. INTRODUCTION
Cookies Retail LLC and any of its affiliates
and subsidiaries (collectively referred to herein as “Cookies”
or the “ Company”) respects your privacy and we are committed to
protecting it through our compliance with this privacy policy (this “Privacy Policy”).
The terms “we”, “us” and “our” refer to Cookies. The term “you” refers to the
person visiting this Website (as defined below).
This Privacy Policy, including our Cookie
Policy, describes the types of information we may collect from you or that you
may provide when you visit the website (the “Website”) and our
practices for collecting, using, maintaining, protecting, and disclosing that
information.
This Privacy Policy applies to information we
collect:
(a) On this Website;
(b) In email and other electronic messages
between you and the Company; and
(c) Any signups with the Company’s loyalty
program and/or reward program.
(d) It does not apply to information
collected by: us offline or through any other means, including on any third
party;
Please read this Privacy Policy carefully to
understand our policies and practices regarding your information and how we
will treat it. If you do not agree with our policies and practices, your choice
is not to use our Website. By accessing or using this Website, you agree to
this Privacy Policy and the Cookie Policy. This Privacy Policy may change from
time to time (see Section 11
– “Changes to this Privacy Policy”). Your
continued use of this Website after we make changes is deemed to be acceptance
of those changes, so please check the policy periodically for updates.
2. PERSONS UNDER THE AGE OF 21
With the exception of Florida where patients
are required to be 18 years and older, our website is not intended for persons
under 21 years of age. No one under age 21 may provide any information to or on
the Website. We do not knowingly collect personal information from persons
under 21. If you are under 21, do not use or provide any information on this
Website or through any of its features, register on the Website, or provide any
information about yourself to us, including your name, address, telephone
number, or email address. If we learn we have collected or received personal
information from a person under 21, we will delete that information. If you
believe we might have any information from or about a person under 21, please
contact us at customerservice@cookiesretail.co.
3. TYPE OF DATA WE COLLECT
The personal data that we collect includes,
but is not limited to:
(a) Communication
Identity data, including
your first name, last name, date of birth, e-mail address, telephone number,
mailing address, and records and copies of your correspondence, if you contact
us.
(b) Tracking and Usage
Information about your internet connection,
the equipment you use to access our Website, and technical and usage data,
including data about your use of the Website (e.g. date, time and location of
access to our Website, “mouse events”, apps or newsletter, clicked pages/links
or entries and comparable data), and the use of other technology on the devices
(and the type of devices) you use to access our Website, including information
collected through cookies and other tracking technologies. Please see the
attached Cookie Policy for more information.
(c) Marketing
Marketing and communications data, including
your preferences in receiving marketing from us and/or our third parties and
your communication preferences. You maintain the ability to opt out of direct
marketing.
4. HOW DO WE COLLECT YOUR INFORMATION
We collect this information:
(a) Directly from you when you provide it to
us.
(b) Automatically as you navigate through the
Website. Information collected automatically may include usage details, IP
addresses, and information collected through cookies, web beacons, and other
tracking technologies. Please see the attached Cookie Policy for more
information.
(c) From third parties, for example, our
business partners.
5. HOW WE USE YOUR INFORMATION
We may use, or disclose the personal
information we collect for one or more of the following purposes:
(a) To fulfill or meet the reason you
provided the information. For example, if you share your name and contact
information to ask a question about our products or services, we will use that
personal information to respond to your inquiry.
(b) When necessary for the performance of our
contract with you or your designee.
(c) To provide, support, personalize, and
develop our Website, products, and services.
(d) To create, maintain, customize, and
secure your customer profile with us.
(e) To process your requests and
transactions, and prevent transactional fraud.
(f) To provide you with support and to
respond to your inquiries, including to investigate and address your concerns
and monitor and improve our responses.
(g) To personalize your Website experience
and to deliver content and product and service offerings relevant to your
interests, including targeted offers and ads through our Website, third-party
sites, and via email or text message (with your consent, where required by
law).
(h) To perform in connection with your roles,
responsibilities, and/or status as a job applicant to or an employee, owner,
director, officer, or contractor of Cookies, including administering payroll,
benefits, maintaining compliance with policies and procedures, and to comply
with health and safety and occupational health obligations;
(i) To help maintain the safety, security,
and integrity of our Website, products and services, databases and other
technology assets, and business.
(j) For testing, research, analysis, and
product development, including to develop and improve our Website, products,
and services.
