International Addendum

INTERNATIONAL PRIVACY RIGHTS ADDENDUM

Last Revised: April 25, 2025

This addendum applies only to individuals located in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”).

Controller

World Threads Inc., d/b/a Eberjey is the controller of personal data covered by our Privacy Policy for purposes of European Laws.

Personal Data

Any reference to “personal data” in this Addendum includes “personal data” as defined in European data protection laws (collectively, “European Laws”).

Lawful Basis for Processing

We use your personal data for business purposes as outlined below and only as permitted by law. Our processing of your personal data may require sharing it with third parties in order to accomplish the stated purpose.

Business Purposes

Personal Data Used

Lawful Basis

To present our website and its contents to you.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

 

Legitimate Interest in providing our services to you.

To personalize your site experience and to allow us to deliver the type of content and product offerings in which you are most interested.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

 

Legitimate Interest in providing our services to you.

To allow us to better service you in responding to your customer service requests.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

 

Processing necessary for performance of a contract or to take steps at the request of the data subject prior to entering into a contract. 

To quickly process your requests, transactions, purchases, and payments.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Processing necessary for performance of a contract or to take steps at the request of the data subject prior to entering into a contract. 

To administer a contest, promotion, survey, or other site feature.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Consent.

To inform you about offers for our services, products, and special promotions.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Consent.

To investigate and respond to inquiries and complaints.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Legitimate Interest in correcting errors and improving our services.

To improve and secure our website and systems.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

 

Legitimate Interest in correcting errors in and improving our services and understanding our consumers and business operations and preventing harm to ourselves and others from malicious activity.

Fraud monitoring and prevention.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Legitimate Interest in preventing harm to ourselves and others from malicious activity.

To provide customers that sign-up for our email list advance notice of sales, new arrivals, sample sale dates, and other Eberjey news.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Consent.

To fulfill any other purpose for which you instructed when you provide it.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Necessary for performance of a contract or to take steps at the request of the data subject prior to entering into a contract.

To provide you with notices about your account and product purchases.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Legitimate Interest in providing our services to you.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Legitimate Interest in protecting our legal rights and the legal rights of others.

To notify you about changes to our site or services we offer or provide.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Legitimate Interest in providing our services to you.

Uses we believe to be necessary or appropriate under applicable law and regulations to comply with legal processes, respond to requests from governmental authorities, protect our business, and to protect our rights.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Compliance with legal obligations.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Eberjey assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Eberjey about our customers are among the assets transferred.

· Identifiers

· Characteristics of protected classification

· Commercial information

· Internet & network information

· Geolocation data

· Audio, visual, and electronic information

· Inferences

Legitimate Interest in managing our business affairs.

 

“Legitimate Interest” means the interests of our business in conducting and managing our business to enable us to give you the best Sites and Services possible and protect our reasonable business concerns. We consider and balance any potential impact on you (positive and negative) and your rights under European Laws before we process personal data for our Legitimate Interest. We do not process personal data for our Legitimate Interests if we determine that our interests are overridden by the impact on your rights (unless we have consent, or the processing is otherwise permitted by law). If you are located in Europe, please contact us if you would like more information about how we assess our Legitimate Interests.

If consent is our lawful basis for processing your personal data, we will obtain consent from you prior to processing your personal data for the purpose for which consent is required and you may revoke your consent at any time by contacting us using the contact information below.

Change of Purpose  

We may use your personal data for reasons not described in our Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and explain the applicable legal basis.

Special Categories of personal data

We ask that you not provide us with any special categories of personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).

If you provide any special categories of personal data to us, you must consent to our processing and use of such special categories of personal data in accordance with our Privacy Policy. If you do not consent to our processing and use of special categories of personal data, you must not submit such special categories of personal data.

International Transfers

Personal data will be processed in the United States and/or Europe. Whenever we transfer your personal data out of Europe, we ensure that we have your consent or adequate safeguards are in place as required by the GDPR or its Swiss or UK equivalent by either (i) transferring your personal data to countries whose laws have been deemed adequate by relevant data protection authorities, (ii) transferring your personal data to persons participating in programs such as the EU-U.S. Data Privacy Framework that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or UK government, or (iii) using standard contractual clauses approved by the European Commission and/or UK government which give personal data a similar amount of protection as it has in Europe, including additional safeguards as needed. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Europe.

What rights do I have?   

Individuals located in the EEA and other countries and jurisdictions may have certain rights with respect to their personal data.  These rights include:  

  • Access and Update. You can review and change your personal data by notifying us through the Contact Information below of any changes or errors in any personal data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
  • Objection. You can object to our processing of your personal data when 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 infringes your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.   
  • Restrictions. You have the right to restrict our processing of your personal data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your personal data is determined to be unlawful, or if we no longer need your personal data for processing but we have retained it as permitted by law.   
  • Portability. To the extent the personal data you provide Eberjey is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such personal data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this personal data to another controller, when technically feasible.  
  • Withdrawal of Consent. To the extent that our processing of your personal data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your personal data.   
  • Right to be Forgotten. You have the right to request that we delete all of your personal data. We cannot delete your personal data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your personal data or after a final determination that your personal data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your personal data as set forth in our Privacy Policy. In addition, we cannot completely delete your personal data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.  
  • Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly to give us an opportunity to work directly with you to resolve any concerns about your privacy.   
  • How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Us below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your personal data, you may be charged a fee subject to a maximum set by applicable law. We will inform you in advance before any fee is incurred. 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 multiple requests. In this case, we will notify you and keep you updated. If we decline your request, we will tell you why, subject to legal restrictions.

     

  • Questions

    If you have any questions about this addendum, please email us at privacy@eberjey.com.