1. Collection of Information: We collect the following categories and types of information from the various sources highlighted below:
1. Information You Provide to Us
In this Policy “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This will usually include various different types of information as describe below.
We may ask you to provide us with the following Personal Information: (1) contact information and other identifying information, including your first and last name, email address, home address, zip code, phone number; (2) financial information, including credit and debit card numbers, checking account numbers; (3) demographic information, including date of birth ; (4) audio and visual information, including your videos and photos; (5) commercial information, including products purchased or viewed on our Site; and (6) inferences drawn from the other information that we receive directly or passively from you, in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude. We may collect this information from you such as when you:
- Submit account registration forms;
- Sign up or request to be placed on our mailing, SMS text and/or email marketing lists;
- Place an order through the Site;
- Participate in a survey or Promotion (defined in Section 3(e) below);
- Contact us regarding a question or concern;
- Submit an application for employment; and
- Otherwise interact with the Site or the Store.
Your decision to provide this information is voluntary, but if you choose not to provide this requested information you may not be able to take advantage of all of the Site’s features or our services.
2. Information We Passively Collect When You Use the Site
In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain identifiable information when you visit or interact with the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:
- your IP address or other unique identifier ( “Device Identifier”);
- your Device browser, operating system and mobile network information;
- the areas within our Site that you visit and your activities there, including remembering you and your preferences;
- your general location; and
- certain other Device data, including the time of day you visit our Site, among other information.
We may use various methods and technologies to collect and/or store Usage Information, such as:
- Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some (but not all) instances can be blocked by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options. Please note that these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, visit www.adobe.com. Please understand that if you disable or remove any type of cookie, some parts of our Site may not function properly.
- Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages. Web beacons may be used by us for a number of purposes, including to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter. The embedded script does not collect your Personal Information.
- ETag, or entity tag. An ETag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.
We may use the above technologies (or ones we incorporate in the future) for a variety of purposes, including:
- Prevention of fraudulent activity and improved security functionality.
- To assess the performance of the Site.
- To offer you enhanced functionality when accessing the Site, including identifying you when you sign in to our Site or keeping track of your specified preferences.
- To deliver content relevant to your interests on our Site and third party sites based on how you interact with our advertisements and/or content.
Our Site (including our mobile apps) may use location-based services to verify your location, deliver you relevant content and/or advertising based on your location, as well as to share your location with our service providers as part of the location-based services we offer. Further, we or our service providers may use your location information to display our nearest Store location to you. You have the ability to turn location-based services on and off by adjusting the settings of your Internet browser or mobile device, or by following the standard uninstall process and removing all new-towels.com Imports applications from your mobile device.
4. Information We Collect From Third Parties
5. Information We Collect When You Interact with Third-Party Sites
6. Information You Provide About a Third Party
You may send someone else a communication from the Site, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) will be used to facilitate the communication and will not be used for marketing purposes unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Site, your email address, mobile number, name or username and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.
2. How We Use the Information We Collect
We may use your Personal Information, Demographic Information or Usage Information for various purposes, including, but not limited to, the following:
- Improving the effectiveness of our Site, marketing endeavors and service offerings;
- Processing credit applications;
- Site registration;
- Processing and completing purchase, return and similar transactions;
- Providing customer service;
- Notifying you of product recalls or providing other information concerning products you have purchased;
- Sending you direct mail offerings;
- Sending you email communications such as electronic newsletters about our products, services and Promotions;
- Sending you email about orders you have made on new-towels.com;
- Enabling you to participate in the Site’s features such as surveys and Promotions;
- Identifying your product and service preferences and informing you of new or additional products, services and Promotions that may be of interest to you;
- Providing mobile marketing messages and service messages;
- To analyze preferences, trends and statistics; and
We may share your Personal Information, Demographic Information or Usage Information with third parties under various circumstances, including, but not limited to, the following:
1. When You Request We Share With Third Parties.
We may share information with third parties at your request. In the event we do so, all information we disclose will be subject to the privacy policies and practices of such third parties. In addition, the third parties may store, collect or otherwise have access to your information when you interact with their technologies, content or apps on our Site or link to them from our Site. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools. We are not responsible for the practices of such third parties and, therefore, you should review such third-party privacy policies prior to interacting with them.