(k) To respond to law enforcement requests
and as required by applicable law, court order, or governmental regulations.
(l) As described to you when collecting your
personal information.
(m) To evaluate or conduct a merger,
divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which personal information
held by us about our consumers is among the assets transferred.
(n) For any other purpose with your consent.
(o) We may use the information we have
collected from you to enable us to display advertisements to our advertisers’
target audiences. Even though we do not disclose your personal information for
these purposes without your consent, if you click on or otherwise interact with
an advertisement, the advertiser may assume that you meet its target criteria.
You can object to the processing described
above as set forth in Section 8.
6. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about
our users, and information that does not identify any individual, without
restriction.
We may disclose personal information that we
collect or you provide as described in this Privacy Policy:
(a) To our subsidiaries and affiliates.
(b) To employees, contractors, service
providers, and other third parties we use to support our business (“ Service Providers”).
The Service Providers are subject to contractual obligations to implement
appropriate technical and organizational security measures to safeguard the
personal data, and to process the personal data only as instructed.
(c) To a buyer or other successor in the
event of a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of Cookie’s assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar proceeding, in which
personal information held by Cookies about our Website users is among the
assets transferred.
(d) To fulfill the purpose for which you
provide it.
(e) For any other purpose disclosed by us
when you provide the information.
(f) With your consent.
(g) To comply with any court order, law, or
legal process, including to respond to any government or regulatory request.
(h) To enforce or apply
our terms of use located on the website and other agreements, including for
billing and collection purposes.
(i) If we believe disclosure is necessary or
appropriate to protect the rights, property, or safety of Cookies, our
customers, or others.
7. HOW LONG WILL WE KEEP YOUR DATA
We intend to keep your personal data for as
long as necessary to fulfil the purposes we collected it for, including to
satisfy legal and reporting requirements.
To determine the appropriate retention period
for personal data, we consider amount, nature, and sensitivity of the personal
data, potential risk of harm from unauthorized use or disclosure of your
personal data, purposes for which we process your personal data and whether we
can achieve those purposes through other means, and applicable legal
requirements.
We process and store your data for the
duration of the relevant commercial business relationship. This includes the
performance of our services.
We are subject to various retention and
documentation obligations arising from the relevant local data protection laws.
The periods and deadlines for retention and/or documentation set out in some
applicable laws/regulations can extend up to ten years beyond the end of the
contractual or pre- contractual legal relationship. Special statutory
provisions may require longer retention.
In some circumstances you may ask us to
delete your personal data. If the data is no longer required to meet
contractual or statutory obligations and rights, it is regularly deleted unless
its further processing - for a limited period - is necessary to fulfil the
purposes listed in this Privacy Policy, for example, due to an overriding
legitimate interest. Such an overriding legitimate interest is deemed to be the
case, for example, if it is not possible to delete the data as a result of a
special type of storage, or because it is only possible at an unreasonably
great expense and processing for other purposes is excluded by appropriate
technical and organizational measures.
In some circumstances we may anonymize your
personal data (so that it can no longer be associated with you) for research or
statistical purposes, in which case we may use this information indefinitely
without further notice to you.
8. YOUR RIGHTS WHEN MAKING YOUR
PERSONAL DATA AVAILABLE TO US
8.1 Choices About How We Use and
Disclose Your Information
We undertake to keep your personal data
confidential and to ensure that you may exercise your rights. Notwithstanding
the purpose or legal basis pursuant to which we process your data, you have the
following rights.
(a) Tracking Technologies and Advertising.
We may work with third party analytics
companies to help us understand how services are being used, such as data
collection, reporting, ad response measurement, website and mobile application
analytics, and to assist with delivery of relevant marketing messages and
advertisements (collectively, “Services”).
We may use Google Analytics, an analytics
service provided by Google or other third party analytics services providers
("Analytics Services") to collect information about your use of the
Services. These Analytics Services may collect information about the content
you view and your system information and geographic information. The
information generated by the Analytics Services about your use of the Services
will be transmitted to and stored by the Analytics Services. The information
collected by the Analytics Services allows us to analyze your use of the
Services.
We encourage you to review your device and
Services settings to ensure they are consistent with your preferences,
including with respect to the collection and use of information. You may be
able to stop further collection of certain data by the Services by updating
your applicable device settings, or you may uninstall the Services. In
addition, you may choose not to share your location details by adjusting your
mobile device's location services settings. For instructions on changing the
relevant settings, please contact your service provider/carrier or device
manufacturer.
