Last updated: January 1, 2020
We are committed to respecting privacy and recognize the need for appropriate protection and management of anypersonal informationthat is shared with us as part of using our Service.
You may choose whether or not to provide personal information in connection with your use of our Service. If you choose not to provide the personal information we request, you may still visit and use parts of our Services, but may be unable to access or use certain features, options, programs, products, and services.
PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on whether you are a customer, user, applicant or visitor, and the requirements of applicable law.
Information You Provide to Us.
Account Creation: When you create a user account or sign up for a Membership with us, we may collect your name, email address, username, password, information about your clothing size, payment information, and mailing address.
Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job or otherwise communicate with us.
Surveys. We may contact you to participate in surveys.If you decide to participate, you may be asked to provide certain information which may include personal information.
Social Media Content. We may offer forums, blogs, or social media pages.Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
Registration for Sweepstakes or Contests. We may run sweepstakes and contests.Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law.In some jurisdictions, we are required to publicly share information of winners.
Information Collected Automatically or From Others
Automatic Data Collection. We may collect certain information automatically when you use the Services.This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services.Information we collect may be associated with accounts and other devices.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences.Most browsers allow you to block and delete cookies.However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons.A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about visitors’ engagement on that web page.The use of a pixel allows us to record, for example, that a visitor has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services.For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you.For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings.Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service.This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
HOW WE USE YOUR INFORMATION.
We use your information for a variety of business purposes, including to:
Fulfil our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Communicating with you about your account, activities on our Services and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Providing advertising, analytics and marketing services;
- Providing Services on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information;
- Processing applications and transactions; and
- Allowing you to register for events.
Analyze and improve our Services pursuant to our legitimate interest, such as:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
- Undertaking research for technological development and demonstration;
- Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
- Improving, upgrading or enhancing our Services;
- Developing new products and services;
- Ensuring internal quality control;
- Verifying your identity and preventing fraud;
- Debugging to identify and repair errors that impair existing intended functionality;
- Enforcing our terms and policies; and
- Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
Provide you with additional content and services, such as:
- Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or services;
- Auditing relating to interactions, transactions and other compliance activities; and
- Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
We may use technologies considered automated decision making or profiling.We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology.You may escalate any concerns you have by contacting us below.
Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities.For example, we may allow you to provide information about your friends through our referral services.Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
- Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services.This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party sites.
Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps.For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop.To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
Notice Regarding Third-Party Websites, Social Media Platforms and Software Development Kits. The Services may contain links to other websites, and other websites may reference or link to our website or other Services.These other websites are not controlled by us.We encourage our users to read the privacy policies of each website and application with which they interact.We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications.Visiting these other websites or applications is at your own risk.
We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services.APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes, including to provide analytics services and content that is more relevant to you.For more information about our use of APIs and SDKs, please contact us as set forth below.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES.
Except as provided below, we do not share your personal information. For a list of the categories of personal information we have disclosed about consumers for a business purpose in the past 12 months, please click here.For a list of categories of personal information we have sold about consumers for a business purpose in the past 12 months for valuable consideration, please click here.
Service Providers. We may share any personal information we collect about you with our third-party service providers, who may only use your data to provide services to us.The categories of service providers (processors) to whom we may entrust personal information include, but are not limited to: IT and related services; information and services; payment processors; customer service providers; and vendors to otherwise support the provision of the Services.
Business Partners. From time to time, we may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly offered product or service from us, we may share Personal Information collected in connection with your purchase or expression of interest with our joint promotion partner(s). We do not control our business partners’ use of Personal Information we collect, and their use of the information will be in accordance with their own privacy policies.
Affiliates. We may share any personal information we collect about you with our affiliated companies.
Advertising Partners. Through our Services, we may direct third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information we have collected about you (such as your hashed email address, demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks.This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store about you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
You have certain choices about your personal information.Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below.Even if you opt out, we may still collect and use non- personal information regarding your activities on our Services and for other legal purposes as described above.
Email and Telephone Communications.
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
You may opt out of receiving text messages from us by following the instructions in the text message or replying "STOP" to a text message you have received from us or by otherwise contacting us.
We may send you push notifications through our mobile application.You may at any time opt- out from receiving these types of communications by changing the settings on your mobile device.We may also collect location-based information if you use our mobile applications.You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track.”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies, Interest-Based Advertising, and Analytics.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store.Alternatively, for some devices you may use your device’s platform controls in your settings to exercise your choice.
For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites.
You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
To opt out of Facebook targeted advertising, please visit
Please note you must separately opt out in each browser and on each device.Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites.These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
Your Privacy Rights.
In accordance with applicable law, you may have to the following rights:
Access to/Portability of Personal Data. You can receive a copy of data we process about you consistent with legal requirements.In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
Correction. You can request correction of your personal information where it is inaccurate or incomplete.In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
Deletion. You can request we delete personal information we collect or maintain about you, subject to certain exceptions prescribed by law.
Restriction of or Objection to processing. You can request restriction or object to the processing of your personal information, and you have the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you would like to exercise any of these rights, please log into your account or contact us as set forth below. We will process such requests in accordance with applicable laws.To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to log in to your account or requesting additional information. You have a right not to receive discriminatory treatment as a result of your exercise of these rights. In some cases, you may designate an authorized agent to make a request on your behalf.
We do not collect your personal information unless you have a user account with us. If you do not have a user account, but believe we may use your personal information, please submit your request to exercise your rights in writing to CaaStle Inc. 5 Penn Plaza, Fl. 4, New York, NY 10001 Attn: Legal Team or email@example.com.
We reserve the right to retain any Personal Information as long as the Personal Information are needed to provide our Services, fulfill the purposes that are described in this Policy, and comply with applicable law.
SECURITY OF YOUR INFORMATION.
The privacy and security of Personal Information is very important to us. Taking into account the nature, scope, context and purposes of processing Personal Information as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, Gwynnie Bee has implemented appropriate technical and organizational measures to ensure and to be able to demonstrate that its processing of Personal Information is performed in accordance with applicable law. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS.
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Gwynnie Bee has collected about them and whether Gwynnie Bee disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information by clicking here. The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in the link above.
“Sales” of Personal Information under the CCPA
California residents have the right to opt out of the “sale” of their personal information. Under the CCPA, “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money).
Gwynnie Bee does not sell personal information for monetary gain and we have NOT sold your personal information in the past 12 months for exchange of money. However, we may share your personal information with third-parties to improve and market the service and under CCPA, this is considered a “sale.” The categories of personal information we have “sold” and the categories of third parties we have “sold” personal information to in the preceding twelve months are listed here.
Gwynnie Bee’s business and commercial purposes for “selling” personal information in the “HOW WE USE YOUR INFORMATION” section above. Gwynnie Bee does not have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Opt-out of “Sales.” California residents may opt-out of the “sale” of their personal information by opting out of cookies as described above in the section “Cookies, Interest-Based Advertising, and Analytics.”
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. 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. To designate an authorized agent, please log into your account or contact us as set forth below.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to 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 your name, email address, username, and/or account password.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.
California Shine The Light Law.
The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties.
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at firstname.lastname@example.org with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.
Third Party Websites/Applications.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
5 Penn Plaza, Fl. 4,
New York, NY 10001
Attn: Legal Team