Privacy Policy

GENERAL PRIVACY NOTICE

 

World Threads Inc., d/b/a Eberjey (“Eberjey”, “we”, “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy. The purpose of this Privacy Policy (our “Privacy Policy”) is to describe to you Eberjey's practices and policies regarding our collection and use of your personal data, and to explain your privacy rights. By visiting this website, you are accepting and consenting to the practices that are described in this Privacy Policy.

 

We may process and collect personal data from you when you visit this website, register on the site, place an order, enter a contest, respond to a communication such as email, or otherwise provide us with information. We may also obtain information from other sources, such as social media platforms, linked to our website. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously.

 

WHAT INFORMATION DO WE COLLECT?

 

The information we collect may include the following:

 

Personal data that you provide: contact information, name, address, telephone number, email address, credit card, and debit card number and related information, logins, and passwords. You can view this website without providing this information, unless you choose to place an order. We may obtain personal data from you through this website, offline such as when you call us, or from other sources, such as public databases, social media platforms or other third parties, to the extent permitted by law.

 

User Contributions: You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website (collectively, “User Contributions”). Your User Contributions are posted on the Website at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

 

Personal data obtained automatically through or generated on our website: information about your computer and internet connection, such as your IP address, unique device identifier, unique advertising identifier, operating system, and browser type; and details of your visits to our website, such as traffic data, logs, date and time of your visit to our website, error information, clickstream data, and other communication data and the resources that you access and use on the website, your internet activity on our website such as pages viewed, products viewed, products purchased, clicks, scrolling and mouse-overs, information on your first visit, previous visit, and current visit, the visited pages, and the manner in which you navigate the website. The technologies we use for this automatic data collection may include and other information collected through cookies, pixels, web beacons, session replay tools, and other tracking technologies. The policy can be viewed at https://eberjey.com/pages/cookie-policy.

 

Personal data obtained from third parties using cookies and other tracking technologies: We may obtain personal information from third party sources. Our service providers (such as: Google, Bing, Shopify, BlueCherry, Klaviyo, Yotpo, ShipStation, KWI, and Zendesk) may also use online identifiers such as cookies, web beacons, or other tracking technologies to collect and store information about you (e.g. IP address, unique device identifier, unique advertising identifier, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookie and session ID) when you use our website, purchase products from our online store, and use our website (e.g. pages viewed, products viewed, products purchased, scrolling movements, and clicks on our website). The information they collect and store may be associated with your personal data or they may collect and store information, including personal data, about your online activities over time and across different websites and other online services. The services may analyze the behavior of website users and interactions with our emails (e.g. when you open or click in an email) to provide our users with personalized purchase recommendations and to tell which mailings appeal most to our customers. They may use this information to provide you with targeted, 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.

 

Information about gift recipients: One of the features of this website is the ability to purchase gifts for others either from a gift registry created on the site or separately. When you make a gift, we collect information about the recipient of the gift so that we can fulfill your order, including the recipient's name, address, and other contact information. We do not use information about gift recipients for marketing purposes. If you submit personal data about other people to us, you represent that you have the authority to do so and give us permission to use that information in accordance with this Privacy Policy.

 

HOW DO WE COLLECT PERSONAL DATA?

 

We and our third party service providers may collect information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version. We use this information to ensure that the website functions properly.
  • Through your use of the website: When you use the website, we and our service providers may track and collect usage data, such as the date and time the App on your device accesses our servers, and what information and files have been downloaded to the App based on your device number.
  • Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. For information on how we use cookies, see our Cookie Policy available at https://eberjey.com/pages/cookie-policy.
  • Using pixel tags and other similar technologies: We may use pixel tags (also known as web beacons and clear GIFs) to track the actions of users of the website, measure the success of our marketing campaigns, and compile statistics about usage of the website.
  • Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the website and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google's practices by going to google.com/policies/privacy/?partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • IP address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the website. We may also derive your approximate location from your IP address.
  • Physical location: We may collect the physical location of your device (by country or zip code) by, for example, using satellite, cell phone tower, or WiFi signals. We may use your device's physical location to provide you with personalized location-based services and content. You may be permitted to allow or deny such uses of your device's location, such as through your device settings. If you do, we may not be able to provide you with the applicable personalized services and content.
  • From you: Information such as your preferred means of communication is collected when you voluntarily provide it, such as when you purchase products from us through our online store.
  • By aggregating information: Aggregated personal data does not personally identify you or any other user of the website. For example, we may aggregate personal data to calculate the percentage of our users who live in a particular geographic region.