From time to time we may disclose certain
information (name, mailing address and non-sensitive transactional information
such as your purchase history, amounts paid and products ordered) to marketing
companies for trade or rental purposes.
If you prefer to opt-out of the use of your
personal information by marketing companies for trade or rental purposes,
please let us know at customerservice@cookiesretail.co .
Unless you notify us otherwise, you hereby expressly consent to the disclosure
of such information for such marketing purposes. Please see attached Cookie
Policy for more information.
(b) Promotional Offers from Cookies.
From time to time, we may host a promotion,
sweepstakes, or content on the Services. You may be asked to provide personal
information or permit the transfer of your personal information to a third
party in connection with such promotion, sweepstakes or content. The parties
who privacy policy applies will be disclosed at point of collection or transfer
and you will have a choice of whether or not you wish to permit such transfer
or collection of information to a third party.
If you do not wish to have your contact
information used by Cookies to promote our own or third parties’ products or
services, you can opt-out by sending us an email stating your request to customerservice@cookiesretail.co.
If we have sent you a promotional email, you may send us a return email asking
to be omitted from future email distributions. This opt out does not apply to
information provided to Cookies as a result of a product or service purchase,
warranty registration, product service experience or other transactions.
We do not control third parties’ collection
or use of your information to serve interest-based advertising. However, these
third parties may provide you with ways to choose not to have your information
collected or used in this way. You can opt out of receiving targeted ads from
members of the Network Advertising Initiative (“NAI”) on the NAI’s
website.
California residents may have additional
personal information rights and choices. Please see the attached California
Privacy Notice for more information.
(c) Social Media and Sharing.
The Services may use social networking or
"share functionality" or may contain links to third-party social
media sites or applications that are not owned or controlled by us. We also may
allow you to use social media sites or applications to leverage your existing
social media site or application accounts to access features of the Services.
Your use of these features may result in the collection or sharing of
information about you by these sites or applications, depending on the feature.
We have no control over, and assume no
responsibility for, any share functionality or the content, privacy policies,
or practices of any third-party site or application. We encourage you to review
the privacy policies and settings on the social media sites or applications
with which you interact to make sure you understand the information that may be
collected, used, and shared by those sites. You are subject to the policies of
those third parties when and where applicable.
8.2 Accessing and Correcting Your
Information
You can review and change your personal
information by sending us an email at customerservice@cookiesretail.co to
request access to, correct or delete any personal information that you have
provided to us. We may not accommodate a request to change information if we
believe the change would violate any law or legal requirement or cause the
information to be incorrect.
California residents may have additional
personal information rights and choices. Please see the attached California
Privacy Notice for more information.
9. COOKIES
As further described in our Cookie Policy, we
use cookies and similar technologies to collect data (e.g., device IDs) to
recognize you and your device(s) on, off and across different services and devices
where you use the Website. Please see the attached Cookie Policy for more
information.
10. LINKS TO THIRD PARTY WEBSITE
This Website may also contain links to
websites operated by other companies, including websites operated by our
third-party service providers, and unrelated third parties. This Privacy Policy
does not apply to personal data collected on any of these other websites. When
you access third-party websites through a link on our Websites, please review
the Privacy Policy posted on that website.
11. DATA SECURITY
We have implemented measures designed to
secure your personal information from accidental loss and from unauthorized
access, use, alteration, and disclosure. All information you provide to us is
stored on our secure servers behind firewalls.
Unfortunately, the transmission of
information via the internet is not completely secure. Although we do our best
to protect your personal information, we cannot guarantee the security of your
personal information transmitted to our Website. Any transmission of personal
information is at your own risk. We are not responsible for circumvention of
any privacy settings or security measures contained on the Website.
12. CHANGES TO THIS PRIVACY POLICY
We may update or revise this Privacy Policy
and we reserve the right to do so, at any time and without prior notice, by
posting the revised version on our Website. These changes will be effective as
of the date we post the revised version on our Website. Your use of our Website
following any such change constitutes your consent to the terms of the revised
privacy policy. For this reason, it is important to review this Privacy Policy
regularly.
13.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California
law may provide you with additional rights regarding our use of your personal
information. To learn more about your California privacy rights, see the
attached Privacy Notice for California Residents.
14. CONTACT INFORMATION
If you have questions or concerns regarding
this Privacy Policy, please contact us at customerservice@cookiesretail.co.
