PRIVACY | The Ribbon

OUR PRIVACY POLICY
Last Updated: August 20, 2024

This Privacy Policy describes how The Ribbon collects, uses and shares personal information about you and the choices that are available to you with respect to our handling of your information. This Privacy Policy applies to personal information we collect when you interact with us online (e.g., through our website or other online products and services) or offline (e.g., when you shop in our stores or interact with customer support) or otherwise interact with us as described below. Our online and offline services and interactions with you are collectively referred to as "Services" in this Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. In some cases, we may provide you with additional notice (such as adding a statement to the homepages of our websites or sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our personal information practices and the choices available to you.

COLLECTION OF INFORMATION
Personal Information We Collect Directly from You
We collect personal information you provide directly to us. For example, we collect personal information when you use our website; sign up to receive our emails; participate in a sweepstakes, contest, promotion or survey; communicate with us via third-party social media sites; apply for and/or participate in our loyalty program; apply for a job; or otherwise communicate with us.
The types of personal information we may collect include your name, email address, zip or postal code, billing address, shipping address, phone number, payment card information, product preferences, demographic information and any other personal information you choose to provide.
In some cases, we may also collect personal information you provide about others, such as when you purchase a gift card for someone and request that we deliver it electronically, create and share a "wishlist" or decide to purchase and ship products to someone. We will use this personal information to fulfill your requests and will not send marketing communications to your contacts unless they separately opt in to receive communications from us.

Personal Information We Collect Automatically
We automatically collect certain personal information about you when you access or use our Services or dine with us, including:

Log and Usage Information: We collect information about your use of our online Services, such as the type of browser you use, access times, pages viewed, items placed in your cart, links clicked, browsing behavior, and the referring URL (the webpage you visited before navigating to our online Services).

Device Information:

We collect information about the device you use to access our online Services, including the hardware model, IP address, unique device identifiers and operating system and version.
Transaction Information:

When you purchase or return a product, we collect information about the transaction, such as product details and the date and location of the purchase/return.
Video Data:

We collect video data via security cameras we deploy in some of our retail stores.

Information Collected by Cookies and Similar Tracking Technologies:

We (and our service providers) use cookies, web beacons (also known as "tracking pixels") and similar tracking technologies to collect information about you when you interact with our online Services or emails, including information about your browsing and purchasing behavior. We may combine this information with other information we collect about you and use it for various purposes, such as improving our websites and your online experience, understanding which areas and features of our sites are popular, counting visits, understanding campaign effectiveness, tailoring our communications with you, determining whether an email has been opened and links within the email have been clicked and for other internal business purposes. For more information about cookies and how to disable them, please see the "Cookies" section below.

Personal Information We Collect from Our Partners and Other Sources:
We may obtain personal information about you from other sources and combine that with information we collect about you. For example, we collect personal information from the local postal services’ national change of address databases to verify and update mailing addresses. If you interact with us on social media, we will also collect personal information about you from those interactions.

Personal Information We Derive:
We may derive personal information or draw inferences about you based on the other types of personal information we collect. For example, we may infer your location based on your IP address, or that you are interested in making a reservation based on your browsing behavior on our Services.

USE OF PERSONAL INFORMATION
We may use personal information about you for various purposes, including to:

- Provide, maintain and improve our Services, including to facilitate and improve your in-store experiences;
- Deliver the products and Services you request, or that are reasonably anticipated within the context of our ongoing business relationship, complete transactions, perform our contractual obligations and send you related information, including confirmations and receipts;
- Process your orders, payments and account adjustments and initiate, render, bill and collect payment for our products and Services;
- Conduct internal research and development and make business decisions about current and future product and service offerings;
- Respond to your comments, questions and requests and provide customer service;
- Communicate with you about products, services, offers, promotions, rewards and events and provide news and information we think will be of interest to you;
- Manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages;
- Personalize your online experience and provide advertisements, content or features that match your profile and interests;
- Monitor and analyze trends, usage and activities;
- Process and deliver contest, promotion and sweepstakes entries and rewards;
- Detect, protect against and prevent security incidents and illegal or unauthorized activities, investigate complaints and claims and provide other security protections, such as identity verification;
- Protect users of our Services from fraudulent, malicious, deceptive, abusive or unlawful activities of others;
- Debug and repair errors in our products and Services and other activities to maintain and improve the quality and safety of our products and Services;
- Cooperate with law enforcement and protect the rights (including free speech), interests, safety or property of Bacall's or our customers, service providers and other third parties;
- Comply with and enforce applicable legal and regulatory obligations and respond to governmental requests;
- Enforce our policies, terms and conditions or other agreements;
- Defend against or pursue claims, disputes or litigation – in court or elsewhere;
- Provide you the benefits of our loyalty program if you are a member of our loyalty program; and
- Carry out any other purpose readily apparent to you or described to you at the time the personal information is collected.

