Updated June 24, 2022
About This Policy
This Policy describes the privacy practices of the Company and its subsidiaries, divisions, and affiliates (collectively and/or individually, “Company”, “our”, or “we”). Except as otherwise provided, it applies to our interactions with our customers and visitors, including, but not limited to:
- Use of our websites, including mobile websites, applications (collectively, the “Site”)
- Visits to our stores/locations or attendance at one of our events
- Phone and email communications
- Social media interactions on our websites and other third-party websites like Facebook, YouTube, Pinterest, Google+, Instagram and Twitter
- Viewing our online advertisements or emails
- Through our authorized service providers
Personal Information We Collect
As described below, the Company may collect or has collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of personal information we collect about you. In that case, we will inform you.
- Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements. Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number.
- Characteristics of protected classifications under California or federal law. Examples include race, religion, and age.
- Commercial information. This includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Education information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data. This might include location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category including identifiable information obtained about you while speaking with our customer service representatives on the telephone.
- Professional or employment-related information.
- Consumer profile. This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
Purposes We Collect Your Personal Information.
Set forth below are the business or commercial purposes for which we have collected your PI. We may, in the future, use your PI for additional or different purposes. Before doing so, we will inform you and obtain your consent when required by law.
- To provide you with information, products or services that you request from us.
- To fulfill or meet the reason for which the information is provided. For example, if you purchase a product from us, we will collect your address for shipping purposes or to fulfill our tax collection and reporting obligations.
- To contact you and/or provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To engage in marketing activities, including to help design products and services appropriate for our clients.
- To communicate with you via social media concerning our products and services.
- To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To review, improve, and monitor our website, applications, online services, and overall client experience, including to provide customization to meet specific needs, ensure a consistent experience, and assess trends, interests, and demands of clients.
- To provide customer service and engage in quality control activities concerning our products and services.
- For testing, research, analysis and product and service development.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To process applications for employment, as well as to evaluate and improve our recruiting efforts.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sources of Personal Information
Below is a non-exhaustive list of sources from which we may collect your PI.
- You. For instance:
- During a website visit, when you complete a web-form, or when you visit us at one of our stores, locations, or events.
- If you upload or share a photo, submit a request, submit information, or post other digital content through one of our websites, applications or via social media interactions on third party websites like Facebook or Twitter.
- If you register for a referral or loyalty program.
- If you participate in a sweepstake, contest, promotion, program, clinic or workshop.
- If you request a quote, warranty or other information.
- If you use a rebate.
- In connection with your interactions with us as a registered user of our websites.
- We may use tracking tools like browser cookies, flash cookies, and web beacons.
- Your friends and family, such as when they provide your information through one of our refer-a-friend type features or programs. Persons who share such information in connection with those features or programs should only submit email addresses of individuals with whom they have a close personal or family relationship, who would be interested in receiving the communication, and who have authorized the sharing of their email address
- News outlets
- Social media and related services
Sharing Personal Information
During the past 12 months, we shared the following categories of PI with the following categories of third parties:
Categories of Personal Information Disclosed
Categories of Third Parties to Whom Disclosed
Characteristics of protected classifications under California or federal law
Internet or other electronic network activity
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
We do not sell your PI and do not have actual knowledge that we have sold personal information of minors under age 16.
Cookies and Other Tracking Technologies
As is true of most websites and applications, the Site collects some personal information automatically and stores it in log files. This information may include your IP address, browser type, language, internet service provider (ISP), referring and exit page, operating system, and date/time stamp. We use this personal information to, for instance, improve our understanding of and analyze trends, to administer the Site, to learn about user behavior on the Site, and to gather demographic information about our user base as a whole.
To monitor use of the Site and improve its quality, we may compile statistical information concerning the use of the Site through analytics services, such as those provided by Google Analytics, and may also use tools that record user sessions, including IP addresses. Examples of this information may include: the number of visitors to the Site or to sections or pages of the Site; patterns of traffic flowing through the Site; length of time spent on the Site, or in sections or pages of the Site; the other sites that refer visitors to the Site; the pages of the Site that visitors frequently use as entry and exit points; and utilization of the browser and operating systems and versions used by visitors to the Site.
We may use various kinds of software devices to collect information about use of our Platform.
- Cookies. One such device is “cookies,” which are small files that uniquely identify and recognize your browser or device and automatically collect certain information from you. The Site utilizes a few different types of cookies, which are described below.