COOKIE
POLICY
Last updated: Jan 2023
At Cookies, we believe in being transparent
about how we collect and use data. This cookie policy (the “Cookie Policy”)
is designed to inform you about our use of cookies, local storage objects and
similar technologies. For ease of reference, unless otherwise stated below, we
will use the term “cookies” in this Cookie Policy to refer to all of these
technologies. This Cookie Policy is part of our Privacy Policy, which also
includes additional details about our collection and use of information.
Capitalized terms used in this Cookie Policy but not defined have the same
meaning as in our Privacy Policy.
1. OVERVIEW
As you navigate through and interact with our
Website, we may use automatic data collection technologies to collect certain
information about your equipment, browsing actions, and patterns, including:
a. Details of your visits to our Website,
including traffic data, location data, logs, and other
communication data and the resources that you access and use on the Website.
b. Information about your computer and
internet connection, including your IP address, operating system, and browser
type.
By continuing to visit or use our Website,
you are agreeing to the use of cookies and similar technologies for the
purposes described in this Cookie Policy.
2. WHY DO WE USE COOKIES?
The information we collect automatically is
only statistical data and does not include personal information, but we may
maintain it or associate it with personal information we collect in other ways
or receive from third parties. It helps us to improve our Website and to
deliver a better and more personalized service, including by enabling us to:
a. Estimate our audience size and usage
patterns.
b. Store information about your preferences,
allowing us to customize our Website according to your individual interests.
c. Speed up your searches.
d. Recognize you when you return to our
Website.
We do not collect personal information
automatically, but we may tie this information to personal information about
you that we collect from other sources or you provide to us.
3. WHAT COOKIES DO WE COLLECT?
A cookie is a small text file that stores
Internet settings. Almost every website uses cookie technology. The cookie is
downloaded by your Internet browser the first time you visit a website. The
next time you visit this website from the same device, the cookie and the
information in it are either sent back to the originating website (first-party
cookies) or to another website to which it belongs (third-party cookies). By
that, the website can detect that it has already been opened using this
browser, and in some cases it will then vary the content it shows.
Some cookies are extremely useful because
they can improve your user experience when you return to a website you have
already visited. This assumes that you are using the same device and the same
browser as before; if so, cookies will remember your preferences, will know how
you use the website, and will adapt the content you are shown so that it is
more relevant to your personal interests and needs.
Based on what function cookies have and the
purpose for which cookies are used, there are different categories of cookies
we may use on the Website: strictly necessary cookies, performance cookies,
functional cookies, marketing cookies, and web beacons.
3.1 Strictly necessary cookies
These are cookies that are essential to
fulfil an action requested by you, such as identifying you as being logged in.
If you prevent these cookies by adjusting your browser settings we cannot
guarantee how our website will perform during your visit. These cookies are
essential in order to enable you to move around the website and use its
features. Your consent is not required for the use of strictly necessary
cookies.
3.2 Performance cookies
These are cookies used to improve our
website, for example, for analytics that let us see how a website is being used
and where to make improvements, including the number of visitors, where
visitors have come from to the website and the pages visited. These cookies do
not save information that would allow the user to be identified. The collected
information is aggregated, and therefore anonymous. These cookies are used
exclusively to improve the performance of the website, and with it the user
experience.
3.3 Functionality cookies
These cookies enable a website to save
information which has already been entered (such as user names, languages
choices, and your location), so that it can offer you improved and more
personalized functions. Functional cookies are also used to enable features you
request such as playing videos. These cookies collect anonymous information and
cannot track your movements on other websites.
3.4 Targeting and advertising cookies
These cookies track browsing habits and are
used to deliver targeted (interest-based) advertising. They are also used to
limit the number of times you see an advertisement and to help measure the
effectiveness of advertising campaigns. They remember whether you have visited
a website or not, and this information can be shared with other organizations
such as advertisers. Cookies for improving group targeting and advertising will
often be linked to site functionality provided by other organizations.
3.5 Web Beacons
Web beacons are small, transparent graphic
images that are delivered through a web browser or HTML e-mail. Web beacons may
include GIF or PNG images, pixels, javascript, or other tags, which are used to
track visitor activity on a particular website, or the viewing of a particular
e-mail. We may also use other tracking mechanisms such as web beacons to
collect marketing statistics.
4.
THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications, including
advertisements, on the Website are served by third-parties, including
advertisers, ad networks and servers, content providers, and application
providers. These third parties may use cookies alone or in conjunction with web
beacons or other tracking technologies to collect information about you when
you use our website. The information they collect may be associated with your
personal information or they may collect information, including personal
information, about your online activities over time and across different websites
and other online services. They may use this information to provide you with
interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’
tracking technologies or how they may be used. If you have any questions about
an advertisement or other targeted content, you should contact the responsible
provider directly.