 

WHAT ARE OUR LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA?

 

If you are in the European Union, the processing of your personal data occurs in the United States. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

  • Consent: By using our website, you consent to our collection, use, and sharing of your personal data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the website. You will always have the right to withdraw any consent that you given to process your personal data. If you do choose to withdraw your consent, the withdrawal will not affect the lawfulness of processing your personal data prior to your withdrawal.
  • By agreement: We will process your personal data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you.
  • Legal obligation: We will process your personal data to the extent that we are required or permitted to do so by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
  • To protect your vital interests: We will process your personal data if we determine that it is necessary to do so to protect your vital interests.
  • A legitimate interest: We may also process your personal data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your personal data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Eberjey and you; detect and correct bugs and to improve our website; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other financial crime; promote and market our business; and check your credit and perform risk assessments.

 

SOCIAL MEDIA PLATFORMS

 

Our website contains social media buttons. This Privacy Policy does not cover such social media platforms. We are not responsible for the content of any social media platform, the products, or services offered on any social media platform, or the manner in which a social media platform may collect and use your personal data. We encourage you to read the privacy policy and terms and conditions of use that are posted on the social media platforms you visit.

 

WHAT DO WE USE YOUR PERSONAL DATA FOR?

 

We use your personal data for a variety of purposes. These include:

  • To present our website and its contents 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.
  • To allow us to better service you in responding to your customer service requests.
  • To quickly process your requests, transactions, purchases, and payments.
  • To administer a contest, promotion, survey, or other site feature. Some of these activities may have additional rules, which may contain additional information about how we use and disclose your personal data. We suggest you read such rules carefully, as you will be bound by them if you choose to participate.
  • To inform you about our services, products, and special promotions.
  • To investigate and respond to inquiries and complaints.
  • To improve and secure our website.
  • To produce aggregated data that does not identify you, which helps us generate statistics about our website users and products, the demographic distribution of visitors to our website, and the effectiveness of our marketing and promotion activities, which in turn helps us to analyze and improve the website, the user experience, and our products and services.
  • Fraud monitoring and prevention.
  • To provide customers that sign-up for our email list advance notice of sales, new arrivals, sample sale dates, and other Eberjey news. If you would like to unsubscribe from our email list, please refer to the “How Can You Opt-Out, Remove, Or Modify Information You Have Provided To Us?” section below.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account and product purchases.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. If you refuse to provide such personal data or withdraw your consent to our processing of personal data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
  • To notify you about changes to our website or any products or services we offer or provide though them.
  • 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, protect our rights and to allow us to pursue available remedies or limit the damages we may sustain.

 

HOW DO WE PROTECT PERSONAL DATA?

 

We take the security of your personal data seriously. We have put in place appropriate technical and organizational measures, including internal policies and controls, designed to:

  • Protect your information, for example to backup and protect the integrity of our electronic communications and data storage systems;
  • Limit access to your personal data to those employees, agents, contractors, and other third parties on a need to know basis. They may only process your personal data on our instructions, they are subject to a duty of confidentiality and are obliged to keep it secure;
  • Prevent your personal data from unauthorized or unlawful use or disclosure and against unintended access, loss or destruction, or damage; and
  • Deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

We implement a variety of security measures to maintain the safety of your personal data. Your personal data is maintained in private files on our secure web server and on our internal systems. All sensitive/credit card information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases.

 

HOW LONG DO WE RETAIN PERSONAL DATA?

 

Your personal data will not be kept longer than necessary and will be deleted, as soon as reasonably possible in view of the purposes for processing your personal data (see What Do We Use Your Personal Data For?), unless we have an ongoing legitimate reason to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). Under certain circumstances you may have the right to request that we delete personal information about you. If you would like to request access to or deletion of your personal information, please call us at 305 635 0030; or email us at privacy@eberjey.com.

 

When we have no ongoing legitimate business need or no other legitimate reason to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives and/or it is technically impossible and/or economically impractical), we will securely store your personal data until deletion is possible.