SHARING OF PERSONAL INFORMATION
We may share personal information about you as follows:

- With vendors, consultants, contractors and other service providers who access personal information to carry out work on our behalf and improve the products and services they provide to us (e.g., companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, analytics, marketing and advertising);
- In response to a request for personal information if we believe disclosure is in accordance with any applicable law, regulation or legal process or as otherwise required by any applicable law, rule or regulation;
- If we believe your actions are inconsistent with our user agreements or policies or to protect the rights, property and safety of us or any third party;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company;
- With our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
- With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
- By publicly posting, at our discretion, your product review or other user content if you provide one; and
- With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

ADVERTISING & ANALYTICS
We engage third parties to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect personal information about your use of our websites, such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This personal information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our websites and other websites and better understand your online activity. For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.networkadvertising.org and http://www.aboutads.info/choices. European users may opt of receiving targeted advertising by visiting http://www.youronlinechoices.eu/. Please note that you need to renew this choice on each device and browser you use to access our Services.

We may also work with third parties (such as Facebook and Instagram) to serve ads to you as part of a customized campaign on their platforms. If you prefer not to see customized ads from us, you can usually opt out by changing your account settings or preferences on such platforms.

DATA RETENTION
Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as is necessary for the processing purpose(s) for which the personal information was collected and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired.

CHILDREN
We do not, in providing the Services, knowingly collect personal information from children. If you have reason to believe that a child has provided personal information to us via the Services, please contact us, and we will endeavor to delete that personal information from our databases.

YOUR CHOICES

Cookies:
Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites. For more information, please see the cookie policy.

Data Transfers:

The Ribbon is headquartered in the United States and we process and store the information we collect from you, regardless of your location, in the U.S.. If you are based outside the U.S., we transfer your personal information to, and process your personal information on, servers located in the U.S., a jurisdiction that may not provide equivalent levels of data protection as your home jurisdiction. Such transfers and processing of your personal information are necessary to provide our Services.

We provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing Standard Contractual Clauses.

Legal Basis for Processing
We process your personal information described above:

- As necessary to fulfill our responsibilities under our contract with you (e.g., processing payments for and providing the products you have ordered);
- As necessary for our legitimate interests, including our interest in providing relevant and secure Services and improving our Services and products;
- As necessary to comply with our legal obligations; or
- As consistent with your consent, which you may revoke at any time.

Exercising Your Rights:
You have the right to access personal information we hold about you and to ask that your personal information be corrected or erased and to port your personal information. You may also have the right to object to, or request that we restrict, certain processing or to withdraw consent you have previously provided. If you would like to exercise any of these rights, you may contact us at info@bacalls.com.

Questions or Complaints:
If you have a concern about our processing of your personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/

CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS
Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or "CCPA" (California Civil Code Section 1798.100 et seq). If you are a California resident, this section applies to you.

Collection and Use of Personal Information: In the preceding 12 months, we have collected the following categories of personal information: identifiers, information subject to Cal. Civ. Code § 1798.80(e), characteristics of protected classifications under California or U.S. law, commercial information, Internet or other electronic network activity information, geolocation data, professional or employment-related information, audio, electronic, visual or similar information, inferences drawn about you and other categories of personal information that relate to, describe or are reasonably capable of being associated with you.

For examples of the precise data points we collect and the sources from which we collect this personal information, please see “Collection of Information” above. We collect personal information for the business and commercial purposes described in “Use of Information” above.

Disclosure of Personal Information: We may share your personal information with third parties as described in the “Sharing of Information” section above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients:

CATEGORIES OF THIRD PARTIES

CATEGORIES OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS OR COMMERCIAL PURPOSE
Vendors, consultants and other service providers who perform services on our behalf
Identifiers
Information subject to Cal. Civ. Code § 1798.80
Commercial information
Internet or other electronic network activity information
Geolocation data
Inferences
Identifiers
Information subject to Cal. Civ. Code § 1798.80
Commercial information
Geolocation data
Identifiers
Information subject to Cal. Civ. Code § 1798.80
Characteristics of protected classifications under California or federal law

Sale of Personal Information:

California law requires that we provide transparency about personal information we "sell," which for the purposes of the CCPA broadly means scenarios in which we have shared personal information with partners in exchange for valuable consideration. While we do not provide personal information about you to other companies for money, we do allow our advertising partners to collect identifiers, commercial information and Internet or other electronic network activity information via our Services to show you ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the “Advertising and Analytics” section above. You can also click the link "Do Not Sell My Personal Information" at the bottom of this page to make an opt-out request.

Your Rights:

Subject to certain limitations, you have the right to request (1) more information about the categories and specific pieces of personal information we have collected, used, sold and disclosed about you, (2) deletion of your personal information, and (3) that we stop selling your personal information. We will not discriminate against you if you exercise your rights under the CCPA.

Once we receive your request, we will verify it by asking you to provide certain information, such as identifiers like your email address and phone number. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf.

Notice of Financial Incentives:

We offer various financial incentives. For example, we may provide discounts, coupons and other benefits for customers who sign up to receive our marketing emails or join our loyalty program. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). You can opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt-out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by contacting us. In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.