- First and Third Party Cookies. First party cookies are generally placed on your computer or device by the website you are visiting. For example, we may use a first party cookie to improve website security. Third party cookies are placed on your computer or device by a source other than the website you are visiting in order to enable third-party features such as advertising, analytics, videos, or interactive content.
- Essential or Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually set in response to actions taken by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These cookies do not store any personally identifiable information.
- Performance and Functionality Cookies. Although these are non-essential cookies, they help the website perform and function as designed. For example, performance and functionality cookies may help the website display videos, enable chat sessions, or recognize whether you visited the website before.
- Analytics Cookies. These cookies track your usage of the website. The information these cookies collect can be used for various purposes such as understanding how visitors use the website, site and content customization, or advertising and marketing.
- Advertising Cookies. Advertising and marketing cookies perform functions such as helping customize your website experience, personalizing ads based on your online activities and interests, measuring the effectiveness of ads, preventing an ad from reappearing, and serving you targeted advertisements. Information from these cookies may be shared with third parties or third parties may place these cookies on your computer or device. Advertising and marketing cookies may track your online activities.
- Customize your experience during a session or across sessions.
- Track the number of unique visitors to our Site, which enables us, among other things, to ensure the Site has sufficient capacity.
- Customize content on the Site.
- Collect anonymous statistical information about Site use, including about the amount of time a user spends on the Site, which website they navigated to the Site from, and how they used Site.
- Web beacons. We may also use web beacons to review how visitors navigate the Site.
- Social media plugins. The Site may also use social media plugins (e.g. Facebook, Twitter, LinkedIn) to enable you to easily share information with others. When you visit the Site, the operator of the social media plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Site. If you are logged into the social media website while browsing our Site, the social plugins allow that social media website to share data about your activities on our Site with other users of the social media website. For example, Facebook Social Plugins could allow Facebook to show certain of your activities on our pages to your Facebook friends and your friends’ activities to you. We do not control any of the content from the social media plugins. For more information about plugins from other social media websites, please refer to those sites’ privacy and information sharing policies.
IMPORTANT: By using the Site, you consent to the processing of any PI provided or collected for the analytics purposes and functions described above.
Do Not Track.
“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Our Sites and Children
We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contacting Us section below.
Notice to Site Users Located Outside the U.S.
The Company operates in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
If you have additional questions, you may call us at 888-444-4203 or reach us by email at email@example.com. You can write to us at Fabble Legal Department 1833 54th Street Brooklyn NY 11204.
Effective Date: December 27, 2021
For California Residents
The CA Policy describes Company’s policies and practices regarding the personal information we collect, use, and disclose about you, including personal information you submit or we obtain when you access the Site and other sources. This CA Policy is adopted in part to comply with the California Consumer Privacy Act (“CCPA”).
Any terms defined within the CCPA have the same meaning when utilized within this CA Policy. The other provisions of the Policy continue to apply except as modified in this CA Policy. Note, however, that personal information as used in this CA Policy does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, such as personal information covered by certain sector-specific privacy laws, 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.
Consumer Rights. Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI. These include:
- Request to Delete. You have the right, subject to certain exceptions, to request that we delete your PI from our records and direct any service providers to delete your PI from their records. Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your personal information from our records.
The Company is not required to comply with your request to delete your PI if it is necessary for it (or its service provider) to maintain your PI in order to:
- Complete the transaction for which the PI 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 the Company 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.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Company’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company.
- Comply with a legal obligation.
- Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.
Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
- Request to Know. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding our receipt of your verifiable consumer request:
- The categories of PI we have collected about you.
- The categories of sources from which the PI was collected.
- The business or commercial purpose for collecting PI.
- The categories of PI we disclosed for a business purpose.
- The categories of third parties with whom we share PI.
- The specific pieces of PI we collected about you.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
In addition to the CCPA, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Company to third parties for the third parties’ direct marketing purposes. Consumers who have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such request must be submitted to us by calling 888-444-4203 or emailing us at firstname.lastname@example.org Please mention in your call or email that you are making a "California Shine the Light" inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
- Nondiscrimination. We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.
Submitting Consumer Rights Requests. To submit any of the Consumer Rights requests as outlined above, please contact us at 888-444-4203 or email email@example.com We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer’s minor child, or
- a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
Upon our request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
If you have an account with us, we will deliver our written response to 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 receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to your rights under this CA Policy. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.