2. Third Parties Providing Services to new-towels.com Imports.
We may use third party service providers to perform certain services, such as: (a) to assist us in e-commerce operations; (b) to manage a database of customer information; (c) hosting the Site; (d) designing and/or operating the Site’s features; (e) tracking the Site’s activities and analytics; (f) enabling us to send you special offers or perform other administrative services; (g) to allow you to participate in live chat on the Site; and (h) other services designed to assist us in maximizing our business potential. We may provide third parties with access to your information to carry out the services they are performing for us. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us. Third-party analytics and other service providers such as Google Analytics may set and access their own technologies on your Device and they may otherwise collect or have access to information about you. These service providers use the technology described above to help us analyze how users use the Site and to provide advertisements to you on other websites. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices. For example, to learn about opting out of Google Analytics, please click here. To learn about opting out of the use of Adobe cookies for analytics and on-site personalization, please click here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
3. Adobe Marketing Cloud Device Co-op.
4. To Protect the Rights of new-towels.com Imports and our Users.
We may disclose your Personal Information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of new-towels.com Imports or third parties (including through the enforcement of this Policy, our Terms of Service, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders).
5. Affiliates and Business Transfer.
We may share your information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site and/or our Stores; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.
6. Sweepstakes, Contests and Promotions.
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Site, in the Stores or through one of our social media pages that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and likeness in advertising associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
7. Co-Branded Areas.
4. Information You Disclose Publicly
1. User Content and Public Information.
The Site may permit you to submit ideas, photographs, videos, audio recordings, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), on blogs, social media sites and message boards and other public forums, as well as in connection with our Site’s product review service and wish list feature. We or others may store, display, publish, distribute or otherwise use User Content online or offline in any media or format and may or may not attribute the User Content to you. Others may have access to this User Content and may have the ability to share it with third parties. Please note that new-towels.com Imports does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Site or what others do with information you share with them on the Site.
2. Name and Likeness.
We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit, please review our Terms of Service.
5. Interest-Based Advertising
You may see certain ads on other websites because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the technologies described in the “Information We Collect When You Use the Site” Section above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site, such as the pages you have viewed. This collection and ad targeting takes place both on our Site and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our marketing efforts. We and our service providers, including Google and Adobe, use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to report how our internet advertising methods are related to your related to visits to the Site.
Also, some third parties, such as companies that offer Internet browsers, have developed signals (e.g., browser do not track signals) that give you a choice regarding the collection of information about your online activities over time and across third-party websites or online services. Currently, we do not monitor or take any action with respect to these signals or other mechanisms offered by Internet browsers. If you would like more information on self-regulatory programs that permit you to exercise choice, click on the ad networks link in the paragraph above.
6. Third-Party Content and Links to Third-Party Sites
The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site, you may be directed to other services that are operated and controlled by third parties. For example, the giftcertificates.com site used to purchase new-towels.com Imports gift cards online is operated by a third party. We are not responsible for the data collection and privacy practices employed by any of these third parties. You access these third party websites or content at your own risk. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may independently collect data about you and may or may not have their own published privacy policies.
7. Transfer of Information to the United States
Our Site is operated in the United States and Canada and intended for users located only in the United States and Canada. If you are located outside of the United States, please be aware that information we collect will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States.
8. What Should Parents Know About Children
We understand the importance of protecting children’s privacy in the interactive world. We do not use the Site to knowingly collect Personal Information from children under the age of 13 without parental consent. If you are a child under 13 years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Site.
In the event that we become aware that we have collected Personal Information from any child, we will dispose of that information in accordance with the Children’s Online Privacy Protection Act. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with information without your consent, please contact us at firstname.lastname@example.org, and we will take reasonable steps to ensure that such information is deleted from our databases. California users under the age of 18 may request the removal of their content or information publicly posted on the Site by e-mailing us at email@example.com.
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.
10. How Long Is My Personal Information Retained
11. Updating Your Information and Choices
You may update or correct information about you through the Site’s account registration forms or by contacting us:
- By Phone: +1 413-237-4442.
- By Email: firstname.lastname@example.org.
- By Postal Mail: new-towels.com Imports Online, Inc., Attn: Customer Service, 151 Catoctin Cir SW, Leesburg, VA 20175, UNITED STATES.
You may opt out of receiving promotional mail, emails and/or text messages from us by sending an email to email@example.com or letter to new-towels.com Imports Online, Inc., Attn: Customer Service, 151 Catoctin Cir SW, Leesburg, VA 20175, UNITED STATES. Please be sure to include your current information and the requested changes you would like us to make to your marketing profile in your communication. You may also cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. Additionally, if you subscribe to text messages from us, you can terminate a particular text message subscription by reply texting “STOP.” Please allow 10 days to process your email request and 6-8 weeks to process your postal mail request, during which period you may continue to receive communications from new-towels.com Imports. Please note that we will retain your information for legitimate business purposes or as required by law. Also, if you have made any public postings on the Site such as in user comment sections of the Site, these communications cannot generally be removed.
Please note that we may still send you certain communications relating to your account or use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
13. Applicable Law
Your California Privacy Rights
California's Civil Code section 1798.100 et seq. provides residents of California a number of rights as they relate to Personal Information. These are the “right to know”, the “right to delete”, and the “right to opt-out”.
Right to Know. You may request new-towels.com provide you the specific pieces of Personal Information that new-towels.com has about you; categories of Personal Information we have collected about you; categories of sources from which the Personal Information is collected; categories of Personal Information that new-towels.com sold or disclosed for a business purpose about you; categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling Personal Information. Please note that much of the information you can make a request for is already contained in this Policy. Should you wish to exercise this right, please see the section below which explains how to do so. If you do not have an account with new-towels.com, we will need to have sufficient information to be able to verify your identity, such as your email address, phone number, and last date of purchase.
Right to Delete. California law gives residents a limited right to request deletion of their Personal Information. However, this right is limited by a number of exceptions. Fundamentally, if new-towels.com has a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with new-towels.com; comply with a legal obligation; or otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information. However, we will respond to requests to remove Personal Information from some of our systems as a part of a request to close or otherwise disable a membership account. If you would like to request deletion of Personal Information, please see the section below which explains how to do so. If you do not have an account with new-towels.com, we will need to have sufficient information to be able to verify your identity, such as your email address, phone number, and last date of purchase..
Do Not Sell My Personal Information
Personal Information that We Sell
We may “sell” (as sell is defined in California's Civil Code section 1798.140) the following categories of Personal Information:
- Characteristics of protected classifications under California and federal law;
- Internet/electronic activity;
- Commercial information; and
- Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, preferences, behavior and attitudes.
We “sell” your Personal Information to digital advertising networks. We do not knowingly sell the Personal Information of minors under the age of 16.
If you would like to opt-out of any sale of your Personal Information, you may do so by following the procedure outlined above in the section entitled “interest based advertising”.
Designating an Authorized Agent. California law permits California residents to designate an agent to manage their rights under California law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Exercising California Privacy Rights”. Note that If you do not have an account with new-towels.com, we will need to have sufficient information to be able to verify your identity, such as your email address, phone number, and last date of purchase. We will also need sufficient Personal Information about your authorized agent to be able to identify them. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent.
Non-discrimination. California law does not permit new-towels.com to discriminate against you because you exercised any your rights under this title, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Financial Incentives. We offer various financial incentives. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by contacting us at firstname.lastname@example.org. The value of your data is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer.
Exercising California privacy rights. If you are a California resident and would like to exercise any of your rights you may do so by contacting us via the methods noted above in the section entitled “Updating Your Information and Choices”. Please be aware that new-towels.com will need to have sufficient information to be able to verify your identity, such as your email address, phone number, and last date of purchase. Please include the right that you are exercising in the subject line to your request.
Your Connecticut Privacy Rights
Connecticut law requires any entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.