5. YOUR CHOICES
You may at any time “opt out” of Cookie’s use
of cookies, web beacons or other tracking mechanisms through your browser
settings. However, disabling such features may prevent you from using certain
features or taking full advantage of all of our offerings on our website.
6. DO NOT TRACK
Do Not Track is a concept that has been
promoted by regulatory agencies such as the U.S. Federal Trade Commission
(FTC), for the Internet industry to develop and implement a mechanism for
allowing Internet users to control the tracking of their online activities
across websites by using browser settings. Some newer Internet browsers have
incorporated Do Not Track features, and when turned on, they send a signal to
the websites you visit, telling the website that you do not want to be tracked
while browsing. Our website does not respond to the browser Do Not Track
signal. Thus, most cookies will continue to be stored until you choose to
delete them.
7. YOUR CALIFORNIA PRIVACY RIGHTS
Please visit the Privacy
Notice to learn more about your California privacy rights.
8. GENERAL
For more information about the cookies we may
use, please contact customerservice@cookiesretail.co.
We store this cookie data until the end of
the term of a particular cookie or until the cookies are deleted by you.
PRIVACY
NOTICE FOR CALIFORNIA RESIDENTS
Last updated: Jan 2023
This Privacy Notice for California
Residents (this “ Notice”) supplements the
information contained in Cookie’s attached Privacy Notice and applies solely to
individuals who reside in the State of California (“consumers”
or “ you”).
We adopt this notice to comply with the California Consumer Privacy Act of 2018
(“CCPA”)
and any terms defined in the CCPA have the same meaning when used in this
Notice.
1. INFORMATION WE COLLECT
We collect information that identifies,
relates to, describes, references, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
consumer (including consumers who are job applicants to or employees, owners,
directors, officers, or contractors of Cookies), household, or device (“personal information”).
Personal information does not include:
(a) Publicly available information from
government records.
(b) Deidentified or aggregated consumer
information.
(c) Information excluded from the CCPA’s
scope, like:
i. health or medical information covered by
the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the
California Confidentiality of Medical Information Act (CMIA) or clinical trial
data; and,
ii. personal information covered by certain
sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA),
the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy
Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the
following categories of personal information from consumers (including
consumers who are job applicants to or employees, owners, directors, officers,
or contractors of MMT) within the last 12 months:
Category |
Examples |
Collected |
A. Identifiers. |
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 |
B. Personal information categories listed in
the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number,
physical characteristics or description, address, telephone number, passport
number, driver’s license or state identification card number, insurance
policy number, education, employment, employment history, bank account
number, credit card number, debit card number, or any other financial
information, medical information, or health insurance information. Some |
NO |
personal information included in this
category may overlap with other categories. |
||
C. Protected classification characteristics
under California or federal law. |
Age (40 years or older), race, color,
ancestry, national origin, citizenship, religion or creed, marital status,
medical condition, physical or mental disability, sex (including gender,
gender identity, gender expression, pregnancy or childbirth and related
medical conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information). |
NO |
D. Commercial information. |
Records of personal property, products or
services purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies. |
YES |
E. Biometric information. |
Genetic, physiological, behavioral, and
biological characteristics, or activity patterns used to extract a template
or other identifier or identifying information, such as, fingerprints,
faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other
physical patterns, and sleep, health, or exercise data. |
NO |
F. Internet or other similar network
activity. |
Browsing history, search history,
information on a consumer’s interaction with a website, application, or
advertisement. |
NO |
G. Geolocation data. |
Physical location or movements. |
NO |
H. Sensory data. |
Audio, electronic, visual, thermal,
olfactory, or similar information. |
NO |
I. Professional or employment-related
information. |
Current or past job history or performance
evaluations. |
NO |
J. Non-public education information (per
the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a
student maintained by an educational institution or party acting on its
behalf, such as grades, transcripts, class lists, student schedules, student
identification codes, student financial information, or student disciplinary
records. |
NO |
K. Inferences drawn from other personal
information. |
Profile reflecting a person’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes. |
NO |
We obtain the categories of personal information listed above from the
following categories of sources:
(d) Directly from you. For example, from
forms you complete or products and services you purchase.
(e) Indirectly from you. For example, from
observing your actions on our website.