 

If you have questions about, or need further information concerning, our data retention periods, please contact us. (See “How Do You Contact Us?”, below)

 

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

 

We respect your privacy rights and will not sell, trade, or rent your personal data to other companies except as expressly set forth in this Policy. However, we need to share your personal data with third parties for certain purposes described in this Policy. These purposes include:

  • Service Providers and Third-Party Marketing Partners. We may use service providers (processors) to help us provide our services (e.g. operate and manage our website and online store, process orders and payments, maintenance, analysis, audit, payments, fraud detection, marketing, and development). These service providers include our third party marketing partners that provide advertising, promotional and marketing services for us on our behalf. We may share personal information with or sell personal information to select third parties for a commercial purpose, including Oracle Data Cloud customers and partners, digital marketers, ad agencies, web publishers, connected TV providers, demand side platforms, data management platforms, supply-side platforms and social media networks; and third-party service providers as necessary to perform Oracle Marketing & Data Cloud services on behalf of Oracle. These third parties will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated to not to disclose or use it for other purposes. The providers may solely process your personal data based on our instructions. For example, we work with service providers offering hosting services. We may also hire IT service providers to support the safe and stable operation of our systems. If we engage a third party to handle personal data, we shall perform a thorough background check on such third party and exercise proper supervision over such third party to ensure the safe management of personal data. We will enter into a data processor agreement with our data processors which meets the requirements of the GDPR.
  • Legal Authorities. We may need to share your data when we believe it's required by law or to protect the rights, security, property or safety of Eberjey, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary. We will attempt to notify visitors about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order, or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.
  • Enforce our Terms and Conditions. We may also share your personal data to enforce or apply our Terms and Conditions here and other agreements, including for billing and collection purposes.
  • Purchasers of our Business. We may also share your personal data as part of a sale, merger, or change in control of our business, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only for the purposes and in the manner set out in this Privacy Policy unless you notify the purchaser to the contrary.

 

OPT-OUT AND OTHER CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

 

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

 

In addition, we strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with control over your personal data:

  • Promotional Offers From Eberjey. We may also use your information to contact you about our other products and services that may be of interest to you. If you wish to consent to this use, please select the box at checkout (or when prompted) to sign up for our newsletter and product updates by email. If you wish to opt-out of receiving emails from us, you may do so at any time by selecting unsubscribe at the bottom of our emails, or by sending us an email stating your request at privacy@eberjey.com. This opt out does not apply to information provided to Eberjey as a result of a product purchase or other transactions.
  • Targeted Advertising. You can opt-out of our sharing your personal information with third parties under certain circumstances, such as sharing your personal information with third parties for targeted advertising purposes. To opt-out of third party data sharing, please email us at privacy@eberjey.com. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (networkadvertising.org) and from members of the Digital Advertising Alliance (“DAA”) on its websites (www.aboutads.info and www.privacyrights.info). EU/EEA-based  individuals can access the European Interactive Digital Advertising Alliance (“EDAA”)  opt-out  program  currently  available  at http://www.youronlinechoices.eu/). If you use a mobile device to access our Site, opt-out information is available through DAA’s AppChoices Program available at http://www.aboutads.info/appchoices. 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 also opt out of receiving targeted ads from members of the NAI on its website.

 

HOW DO YOU REMOVE OR MODIFY INFORMATION YOU HAVE PROVIDED TO US?

  • Withdrawal of Consent: To the extent that our processing of your personal data is based on your consent, you can withdraw your consent to the processing of your personal data at any time. To modify your email subscriptions, unsubscribe from our email list, or update or remove your personal data from our system, please log in to www.eberjey.com and click My 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: At your request, we will delete your personal data from our systems as soon as possible, but please note that due to pre-scheduling of email campaigns, you may receive another email before you are completely removed. 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 this 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. If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms and Conditions available here.
  • Information Access and Correction: You have the right to receive information about the type and contents of the personal data that we store or process and to request the correction of and/or change to any incorrect or incomplete personal data that we hold. We may also 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 to Use: You may object to our use of your personal data or request to limit our use 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.
  • Data 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 may request a copy of your personal data that we store and the transfer of the personal data to another party 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.
  • Profiling: You may object to decisions made solely based on automated processing, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.
  • Requests and 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 in order 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 below under “How Do You Contact us?”. 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.

 

 

DO NOT TRACK SIGNALS

 

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

 

AUTOMATED DECISION MAKING

 

We do not use your personal data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

 

STATE SPECIFIC PRIVACY RIGHTS

 

The law in some states may provide you with additional rights regarding our use of personal data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Policy.

 

USE OF THE WEBSITE BY MINORS

 

Our website is not directed to individuals under the age of 18 and we request that they not provide personal data to us without express parental consent.

 

SENSITIVE INFORMATION

 

We ask that you not send to us, and not disclose, any sensitive personal data such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, sexual orientation, health, biometrics or genetic characteristics, criminal background or trade union membership.

