1. IMPORTANT INFORMATION AND WHO WE ARE
2. INFORMATION WE MAY COLLECT ABOUT YOU
3. HOW IS YOUR INFORMATION COLLECTED
4. HOW WE USE YOUR INFORMATION
5. HOW WE MAY SHARE YOUR INFORMATION
6. INTERNATIONAL TRANSFERS
7. INFORMATION SECURITY
8. INFORMATION RETENTION
9. MANAGING YOUR PERSONAL INFORMATION AND OPTIONS
1. Important Information and Who We Are
The Site is not intended for children under the age of 16. We do not knowingly collect personal information online from visitors in this age group. If you are under 16, do not use or provide any information on this Site or on or through any of its features, 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 child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us by sending an email to firstname.lastname@example.org.
If you are based in the European Union you also have the right to make a complaint at any time to the national supervisory authority for data protection issues in the country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us at the above contact information in the first instance.
2. Information We May Collect
Personally Identifiable Information
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, and company/organization name.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes your internet protocol (IP) address, your mobile device’s unique ID number, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Site, products and services, such as the buttons, controls, products, pages of our Site that you visit, the time spent on those pages, the dates and times of your visits, but also about the webpage you were visiting before you came to our Site and the webpage you go to next.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Browsing Information and Cookies
The Site also uses a browser feature known as a cookie, which assigns a unique identification to your device. The information collected from cookies allows us to provide better customer service to you and to improve features of our Site in a variety of ways, including by determining whether you have visited the Site in the past and which pages of our Site you have visited.
If you are uncomfortable with the idea of your information being used in this way, most devices and web browsers offer privacy settings and options, such as disabling cookies or opting for “Do Not Track” features. We do not override these settings or options. However, in order to access certain content, features, services, products, or benefits of the Site, you may be required to provide us with certain information, including some types of personally identifying information. If you do not wish to provide such information through the Site or if you opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products, or benefits of the Site.
3. How is Your Information Collected
We use different methods to collect information from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- place an order on the Site;
- register an account with us;
- utilize our “Email a Friend” feature;
- contact us with a question or comment; or
- sign up to receive emails about our latest products and services.
- Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Facebook, Instagram, Twitter, Google based outside the EU; and
- search information providers such as Google based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Shopify, Google based outside the EU.
- Identity and Contact Data from our partners, data brokers or aggregators such as Google based outside the EU.
- Identity and Contact Data from publicly availably sources such as Shopify, Klaviyo based outside the EU.
4. How We Use Your Information
We will only use your personal identifiable information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you for the purchase of goods [and/or services] we offer for sale through our Website.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
To find out more about the types of lawful basis that we will rely on to process your personal information, see below.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to setting certain types of cookies to enable you to access our Site or where otherwise indicated in connection with any purpose-specific privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
[(b) Asking you to leave a review or take a survey]
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and/or services)
[To enable you to partake in a prize draw, competition or complete a survey]
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and/or services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products and/or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products and/or services offerings and grow our business)
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
From time to time, Knack may disclose the data collected through the Site, including personally identifiable information, to other persons or entities whom we believe trustworthy. In such cases we might rent, exchange, share and/or cross-reference information, including contact information about you that will enable such persons or entities to contact you regarding products and services that may be of interest to you. We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, by contacting us at any by email at firstname.lastname@example.org, or by contacting customer service at +1-401-404-4003.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. Knack will continue to send you non-promotional, service emails concerning your account, such as emails relating to available upgrades, billing and payment information, outstanding balance on your account, and other emails relating to your account.
CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS
California Civil Code Section §1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to email@example.com; or write to us at our mailing address at Attention: Knack Privacy, 200 Middle Hwy, #375, Barrington, RI 02806.
RHODE ISLAND RESIDENTS: YOUR PRIVACY RIGHTS
Rhode Island Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who Rhode Island residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a Rhode Island resident and would like to make such a request, please submit your request to the email address identified above.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. How We May Share Your Information
We may – for the purposes set out in the table above - share information collected through the Site with our subsidiaries, affiliated companies, and like-minded business partners for the purpose of providing you with the products and services you seek from the Site. We may also share your mailing address and shopping history with other catalog mail companies.
Additionally, in order to provide you with a better customer experience, we may share information with service providers, subcontractors, and business partners who have been retained to perform functions on our behalf or to provide services to us. These services include:
- Order fulfillment, warehousing, and delivery;
- Advertising, marketing, surveys, and promotions, including partnerships and teaming efforts with other companies whose products or services we think you might enjoy;
- Information technology and office services, including software and website development, website hosting, management and evaluation, and data processing, exchange, and cross-referencing;
- Payment processing services, fraud protection, and credit risk reduction; and
- Legal, accounting, audit and other professional service providers.
We reserve the right to disclose information about you to a third party pursuant to a subpoena, court order, or other form of legal process, or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Please contact us at firstname.lastname@example.org if you want further information on the specific third party recipients with whom we may share your personal information and the purpose(s) for such sharing.
6. International transfers
We share your personal information within our company. This will involve, if you are a resident of the European Union, transferring your information outside the European Economic Area (EEA).
Many of our external third party recipients are also based outside the EEA so their processing of your personal data will also involve a transfer of information outside the EEA.
If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the U.S., we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the U.S. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
The security of your personally identifiable information is important to us and Knack is committed to handling such information carefully. We maintain appropriate physical, electronic and procedural safeguards to guard your personally identifiable information. We use secure socket layer technology to protect the security of your payment information and we encrypt your personally identifiable information when it is sent over the Internet. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personally identifiable information, we cannot guarantee its absolute security.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
For more information about the security measures we have implemented to protect your personal information, please contact us at firstname.lastname@example.org.
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.
Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).
8. Information retention
How long will you use my personal information for?
We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal information are set out in the table "Purposes for which we will use your personal information" above.
In some circumstances you can ask us to delete your information: see below for further information.
In some circumstances we will anonymize your personal information (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.
Third Party Links
Please note that we also 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. To learn more about your rights as a consumer and to receive less national advertising mail, please visit the Direct Marketing Association at http://www.dmachoice.org. If you are based in the United States you can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website at http://optout.networkadvertising.org or by visiting https://www.datalogix.com/privacy or http://www.aboutads.info/choices. If you are based in the European Union you may visit the website of the European Interactive Digital Advertising Alliance (“EIDAA”) at https://www.edaa.eu as well as of the European Advertising Standards Alliance (“EASA”) at http://www.easa-alliance.org.
9. Managing Your Personal Information and Options
Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please click on the links below to find out more about these rights:
- Request access to your personal information.
- Request correction of your personal information.
- Request erasure of your personal information.
- Object to processing of your personal information.
- Request restriction of processing your personal information.
- Request transfer of your personal information.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and/or product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.
- Service providers acting as processors based in the United States who provide IT and system administration services/email services/server hosting services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United States who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors or joint controllers based in the United States who require reporting of processing activities in certain circumstances.
YOUR RIGHTS IN RELATION TO INFORMATION WE HOLD ABOUT YOU
You have the right to:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
- If you want us to establish the information's accuracy.
- Where our use of the information is unlawful but you do not want us to erase it.
- Where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products and/or services to you. We will advise you if this is the case at the time you withdraw your consent.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Questions or Concerns
If you have any feedback, questions, or concerns regarding privacy, please send us a detailed message to firstname.lastname@example.org; we will make every effort to resolve your concerns.
Last Updated: 9/2/2018