(f) Government entities from which public
records are maintained and other publicly available sources and unaffiliated
service providers, including data resellers.
2. USE OF PERSONAL INFORMATION
We may use, or disclose the personal
information we collect for one or more of the following purposes:
(a) To fulfill or meet the reason you
provided the information. For example, if you share your name and contact
information to ask a question about our products or services, we will use that
personal information to respond to your inquiry.
(b) When necessary for the performance of our
contract with you or your designee.
(c) To provide, support, personalize, and
develop our website, products, and services.
(d) To create, maintain, customize, and
secure your customer profile with us.
(e) To process your requests and transactions,
and prevent transactional fraud.
(f) To provide you with support and to
respond to your inquiries, including to investigate and address your concerns
and monitor and improve our responses.
(g) To personalize your website experience
and to deliver content and product and service offerings relevant to your
interests, including targeted offers and ads through our website, third-party
sites, and via email or text message (with your consent, where required by
law).
(h) To inform you about Cookies events, news,
and investor-related materials.
(i) To perform in connection with your roles,
responsibilities, and/or status as a job applicant to or an employee, owner,
director, officer, or contractor of Cookies, including administering payroll,
benefits, maintaining compliance with policies and procedures, and to comply
with health and safety and occupational health obligations;
(j) To help maintain the safety, security,
and integrity of our website, products and services, databases and other
technology assets, and business.
(k) For testing, research, analysis, and
product development, including to develop and improve our website, products,
and services.
(l) To respond to law enforcement requests
and as required by applicable law, court order, or governmental regulations.
(m) As described to you when collecting your
personal information or as otherwise set forth in the CCPA.
(n) To evaluate or conduct a merger,
divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which personal information
held by us about our consumers is among the assets transferred.
(o) For any other purpose with your consent.
(p) We may use the information we have
collected from you to enable us to display advertisements to our advertisers’
target audiences. Even though we do not disclose your personal information for
these purposes without your consent, if you click on or otherwise interact with
an advertisement, the advertiser may assume that you meet its target criteria.
We will not collect additional categories of
personal information or use the personal information we collected for
materially different, unrelated, or incompatible purposes without providing you
notice.
3. SHARING PERSONAL INFORMATION
We may disclose your personal information to
a third party for a business purpose. When we disclose personal information for
a business purpose, we enter a contract that describes the purpose and requires
the recipient to both keep that personal information confidential and not use
it for any purpose except performing the contract.
We may share your personal information with
the following categories of third parties:
(a) Our subsidiaries and affiliates.
(b) Contractors, service providers, and other
third parties we use to support our business.
(c) A buyer or other successor in the event
of a merger, divestiture, restructuring, reorganization, dissolution, or other
sale or transfer of some or all of Cookie’s assets, whether as a going concern
or as part of bankruptcy, liquidation, or similar proceeding, in which personal
information held by Cookies about our website users is among the assets
transferred.
(d) To comply with any court order, law, or
legal process, including to respond to any government or regulatory request.
4. YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California
residents) with specific rights regarding their personal information. This
section describes your CCPA rights and explains how to exercise those rights.
4.1 Access
to Specific Information and Data Portability Rights
You have the right to request that we
disclose certain information to you about our collection and use of your
personal information over the past 12 months. Once we receive and confirm your
verifiable consumer request (see Exercising Access, Data Portability, and
Deletion Rights), we will disclose to you:
(a) The categories of
personal information we collected about you.
(b) The categories of
sources for the personal information we collected about you.
(c) Our business or commercial purpose for
collecting or selling that personal information.
(d) The categories of third parties with whom
we share that personal information.
(e) The specific pieces of personal
information we collected about you (also called a data portability request).
(f) If we sold or disclosed your personal
information for a business purpose, two separate lists disclosing:
i. sales, identifying the personal
information categories that each category of recipient purchased; and,
ii. disclosures for a business purpose,
identifying the personal information categories that each category of recipient
obtained.
4.2 Deletion
Request Rights
You have the right to request that we delete
any of your personal information that we collected from you and retained,
subject to certain exceptions. Once we receive and confirm your verifiable
consumer request (see Exercising Access, Data Portability, and Deletion
Rights), we will delete (and direct our service providers to delete) your
personal information from our records, unless an exception applies.
We may deny your deletion request if
retaining the information is necessary for us or our service provider(s) to:
(a) Complete the transaction for which we
collected the personal information, provide a good or service that you
requested, take actions reasonably anticipated within the context of our
ongoing business relationship with you, fulfill the terms of a written warranty
or product recall conducted in accordance with federal law, or otherwise
perform our contract with you.
(b) Detect security incidents, protect
against malicious, deceptive, fraudulent, or illegal activity, or prosecute
those responsible for such activities.
(c) Debug products to identify and repair
errors that impair existing intended functionality.
(d) Exercise free speech, ensure the right of
another consumer to exercise their free speech rights, or exercise another
right provided for by law.
(e) Comply with the California Electronic
Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
(f) 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 information’s
deletion may likely render impossible or seriously impair the research’s
achievement, if you previously provided informed consent.
(g) Enable solely internal uses that are
reasonably aligned with consumer expectations based on your relationship with
us.
(h) Comply with a legal obligation.
(i) Make other internal and
lawful uses of that information that are compatible with the context in which
you provided it.
4.3 Exercising
Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and
deletion rights described above, please submit a verifiable consumer request to
us by either:
• Emailing us at customerservice@cookiesretail.co.
• Visiting https://www.cookiesretail.co/.
Only you, or someone legally authorized to
act on your behalf, may make a verifiable consumer request related to your
personal information. You may also make a verifiable consumer request on behalf
of your minor child.
You may only make a verifiable consumer
request for access or data portability twice within a 12- month period. The
verifiable consumer request must:
(a) Provide sufficient information that
allows us to reasonably verify you are the person about whom we collected
personal information or an authorized representative, which may include: first
and last name, email address, phone number, mailing address, physical address,
company.
(b) Describe your request with sufficient
detail that allows us to properly understand, evaluate, and respond to it.
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.
Making a verifiable consumer request does not
require you to create an account with us.
We will only use personal information
provided in a verifiable consumer request to verify the requestor’s identity or
authority to make the request.
4.4 Response
Timing and Format
We endeavor to respond to a verifiable
consumer request within 45 days of its receipt. If we require more time (up to
ninety days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will
deliver our written response to that account. If you do not have an account
with us, we will deliver our written response by mail or electronically, at
your option.
Any disclosures we provide will only cover
the 12-month period preceding the verifiable consumer request’s receipt. The
response we provide will also explain the reasons we cannot comply with a
request, if applicable. For data portability requests, we will select a format
to provide your personal information that is readily useable and should allow
you to transmit the information from one entity 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.
5.
NON-DISCRIMINATION
We will not discriminate against you for
exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
(a) Deny you goods or services.
(b) Charge you different prices or rates for goods or
services, including through granting discounts or other benefits, or imposing
penalties.
(c) Provide you a different level or quality of goods or
services.
(d) Suggest that you may receive a different price or
rate for goods or services or a different level or quality of goods or
services.
However, we may offer you certain financial incentives
permitted by the CCPA that can result in different prices, rates, or quality
levels. Any CCPA-permitted financial incentive we offer will reasonably relate
to your personal information’s value and contain written terms that describe
the program’s material aspects. Participation in a financial incentive program
requires your prior opt in consent, which you may revoke at any time.
6.
CCPA DATA RIGHTS ARE NOT AVAILABLE FOR CERTAIN PERSONAL INFORMATION
CCPA data rights are not available for personal information
we collect about you in the course of you acting as a job applicant to or an
employee, owner, director, officer, or contractor of Cookies, including, in
these contexts, your emergency contact information and personal information
that is necessary for us to retain to administer benefits for another person
relating to you acting as a job applicant to or an employee, owner, director,
officer, or contractor of Cookies. Any personal information we collect and use
will only be used within the context of your role or former role in these
capacities.
7.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our
discretion and at any time. When we make changes to this privacy notice, we
will post the updated notice on the website and update the notice’s effective
date. Your continued use of our website following the posting of changes
constitutes your acceptance of such changes.
8.
CONTACT INFORMATION
If you have questions or concerns regarding this Notice,
please contact us at customerservice@cookiesretail.co.
California Residents
The California Shine the Light Law grants California
residents the right to obtain certain information about the types of Personal
Information that companies with whom those individuals have an established
business relationship have shared with third parties for direct marketing
purposes during the preceding calendar year. In particular, that law provides
that California residents may request a copy of the Personal Information that
we hold about them. California residents may also request information regarding
the categories of Personal Information that have been shared with third
parties, the names and addresses of those third parties and examples of the
types of services or products marketed by those third parties. To request
either a copy of the information maintained by us about you or to request a
copy of the information disclosure provided by us during the preceding calendar
year pursuant to the California Shine the Light Law, please contact us via
email at optout@cookiesretail.co. Please
allow 30 days for a response to your request.