 

HOW DO YOU CONTACT US?

 

If you have any questions about this Privacy Policy, please contact us by email at privacy@eberjey.com. We can also be reached by mail at 1200 Ponce De Leon Blvd, Suite 802 Coral Gables, FL 33134, or by telephone at 305 635 0030.

 

TEXT MESSAGING

 

You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more.  These messages may use an automatic telephone dialing system and information automatically collected based on your actions while on our sites and may prompt messaging such as cart abandon messages.  To the extent you voluntarily opt to have text notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages. For more information about text messages, see our Terms and Conditions.

 

CHANGES TO OUR POLICY?

 

We recognize that information privacy is an ongoing responsibility and that applicable laws and regulations are subject to change, so we may from time to time update this Privacy Policy. If we decide to make any material changes to how we treat our users’ personal data, we will post a notice on the website’s home page. Policy changes will apply only to information collected after the date of the change. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our website and this Privacy Policy to check for any changes.

 

This policy was last modified on January 26, 2022.


California Privacy Rights

Eberjey Privacy Addendum for California Residents

 

Effective Date: January 26, 2022

Last Reviewed on: January 26, 2022

 

This Privacy Addendum for California Residents (“Privacy Addendum”) supplements the information contained in Eberjey Privacy Policy that this is attached to and applies solely to all visitors, users, and others 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. Personal Information that is regulated under the CCPA may represent a limited portion of personal data as described in the Eberjey Privacy Policy; therefore, this Privacy Addendum applies solely to the Personal Information as defined below. We may update this Privacy Addendum for California Residents as necessary and in the event of changes in the CCPA. Note that this notice does not apply to our personnel. Please contact your supervisor if you are personnel and would like additional information about how we process your personal information.

 

INFORMATION WE COLLECT

 

Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information” or “Personal Data”). In particular, Eberjey collects and has collected Personal Information through its website from its consumers, as provided below.

 

Categories of Personal Information Eberjey has collected in the preceding 12 months:

  • Identifiers (e.g. name, mailing address, email address, unique personal identifier, online identifier, Internet Protocol address (IP address), or other similar identifiers)
  • Personal Information categories listed in the California Customer Records statute (e.g. name, address, telephone number, credit card number, or debit card number. Note, some of this information may overlap with other categories)
  • Commercial information (e.g. records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
  • Internet or other similar network activity (e.g. browsing history, search history, information on a consumer’s interaction with a website, email, application, or advertisement)
  • Geolocation data (e.g. physical location of your device (by country or zip code))
  • Inferences drawn from other Personal Information (e.g. profile reflecting a person’s preferences)

 

Personal Information does not include information that is: (a) publicly available information from government records; (b) deidentified or aggregated consumer information; or (c) certain information excluded from the scope of CCPA, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

Categories of sources from which Eberjey has collected Personal Information:

  • Directly from you. For example, from forms you complete when purchasing a product
  • Indirectly from you. For example, from our operating systems and platforms
  • Affiliates, parents, and subsidiary organizations of Eberjey
  • Service providers
  • Business partners who we partner with to offer our products
  • Advertising networks

 

USE OF PERSONAL INFORMATION

 

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • 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, we will use that Personal Information to respond to your inquiry. We may also save your information to help you check out faster and to provide recommendations for future purchases.
  • To provide, support, develop, and improve our website and products.
  • To process your requests, purchases, transactions, and payments, and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns, and to monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our website and products, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Undertaking internal research for technological development and demonstration.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • 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 Information held by Eberjey about our customers are among the assets transferred.

 

Eberjey 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.

 

SHARING PERSONAL INFORMATION

 

We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another organization for monetary or other valuable consideration except as expressly set forth in this Policy (e.g., see the Section With Whom Do We Share Personal Data?). Eberjey may disclose your Personal Information to a third party for one or more business purposes. 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.

 

Disclosures of Personal Information for a business purpose:

In the preceding twelve (12) months, Eberjey has disclosed the following categories of Personal Information for a business purpose:

  • Identifiers
  • California Customer Records Personal Information categories
  • Commercial information
  • Internet or other similar network activity
  • Geolocation data
  • Inferences drawn from other Personal Information

 

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Service providers
  • Affiliates
  • Advertising Networks
  • Business partners

 

Sales of Personal Information:

 

In the preceding twelve (12) months, Eberjey had not sold Personal Information.

 

 

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.

 

Access Request Rights

 

You have the right to request that Eberjey 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 and Deletion Rights), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you.
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

 

Deletion Request Rights

 

You have the right to request that Eberjey 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 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:

  1. 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, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  6. Comply with a legal obligation.
  7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Opt-Out and Deletion Rights

 

To exercise the access, opt-out and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf (an “Authorized Representative”), 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:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Representative. Before completing your request to exercise the below, we will verify that the request came from you by asking you one or more knowledge-based questions about you.
  • 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. With few exceptions, we will only review and fulfill a request from your Authorized Representative if (a) you grant the Authorized Representative written permission to make a request on your behalf, (b) you or the Authorized Representative provides us notice of that written permission, and (c) we are able to verify your identity in connection with that notice and the request.

 

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.

 

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

 

Response Timing and Format

 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 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 the contact information you provided in 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.

 

Personal Information Sales Opt-Out

 

If you would like to opt-out of our use of personal information for purposes that may be considered a “sale” under the CCPA, you may do so by calling us at 305 635 0030; or emailing us at privacy@eberjey.com.

 

 

NON-DISCRIMINATION

 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

ADDITIONAL CALIFORNIA RIGHTS

 

California law permits minors under the age of 18 to request the removal of your User Contributions, subject to certain exceptions. If you are under the age of 18 in California, you may contact us at privacy@eberjey.com, or by telephone at +1 305 635 0030 (if you contact us via email, please use the subject “California Eraser Law Request”). We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor’s information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Website or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the internet in the future. We do not advertise or market any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age.

 

CHANGES TO OUR CALIFORNIA ADDENDUM

 

We reserve the right to amend this Privacy Addendum as described in our Privacy Policy. When we make changes to this Privacy Addendum, we will inform you of such updates as described in our Privacy Policy.

 

INTERNATIONAL USERS 

Eberjey is the data controller of the Personal Information you provide on the website and/or through the Services.     

Consent to Processing of Personal Information.   

We rely on your consent as a lawful basis to process your Personal Information for the following purposes:  

  • Initial collection of Personal Information through the website and/or the Services; and   
  • Providing you with marketing or promotional communications. You may opt-out of such communications at any time by clicking the “unsubscribe” link found within the Eberjey email updates and changing your contact preferences.   

We also process Personal Information based on our contractual obligations to provide you the website and/or the Services as described in How do we share your Personal Information?, including:  

  • To enable the website to function as expected.  
  • To communicate with you in response to customer services inquiries, to deliver non-promotional, service-related emails, or to administer surveys and questionnaires.  
  • To tailor your experience based on your general region.   

Eberjey may also process Personal Information pursuant to a legal obligation or to protect your vital interests or those of another person.   

We will process your Personal Information as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Information if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Eberjey and you; detect and correct bugs and to improve our website and/or the Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; develop our Products and Services.  

Eberjey has appointed a Data Protection Officer in the European Economic Area (“EEA”) in compliance with the General Data Protection Regulations. Eberjey and its subsidiary, Eberjey, LTD, and its Data Protection Officer may be contacted in any manner set forth below in Contact Us.  

What rights do I have?   

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

  • Access and Update. You can review and change your Personal Information by notifying us through the Contact Information below of any changes or errors in any Personal Information 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.   
  • Restrictions. You have the right to restrict our processing of your Personal Information 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 Information is determined to be unlawful, or if we no longer need your Personal Information for processing but we have retained it as permitted by law.   
  • Portability. To the extent the Personal Information 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 Information in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Information to another controller, when technically feasible.  
  • Withdrawal of Consent. To the extent that our processing of your Personal Information 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 Information.   
  • Right to be Forgotten. You have the right to request that we delete all of your Personal Information. We cannot delete your Personal Information 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 Information or after a final determination that your Personal Information 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 Information as set forth in this policy. In addition, we cannot completely delete your Personal Information 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 in order 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 Information, you may be charged a fee subject to a maximum set by applicable law.  

Automated Decision Making.  

Our processing of Personal Information may include automated decision making, including profiling, which may produce a legal effect concerning you or similarly significantly affect you. The algorithms used for our automated decision making process classifies and categorizes your interests and preferences based on data collected by the website and Personal Information collected by the website.   

 

 

Eberjey Privacy Addendum for Nevada Residents

Effective Date: January 26, 2022

Last Reviewed on: January 26, 2022

 

Eberjey respects your privacy and is committed to protecting it through our compliance with this policy.

 

You are entitled under Nevada law to formally request that we not sell any of your personal information. Please email us at privacy@eberjey.com to submit your request and we will confirm your request.