Last Updated: December 30, 2019
This notice of privacy practices (“Notice”) describes how WIP Ecom LLC (“Carhartt Work in Progress,” Carhartt WIP,” “we,” “our,” or “us”) collects, uses, and shares your information. This Notice applies to information collected about you by Carhartt WIP or on behalf of Carhartt WIP through the Carhartt WIP , located at www.us.carhartt-wip.com (the “Website”) and any other place where we may interact with you (i.e., in our stores or over email).
This Notice does not apply to:
CALIFORNIA PRIVACY STATEMENT
For California residents, please see privacy-related information under Additional Notice for California Consumers.
UPDATES TO THIS NOTICE
We may update this Notice from time to time to provide clarification or notice of changes to our practices. All such changes will be effective upon posting the revised Notice on the Website and we will revise the “Last Updated” legend at the top of this Notice. Your continued use of the Website constitutes your acceptance to such changes. We encourage you to check back from time to time to ensure continuing familiarity with the most current version of the Notice.
GENERAL AUDIENCE WEBSITE
Services offered by Carhartt WIP are not directed to individuals under the age of thirteen (13). Carhartt WIP does not knowingly collect Personal Information (as defined below) from individuals under thirteen (13) years of age. No information should be submitted to or posted to the Website by visitors younger than thirteen (13) years old. Furthermore, we may restrict entries to any contests, sweepstakes or promotions to entrants who are at least 18 years of age or the age of majority.
INFORMATION WE COLLECT
As used in this Notice, “Personal Information” means information about an identifiable individual. Examples of Personal Information that we may collect include name, billing address, shipping address, telephone number, email address, birthdate, and payment information (including payment card number or online payment service number).
Carhartt WIP and its third-party service providers may collect Personal Information about you in the following ways:
Information you give us
Much of the Website is accessible without providing any Personal Information. However, you may be required to provide Personal Information, such as your name and contact information, when you are requesting to set up an account, place an order or take advantage of certain features of the Website (such as online surveys, promotions, contests and sweepstakes, product registration or to sign up for newsletters). If you do not provide your Personal Information, you will not be able to use these areas or features of the Website.
If you provide Carhartt WIP with Personal Information about a person other than yourself, you represent and warrant that you are authorized by that person to provide their Personal Information to us for the purposes for which you provided it.
Information Collected Automatically
When you visit the Website, certain information regarding your use of the Website or our services is collected and/or aggregated by or on behalf of Carhartt WIP through automated means. The information collected automatically may include information about your visit to, and use of, the Website, such as your IP address, type of browser and operating system used, date and time you access the Website, pages you visit, search engine used to access the Website, and if you linked to the Website from another website, the address of that website.
We may collect this information using cookies, web beacons, pixel tags and related technologies. “Cookies” are small identifiers sent from a web server that are stored on a computer’s hard drive to identify the browser during interaction on websites or storing information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
Using the information collected about you over time, we may engage in interest-based advertising, or “online behavioral advertising”, which includes ads presented to you after you leave our Website that encourage you to return. These ads may also include offers we think are relevant to you based on your shopping habits or online activities, and they may be served on websites or applications. We may serve these ads, or third party advertisers and ad networks such as Google AdWords and Facebook or other social media providers may serve you these ads. Many of these third parties have opt-out mechanisms for their ad cookies. For more information about your choices, please see the “Your Choices” section below.
We may allow third party advertising networks to collect information from the Website for targeting advertising purposes, including online behavioral advertising. Please see the “Advertising Networks” and “Your Choices” sections below for further information.
HOW WE MAY USE THE INFORMATION WE COLLECT
We use Personal Information for a variety of purposes, including without limitation:
HOW WE SHARE INFORMATION
We may share Personal Information (i) as you expressly authorize Carhartt WIP to do so; (ii) as permitted by law; (iii) with our Affiliates and (iv) with third parties, including:
We may share non-personally identifiable data, including anonymized data derived from Personal Information collected from the Website, with third parties, including our Affiliates, dealers, marketing businesses and lead generation businesses, for any purpose.
Accessing and Modifying Your Personal Information. You may correct, update and delete the information contained in your online account through the “My Account” page on the Website or by contacting us in writing as specified in the “How to Contact Us” section below. Please note that we may retain some Personal Information for archival and record retention purposes.
Communication Preferences. You may choose not to receive marketing and promotional email communications from us by clicking on the opt-out mechanism contained in such emails (also referred to as “unsubscribe”). You may still receive service-oriented, administrative communications from us, as you cannot opt-out of receiving such administrative communications. Please note that opting out of receiving marketing or promotional email communications will affect only future communications from us. If we already provided your information to a third party before you changed your preferences or updated your information, you may have to directly contact the relevant third party to communicate your choice to them in accordance with their policies.
Cookies. You may be able to opt-out of the automatic collection via cookies of some information by referring to your web browser’s or mobile device’s options or settings menu and adjusting the settings to accept to reject cookies. You may also render some web beacons unusable by rejecting their associated cookies. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences or visit http://www.allaboutcookies.org/ for more information. You can also refer to the “Help” menu of your browser to learn more about Web Beacons and your ability to disable them.
Google Analytics Solutions. Google provides users choices on how their data is collected by Google’s Analytics Solutions through an Opt-out Browser Add-on which can be located at: http://tools.google.com/dlpage/gaoptout?hl=en. By installing this Add-on, no information is being sent to Google Analytics.