After January 1, 2023, the California Consumer Privacy Rights
Act (CPRA) granted additional rights under the CCPA. Among other changes, the
CPRA created a new sub-category of Personal Information called “Sensitive Personal
Information” which is defined as any Personal Information that reveals an
individual’s personal identification numbers (e.g., social security number,
driver’s license, passport number, or state identification card numbers),
account or debit or credit card numbers combined with passwords or codes that
would enable access to the accounts, exact geolocation, racial or ethnic
origin, religious or philosophical beliefs, or union membership, mail, email,
or text message content unless the information was intentionally sent to the
Company and genetic data. We collect limited pieces of Sensitive Personal
Information, as outlined below, for the specific purposes set forth in this
Privacy Policy.
The categories of information we have collected from
California residents in the past 12 months, the sources of that information,
the business purpose for the collection of that information, and the third
parties to whom we may disclose that information may include:
- Identifiers:
We may collect your name, aliases, postal address, email address,
telephone number, online identifier, Internet Protocol address, account
name, or other similar unique personal identifiers. We may collect this
Personal Information directly from you, indirectly from you (e.g., from
observing your actions on our website) or from third party service
providers, such as a data analytics provider. The business purposes for
which we may collect this information may include responding to an inquiry
from you, providing information about products or special offers,
processing your orders, processing employment applications or processing
documentation required for legal purposes. We may disclose this
information to third parties, including, payment processors, providers of
internet, marketing, and administrative services.
- Internet
or other similar network activity: We may collect information related to
browsing history, search history, information on a consumer’s interaction
with a website, application, or advertisement. We may collect this
information indirectly from you (e.g., from observing your actions on our
Site) or from third-party service providers, such as a data analytics
provider. The business purpose for which we may collect this information
includes providing targeted advertising and providing information about
products or special offers. We may disclose this information to third
parties, including, internet service providers, payment processors, and
advertising networks.
- Geolocation
data: We may collect information pertaining to location. We may collect
this information directly from you. The business purposes for which we may
collect this information includes responding to an inquiry, processing
your order or to provide targeted advertising. We may disclose this
information to third parties, including, internet service providers and
advertising networks.
- Inferences
drawn from other personal data: We may collect profiles reflecting a
person’s shopping preferences and behavior. We may collect this
information indirectly from you (e.g., from observing your actions on our
Site), and from third-party service providers, such as a data analytics
provider. The business purposes for which we may collect this information
include improving the online shopping experience for consumers. We may
disclose this information to third parties, including advertising
networks, in aggregated and/or deidentified, i.e., anonymized, form.
· If you are a California resident, the CCPA may grant you
certain rights in connection with the Personal Information we collect,
including:
- You have
the right to know and request, no more than twice in a 12-month
period, information about the categories of Personal Information we have
collected about you, as well as the categories of sources from which such
information is collected, the purpose for collecting such information, and
the categories of third parties with whom we share such information. You
also have the right to know if we have sold your Personal Information or
disclosed your Personal Information for a business purpose, and, if so,
the categories of Personal Information we sold or disclosed for a business
purpose. You also have the right to request the specific pieces of
Personal Information we have collected about you and the third parties to
whom we may disclose Personal Information. We will endeavor to respond to
a verified request within forty-five (45) days of its receipt. If more
time is reasonably necessary to provide you with the information you
request, we may take an additional forty-five (45) days to respond to your
request, and will notify you in writing of the reason(s) an extension is
required.
- You have
the right to “opt out” of the sale and/or sharing of your
Personal Information (or, for consumers who are under 16 years old, the
right not to have their Personal Information sold absent their, or their
parent’s (for consumers ages 13-5), opt-in).
- You have
the right to request that we delete your Personal Information.
We may retain your Personal Information, however, pursuant to one or more
exceptions provided by law.
- You have
the right to correct inaccurate Personal Information maintained
by us.
- You have
the right to limit the use and disclosure of your Sensitive Personal
Information to those uses that are necessary to perform the services
or goods reasonably expected by an average consumer who requests those
goods or services, in addition to other business purposes as permitted by
California law.
- You have
the right to non-discrimination. You have the right to receive equal
service and pricing from a business, even after exercising your rights.
To submit an access or deletion request or opt-out of the
sale of your Personal Information, click here.