Effective Date: November 1, 2022
Information collected through the Services is controlled by DFWS, which is headquartered in the United States. Our mailing address is 201 Tresser Blvd., Suite 500, Stamford, CT 06901-3435.
- The Information We Collect
- How We Use Your Information
- How We Share and Disclose Your Information
- Cookies and Similar Technologies
- Online Analytics and Advertising
- Retention of Your Information
- Third-Party Links and Features
- Your Rights & Choices Regarding Your Information
- Additional Information for Residents of Certain Jurisdictions
- Children’s Privacy
- How We Protect Your Information
- Contact Information
1. THE INFORMATION WE COLLECT
We obtain a variety of information from and about you as you use the Services. Please note that we need certain types of information so that we can provide certain Services to you. If you do not provide us with certain information, or ask us to delete it, you may no longer be able to access or use our Services. For example, if you are a customer but do not provide us with your billing information, we won’t be able to fulfill your orders.
Information You Provide to Us
We collect information directly from you through your use of our Services. For example, we collect information from you through:
- Your account registration and administering your account
- Processing and fulfilling your orders
- Your communications and dealings with us (including on our website and interactive chat function, mobile app, on third-party social media sites, and by mail or email)
- Your participation in sweepstakes, contests, promotions, surveys, or research
- Your reviews, comments, and other posts to our Services
- Your requests for customer support and technical assistance
We will collect any information that you choose to provide to us. The information we collect generally includes:
- Contact, registration, and eligibility information: your name, email address, login information (password and username or email), address, phone number, online screen name, and date of birth.
- Transactional information: billing and payment information, as well as details about your orders
- Inquiries and Feedback: comments and questions you submit through customer service interactions with us or surveys.
- User Generated Content: certain parts of the Services may enable or integrate with others that enable us to receive posts such as reviews, ratings, photos, or other content, that, depending on where you post them, may be publicly viewable.
Information We Collect Through Automated Means
- Device information and related identifiers: When you use our websites and mobile apps, we and our service providers collect and analyze information such as your IP address, browser characteristics, device IDs and characteristics, platform type, advertising identifiers, operating system, and the state or country from which you accessed the Services.
- Usage information: When you use our websites and mobile apps, we and our service providers collect and analyze information about your usage activity such as referring and exit pages and URLs, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services and upload or post content, error logs, language preferences, and other similar information.
We and our service providers also may collect and combine diagnostic and usage information collected on our Services with other information about your online activities over time, including use of other devices, websites, or apps, if such services also use the same vendors.
- Location Information: When you use the Services, we and our service providers collect general location information from your computer or mobile device. “General” location information means information about the city and state in which your device is located based on its IP address. We may also obtain general location when you input your zip code or use location features on the Services to find nearby merchants. This information allows us to give you access to content that varies based on your general location. If we collect precise GPS location information through your device, we will ask your permission first. You can disable geo-location tracking on your device.
Information We Collect from Social Media Platforms
When you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.
Information We Collect from Others
We may also receive additional information, such as demographic and statistical information, from third parties, such as marketers, consumer data resellers, researchers, and analysts.
2. HOW WE USE YOUR INFORMATION
We and our service providers use the information described above to accomplish the following business and operational purposes:
- Administer your account, including to process your registration and verify your information;
- Provide, manage, and improve the Services, including fulfilling your orders;
- Provide you with updates and information about your orders or purchases;
- Respond to your requests for information and provide you with more effective and efficient customer service, including through our interactive chat functions;
- Conduct internal business operations in support of our Services, such as auditing, security, resolving crashes, preventing fraud, invoicing and accounting, sales and marketing, analytics, and research and development;
- Contact you regarding our products, services, surveys, promotions, special events, and other subjects that we think may be of interest to you;
- Customize content, preferences, and advertising on or for the Services;
- Comply with laws, regulations, and other legal process and procedures;
- Establish, exercise, or defend our legal rights; and
- Take steps that we reasonably believe to be necessary to protect the safety, security, and rights of DFWS, its employees, service providers, and others.
We may also aggregate, de-identify, and/or anonymize any information collected through the Services in such a way that we cannot reasonably link information to you or your device. We may use such aggregate, de-identified, or anonymous information for any purpose, including without limitation for research and marketing purposes.