NAI. Some third-party advertising companies we use may collect Personal Information about you via cookies and other technologies in connection with their behavioral advertising programs. While we do not control the programs or policies of third-party advertising companies, the Network Advertising Initiative (“NAI”)offers you the ability to opt-out of such advertising programs of their members by going to http://www.networkadvertising.org/managing/opt_out.asp, http://www.aboutads.info/choices or http://youradchoices.ca. Please note that if you use a different computer, change your web browser, or delete your cookies, you will need to renew all of your opt-out choices. Please also note that this does not opt you out of being served advertising, but only excludes you from targeted (i.e. interest-based) advertising. If you use the Carhartt WIP website or Affiliate websites, you will continue to receive generic advertisements.
Please be aware that if you do not allow us to collect and use your information, portions of the Website’s features and functionality will not operate correctly and we may not be able to provide you with certain services.
SECURITY AND DATA RETENTION
Carhartt WIP takes commercially reasonable measures to secure and protect information transmitted via or stored on the Website. Despite these measures, we cannot guarantee the security of networks, servers and databases we operate or that are operated on our behalf or that the information you transmit to Carhartt WIP over the Internet will not be intercepted, deleted or altered.
We reserve the right to retain any Personal Information reasonably necessary to document our business activities and for archival and record retention purposes.
DO NOT TRACK
We are not currently aware of a worldwide, uniform or consistent industry technology standard or definition for responding to, processing, or communicating “Do Not Track” signals. Accordingly, our website is unable to respond to “Do Not Track” requests from browsers.
CANADA PRIVACY RIGHTS
The file containing your Personal Information is maintained on our servers or those of our service providers or Affiliates, and is accessible by authorized employees, representatives and service providers. To request access to or correction of your Personal Information in our custody or control, or if you have any questions, please write to our Privacy Officer at Carhartt Work in Progress, Attn: Steven Wolski, 401 Broadway Ste 1105, New York, NY 10013.
HOW TO CONTACT US
If you have any questions or comments about this Notice, please contact us by email at email@example.com.
HOW WE COLLECT, USE, AND SHARE PERSONAL INFORMATION
1. Personal Information Collected on California Consumers in the Last Twelve Months
A. Identifiers such as name, postal and email addresses, unique personal identifier, online identifier, token identifier, Internet Protocol (IP) address, account name, social media handle when you request to create an account, purchase our products, interact with us on social media, or sign up to learn more about our products and services.
B. The following categories of Personal Information described in California Civil Code § 1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers”; (2) credit card number, debit card number or other payment information when you purchase our products; and (3) other information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household, as described herein.
C. The following categories of protected classification characteristics under California or federal law: gender.
D. Commercial information such as records of products or services purchased, or obtained, or considered from us.
E.Internet or other similar network activity information, including, but not limited to, browsing history on our websites, search history, information on a consumer’s interaction with our websites or applications.
F. Geolocation data such as physical location or movements.
G. Audio information, including recordings of when you called into our support line; video information in the form of CCTV at our local storefronts; and electronic information in the form of Internet or other electronic network activity information as described above.
H. Inferences drawn from other Personal Information, such as profiles reflecting consumer preferences person’s preferences.
Please note that Personal Information does not include publicly available information from government records, deidentified or aggregate consumer information, and Personal Information protected by certain other sector-specific federal or California statutes.
2. Our Use of Personal Information for Business Purposes in the Last Twelve Months
A. Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
B. Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
C. Debugging to identify and repair errors in our systems;
D. Short-term, transient use including contextual customization of ads;
E. Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
F. Conducting internal research to develop and demonstrate technology;
G. Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
H. Preparing statistics and performing analysis to support our operations;
I. Conducting marketing and surveys regarding our target market and products; and
J. Receiving and responding to inquiries.
3. Sharing of Personal Information in the Last Twelve Months
A. Disclosures of Personal Information on California Consumers for Business Purposes
Within the last twelve months, we have disclosed Personal Information identified in the above categories only (i) for exempt activities, as part of a business-to-business transaction, (ii) at your express request, or (iii) for our business purposes. For more information on the service providers with whom we share information, please see “How We Share Your Information” above.
When we disclose Personal Information for a business purpose, we execute a contract that describes the purpose and requires the recipient to keep Personal Information confidential and not use it for any purpose except performing the contract.
B. No Sales of Personal Information on California Consumers
CALIFORNIA RIGHTS AND CHOICES
1. Right to Know / Portability
You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:
2. Right to Deletion
You have the right to request deletion of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we confirm your verifiable request, 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:
3. Right to Non-Discrimination For Exercise of a California Privacy Right
We will not discriminate against you because of your exercise of any of the above rights, or any other rights under the CCPA. This means that we may not deny you goods or services, charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the CCPA.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
4. How to Submit a Request
You may submit a request to exercise the rights listed above by:
5. Verifiable Request
As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.
6. Agent Authorization
You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent. An agent may be an individual, or a business entity registered with the California Secretary of State. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your identity directly (subject to certain exceptions). We may refuse a request if the agent does not provide adequate proof of their authorization.
OTHER CALIFORNIA PRIVACY RIGHTS
7. California “Shine the Light” Law (Civil Code Section § 1798.83)
Under the Shine the Light Law, a California resident may ask us to refrain from sharing your Personal Information with third parties for their direct marketing purposes. We do not share Personal Information of California Consumers with third parties for their marketing purposes.
CONTACT INFORMATION REGARDING THIS CALIFORNIA NOTICE
You may contact us with questions or concerns about our privacy policies or practices and your choices and rights under California law by: