Last Updated September 13, 2023
This policy applies to information we collect:
· On the Sites.
· In email, text, and other electronic messages between you and the Sites.
It does not apply to information collected by any third party, including through any application or content (including advertising) hosted by a third party that may link to or be accessible from the Sites except to the extent such information is actually provided to us.
Section II – What Data We Collect
Our Sites collect various information about you, including information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In particular, the Sites may have collected the following categories of information from consumers within the last 12 months:
(A) Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
(B) Personally identifiable information A name, signature, address, year or month of birth, household information, telephone number, email address, credit card number, debit card number, or any other financial account information. Some information included in this category may overlap with other categories.
(C) Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(D) Internet or other similar network
activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
(E) Certain Sensitive Information Birthday, pregnancy due date, and medical preferences information.
(F) Inferences drawn from other
personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Thuasne USA obtains the categories of information listed in the table above from the following categories of sources:
· Direct interactions. You may share with us some identifiers or personally identifiable information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o inquire about our products or services;
o apply for a job opening;
o request marketing to be sent to you;
o enter a competition, promotion or survey;
o interact with our sales team or place an order (including through Salesforce or other third party tools used by our team); or
o give us some feedback.
· Automated technologies or interactions. As you interact with our Sites, we may automatically collect Internet or other similar network activity about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please learn more about the cookies we use and about setting your preferences in Section VI – Cookies & Tracking below.
· Third parties or publicly available sources. We may receive analytics and advertising data about you from the sources listed below, as well as, public sources. Please use the following links for more information about how these sources use data when you visit their websites or apps: o Facebook – https://www.facebook.com/about/privacy o Google – google.com/policies/privacy/partners/ o LinkedIn – linkedin.com/legal/privacy-policy o Instagram – https://help.instagram.com/519522125107875/
· Blog. Some of the Sites offer publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access the blog.
Thuasne USA does not collect information through the Sites that consists of:
· Sensitive personal information, other than as describe in Category E above, such as social security numbers, driver’s license numbers, or other similar non-financial information.
· Protected classification characteristics such as race, color, ancestry, national origin, or similar immutable characteristics.
· Geolocation information about your precise location.
· Biometric information such as genetic, physiological, behavioral, and biological characteristics.
· Sensory data such as audio, electronic, visual, thermal, olfactory, or similar information.
· Professional or employment-related information from consumers other than applicants, employees, business owners, directors, officers, medical staff, or contractors of Thuasne USA.
· Non-public education information.
Section III – How We Use Data
Thuasne USA uses data collected to:
· To process purchases, transactions, and payments;
· To fulfill or meet the reason you provided the information;
· Assess your needs to determine suitable products;
· Respond to customer service requests;
· Respond to your questions and concerns;
· Administer your account with Thuasne USA;
· Manage and communicate with you regarding your Thuasne USA account, if you have one, including by sending you product announcements, order information, and support and administrative messages;
· Operate, maintain, administer, improve, and secure the Sites;
· Gather product feedback through reviews;
· Offer surveys and contests to you;
· Send you newsletters and other marketing communications;
· Improve the Sites and our general marketing efforts;
· Conduct research and analysis;
· Analyze trends and track user movement and gather broad demographic information; and
· Study how the Sites are used and to improve the Sites and our other products and services.
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention and safety. We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect
our rights, privacy, safety or property, and/or that of you or others; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and (d) deter and attempt to mitigate threats to the safety, security, or integrity of the Sites.
Section IV – How We Share Data
· Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, in the course of the professional services that they render to us.
· Compliance with Laws and Law Enforcement; Protection and Safety. Thuasne USA may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We may also share any data as otherwise required or permitted by law or approved by you. We may use your information for our general business operations and goods and services provided by us if it is in a form that is not capable of being personally identified with you (including hashed email addresses as described below or other persistent identifiers) or if it is combined with information from one or more other customers in aggregate form that does not personally identify any particular customer. We may also sell, license or otherwise provide such de-identified or aggregated data to third parties.
Section V – Cookies & Tracking
Cookies. We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or
mobile device until you delete them). We may utilize cookies to provide you with a more personal and interactive experience on our Site, gather analytics about the traffic that visits our Sites and how users use our Sites all of which is used for marketing purposes.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
We may choose to use a certain type of cookie to track your browsing habits and gives us the ability to show relevant ads to you. You can disable certain cookies which remember your browsing habits and target advertising at you by visiting: · Network Advertising Initiative (NAI) Consumer Opt-Out Page · Digital Advertising Alliance (DAA) WebChoices · Digital Advertising Alliance of Canada (DAAC) Consumer Choice (for Canadian users) · European Interactive Digital Advertising Alliance (EDAA) Choice (for EU users)
Pixel tags. We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Sites to track the actions of users on our Sites. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Sites, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
Section VI – Your California Privacy Rights
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please contact us at firstname.lastname@example.org. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.
If you reside in California, you also have the following rights:
· You have the right to opt-out of Thuasne USA’s sale of your personal information to third parties.
· You have the right to request the deletion of your personal information, subject to certain exceptions.
· You have the right to request us to disclose to you, no more than twice in a 12-month period, the personal information about you that Thuasne USA collects, uses, discloses, and sells during the preceding 12 months, which shall include as follows:
o o The categories of personal information that we’ve collected and sold about you, or shared for a business purpose with our service providers.
o o The sources from which we collected such information.
o o The third parties with whom we’ve shared that personal information and to whom we’ve sold that personal information.
o o The business or commercial purpose for collecting or selling that personal information.
o o The specific pieces of personal information we’ve collected about you.
Section VII – Your Rights & Choices.
You have the right to request that Thuasne USA not contact you or use your Personal Information for purposes which are not reasonably necessary for the administration of our Sites and any services. If you wish to exercise this optout right or to terminate your account, please contact us at email@example.com.
Where required under applicable law, we will only send you marketing communications with your consent. When you receive marketing communications from us, you may indicate a preference to stop receiving further communications from us, and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the communication you receive, or by contacting us at firstname.lastname@example.org.
Section VIII – Opting Out
Newsletter & Marketing. Thuasne USA will periodically send you email advertisements regarding the products offered. Thuasne USA will not send you marketing messages if you have opted out. You may choose not to receive messages in the future by following the “unsubscribe” instructions located near the bottom of each email or by contacting us at email@example.com.
Transactional E-mails. Thuasne USA provides certain e-mails related to order transactions including order confirmations, shipping confirmations, and shipment tracking information. Please
note that you cannot unsubscribe from certain correspondence from us regarding our services to you, including messages relating to your account, unless you stop using such services in their entirety. In addition, certain information may be required in order to use our Sites; as such, the only practicable method to opt out of providing information in connection with the use of those Sites would be to refrain from subscribing to or using those Sites. In addition, certain messages may be required by law and which you cannot unsubscribe.
Mailing List. We may occasionally contact you about our products and services, including, but not limited to, such things as new product announcements, product information, and newsletters. If you prefer not to receive such correspondence, simply email us at firstname.lastname@example.org.
Section IX – Data Security Disclaimer
Unless required by law, we do not provide any guarantee or warranty by us that your information will not be accessed or compromised by third parties, or that we will use all available security technologies to prevent unauthorized access to, use, or disclosure of your personally identifying information; or that your information will be transmitted without unauthorized interception or modification. We may permanently delete or destroy any and all information at any time as determined by us.
Section X – Transfer of Information to The United States
The Sites are based in the United States, and are directed to U.S. residents, and we process and store information in the U.S.If you are located outside the U.S., we and our service providers may transfer your information to, or store or access to your information in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.
Section XI – Children’s Personal Information
The Sites are general audience sites and are not directed to children under the age of 13. Thuasne USA respects the privacy of parents and children and is committed to complying with the Children’s Online Privacy Protection Act and applicable state law. If a parent believes that his or her child has submitted personal information to Thuasne USA, he or she can contact us via email or postal mail as listed below. Thuasne USA will promptly delete all identifying information upon learning that it relates to a child under the age of 13.
Section XII – Contact Information