3. HOW WE SHARE AND DISCLOSE YOUR INFORMATION
We and our service providers will share the information we collect from and about you for the following business and operational purposes:
- Service Providers: We may provide access to or share your information with select third parties who perform services on our behalf, such as sales, marketing, product content and features, advertising, analytics, research, customer service, delivery, data storage, security, fraud prevention, payment processing and order fulfillment and legal services.
- Business Transfers: We may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
- Your Consent: If you have consented to our sharing of your information, we will also share your information consistent with your consent.
We may share or disclose such aggregate or anonymous information with any third party, including advertisers, promotional partners, and sponsors.
4. COOKIES AND SIMILAR TECHNOLOGIES
To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use web server logs, cookies, tags, tracking pixels, and other similar tracking technologies (“Cookies”).
- A web server log is a file where website activity is stored.
- A cookie is a small text file that is placed on your computer or mobile device when you visit a website, and it enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
- Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or email that are designed to: (i) collect usage information like ad impressions or clicks and email open rates; (ii) measure popularity of the Services and associated advertising; and (iii) access user cookies.
Cookies are typically classified as either “session cookies,” which do not stay on your device after you close your browser or “persistent cookies,” which will usually remain on your device until you delete them or they expire. Sometimes cookies are placed by us (“First-Party Cookies”) and sometimes they are placed by others (“Third-Party Cookies”). Different cookies are used to perform different functions on our Services:
- Essential Cookies: Some cookies are essential to the Services and enable you to use the features of the Services and access secure areas of the Services. Without these cookies, we cannot enable appropriate content based on the type of device you are using (for example, essential cookies store user log-in information so that you don’t have to re-enter it for each page you visit on our website).
- Functional Cookies: These cookies allow us to remember choices you make on our Services (such as your preferred language or the region you are in).
- Analytics Cookies: We use our own cookies and/or third-party cookies to see how you use our Services in order to enhance their performance and develop them according to the preferences of our customers and visitors. For example, cookies may be used to: maintain a consistent look and feel across our Services, track and provide trend analysis on how our users interact with our Services, track errors, and measure the effectiveness of our content.
- Advertising Cookies: These cookies record your visit to our Services, the pages you have visited, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a website. We or our service providers may use this information to make advertisements more relevant to you.
There are a number of ways you can manage what cookies are set on your devices. If you do not allow certain cookies to be installed, the Services may not be accessible to you and/or the performance or features of the Services may be compromised. See Online Analytics and Advertising for more information.
5. ONLINE ANALYTICS AND ADVERTISING
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain analytics tools, such as tracking pixels, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The Services may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google Display Network, Criteo, and others) to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you to assist in the delivery of relevant advertising about the Services on other websites you visit and other services you use.
Notice Concerning Do Not Track.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, which is why we describe a variety of opt-out mechanisms above. However, we do not currently recognize or respond to browser-initiated DNT signals. Learn more about Do Not Track.
6. RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
7. THIRD-PARTY LINKS AND FEATURES
8. YOUR RIGHTS & CHOICES REGARDING YOUR INFORMATION
If we send you marketing communications in your jurisdiction (based on our relationship with you, your consent, or applicable law), you may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below.
Your local laws (such as those in the European Union, California, or Nevada) may permit you to exercise certain rights with respect to the information we collect from and about you. Please see Additional Information for Residents of Certain Jurisdictions for more information.
9. ADDITIONAL INFORMATION FOR RESIDENTS OF CERTAIN JURISDICTIONS
Your local laws may entitle you to additional information or permit you to exercise certain rights with respect to the information we collect from and about you. Please note that your rights vary depending upon your location, and that we may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you or to comply with a legal obligation. In some circumstances, if you still ask us to delete your information, you may no longer be able to access or use our Services.
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
We use the above categories of information that we collect from you and from marketers, social media companies, researchers, consumer data resellers, and analytics partners in order to provide and manage the Services you request; to contact you; to analyze the use of our Services; to market our Services to you; for bug detection and error reporting; to audit consumer interactions on the Services; to protect the rights of the Services; for legal compliance; and with your consent. For more detail regarding the purposes for which we use information, please see How We Use Information for more information.
Sharing in the Last Twelve (12) Months
For a Business Purpose. In the preceding twelve (12) months, DFWS has disclosed the following categories of personal information for a business purpose to the following categories of third parties:
- We have disclosed your personal identifiers, internet and other network activity information, payment card or financial account information, and commercial information to service providers that perform services on our behalf. These service providers include our data hosting service provider, marketing service providers, data analytics service providers, customer service providers, importers and distributors, shipping service providers, website development service providers, and payment processors.
- We have disclosed your internet or other electronic network information to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair website errors that impair functionality.
- We have disclosed your internet or other electronic network information and location information to our IT support and data analytics providers to maintain, improve, and upgrade DFWS Services.
For a Sale.
- DFWS shares your identifiers, inferences drawn from your commercial information and internet or other electronic network activity information, commercial information, and internet or other electronic network activity information with its third party partners, sponsors, and advertisers (including social media platforms) to offer you products and services that may be of interest to you (which may be co-branded or jointly offered by a partner). This use of your personal information may be considered a sale under the California Consumer Privacy Act. To opt out of this sharing, follow the instruction in the “California Privacy Rights” section below or visit Do Not Sell My Personal Information.
California Privacy Rights
To the extent that the CCPA applies to our processing of your personal information, you would be entitled to the following rights:
• Right to Access. You have the right to request what personal information we have collected, used, disclosed, and sold about you within the preceding twelve (12) months. You may only submit a request for access twice within a twelve-month period.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.
• Right to Opt Out. You have the right to opt out of the sale of your personal information to third parties. DFWS does not have actual knowledge that it sells personal information of minors under the age of sixteen (16) years.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt out under the CCPA.
To exercise your right to access or delete your personal information, you may submit a request via email at IT.Web@deutschfamily.com. To opt out of the sale of your personal information, please visit Do Not Sell My Personal Information.
For requests submitted via email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. The interactive webform contains the information that we need to verify your identity and review your request.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
European Union Economic Area
Legal Bases for Use of Your Information
Some countries require that companies only process your “Personal Data” (as that term is defined in the applicable law like the EU General Data Protection Regulation) if they have a “legal basis” (or justifiable need) for processing your Personal Data. To the extent those laws apply, our legal bases for processing Personal Data are as follows:
- Where your Personal Data is necessary to perform our obligations pursuant to a contract (or pending contract) with you. For example, we will process your Personal Data to comply with our Terms of Service to enter into a contract with you, and to honor our commitments in any contracts that we have with you.
- Where your Personal Data is necessary for our legitimate interests or the legitimate interests of others. For example, we will process your Personal Data: to operate our business and our Services; identify and fix any issues with our Services; provide security for our Services; learn more about how our customers use the Services; perform internal analytics concerning the Services; improve the Services and users’ experiences with the Services; provide you with information about new products, special offers or other information that we think you may find interesting using the email address which you have provided; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud; and to know the customer to whom we are providing Services.
- Where use of your Personal Data is necessary for us to comply with our legal obligations.
- Where we have your consent. For example, where a country requires that we obtain your consent before we process certain data, we will seek your consent in accordance with those countries’ requirements.
If you are a citizen of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you may request that we:
- provide access to and/or a copy of certain information we hold about you
- delete certain information that we are holding about you
- prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
- update or rectify information that is out of date or incorrect
- oppose, cancel, or restrict the way that we process and disclose certain of your information
- transfer your information to a third-party provider of services
- revoke your consent for the processing of your information
Please note that, in providing services to you, we may subcontract the processing of your data to, or otherwise share your data with, DFWS affiliates and subsidiaries, trusted service providers, and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions, and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage, or use.
If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
Nevada Resident Privacy Rights
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” (as such terms are defined by Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity.
10. CHILDREN’S PRIVACY
The Services are intended for adults only. We do not knowingly solicit any information from children or people under the legal drinking age, nor do we knowingly market or otherwise target our websites or its products or services to children or people under the legal drinking age.
If we become aware that a visitor to our websites is under the legal drinking age in the relevant jurisdiction and has registered with the Services, we will remove his or her personal data from our files. We also comply with other age restrictions and requirements in accordance with applicable local laws.
11. HOW WE PROTECT YOUR INFORMATION
We take measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services and that any such transmission is at your own risk. You are responsible for keeping your account information—and especially your login information—confidential. We ask you not to share your login credentials with anyone.
13. CONTACT INFORMATION