PRIVACY POLICY AND COOKIE POLICY

Last Updated 11/24/2020

This privacy policy describes how New Occasion Brands LLC (collectively, “we”, “us” or “our”) collects, generates or processes personal data when you, a user (“User” or “you”), use our websites and online services (“Sites”) and mobile applications (“Apps”) (collectively referred to as “Services”). It also explains how your personal data is used, shared, and protected, what choices you have relating to your personal data and how you can contact us. By using our Services, you are accepting the practices described in this policy. If you do not agree to the terms of this Policy, please do not use our Services.

WHAT PERSONAL DATA DO WE COLLECT AND WHEN?

When you use our Services, we collect certain personal data to provide you with the products or services you request. This personal data includes:

Information that you provide

We collect any information that you enter through our Services or give us in any way. For example, when you create an account, place an order, request to receive communications, participate in our events or contests, contact our consumer services, or use our Services in any other way. Such information includes, but is not limited to the following:

contact details including name, email, telephone number and shipping and billing address;
login and account information, including screen name, password and unique user ID;
personal details including gender, hometown, date of birth and purchase history;
payment or credit card information;
personal preferences including your favorites/wish list as well as marketing and cookie preferences;
and information you give us through your calls with our customer service.

We collect additional personal data from you to enable particular features within our Services. We may provide you the option to connect your Site account to your account on some social networking sites, such as Facebook, Instagram, Pinterest, Twitter, or Snapchat, for the purpose of logging in, uploading information or enabling certain features on the Site or App. This personal data includes:

log-in credentials, username, age and gender;
profile picture, cover photo, friend networks, locale, and any other information you have made public.

Automatic Information

When interacting with our Services, certain data is automatically collected from your device or web browser. More information about these practices is included in the “Cookies and Pixel Tags” section of this privacy policy below. This data includes:

device IDs, call state, date/time of access, network access, storage information and battery information; and
cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags.

Mobile Device

When you download or use our Apps, we may receive data about your location and your mobile device, including the hardware model, operating system and version, and unique device identifiers.

CHILDREN ONLINE PRIVACY PROTECTION ACT (COPPA)

We do not knowingly collect or solicit personal data from children under the age of 13 (“Children” or “Child”). If you are a parent or guardian and you are aware that your Child has provided us with personal data, please contact us by using the contact details in the “Question and Feedback” section below. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

TOOLS TO MANAGE WHAT PERSONAL DATA WE COLLECT

When using our Services, we also provide in-time notice or obtain consent for certain practices. For example, we will obtain consent to use your location or send push notifications. We may obtain this consent through the Services or using the standard permissions available on your device.

In many cases, your web browser or mobile device platform will provide additional tools to allow you to control when your device collects or shares particular categories of personal data. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarize yourself with and use the tools available on your devices.

WHY AND HOW DO WE USE YOUR PERSONAL DATA?

We use your personal data in the following ways:

To Provide the Features of the Sites, Apps, and Services You Request

When you use our Services, we will use your personal data to provide the requested product or service. For example, if you make a purchase through our Services or participate in an event or promotion, we will use the contact information you give us to communicate with you about the purchase, event or promotion. If you contact our consumer services, we will use information about you, such as delivery or payment information, or the product you have purchased to help you resolve a problem or question.

In some cases, to use particular features within our Services, you may need to provide us with additional data or additional consent to use particular data in a certain way. For example, to share content on social media, you may be required to provide your social media account credentials to sign in.

To Communicate Information about our Products, Services, Events and for Other Promotional Purposes

When you consent, we will send you marketing communications and news concerning our products, services, events and other promotions. You can opt-out at any time after you have given your consent.

If you are an existing customer of ours (for example, if you have placed an order with us), we may use the contact details you provided to send you marketing communications about similar products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us as well as information from our other products or services (such as your use of our Services, your visits to or purchases made in our stores, your participation in our events and contests) to personalize communications on products and services that may be interesting for you.

To Operate, Improve and Maintain our Business, Products and Services

We use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits and other internal functions. We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Services. We may also record your calls with our customer service to handle your inquiry and for training, research and product development purposes.

To Protect Our or Others' Rights, Property or Safety

We may also use your personal data about how you use our Services to prevent or detect fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests or applicable law.

For General Research and Analysis Purposes

We use data about how our visitors use our Services to understand customer behavior or preferences. For example, we may use information about how visitors to our Sites search for and find products to better understand the best ways to organize and present product offerings in our storefront.

Other Purposes

We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

Legal Grounds

To process your personal data, we rely on certain legal grounds, depending on how you interact with our Services.

When you purchase products from our Services, we need your personal data to fulfill our contract with you. For example, we need your payment and contact details to deliver your order.
When you use our Apps, we rely on your consent for processing and for certain limited purposes to fulfill our contract with you (for example, for in-App purchases).
We also rely on other legal grounds, such as our legitimate interests as a business, to comply with a legal obligation, or to protect your vital interests.

Legal Ground for Processing Personal Data Under The General Data Protection Regulation (“GDPR”)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect it.

We may process your personal data because:

We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
For payment processing purposes
To comply with the law

SHARING OF YOUR PERSONAL DATA

From time to time we establish business relationships with other persons or entities whom we believe trustworthy and your personal data is sometimes shared with:

Third party service providers process personal data on our behalf, for example to process credit cards and payments, shipping and deliveries, host, manage and service our data, distribute emails, send mailers, research and analysis, manage brand and product promotions as well as administering certain services and features. We may share your information when we team up with another company to offer or provide products, services, contests, or promotions to our customers. When using third party service providers we enter into agreements that require them to implement appropriate technical and organizational measures to protect your personal data.
Other third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law; (ii) prevent illegal uses of our Services or violations of our Sites' and the Apps' Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).
To any other third party where you have provided your consent.

We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA

Encryption & Security

We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data.

International Transfers of your Personal Data

The personal data we collect (or process) in the context of our Services will be stored in the USA and other countries. Some of the data recipients with whom we share your personal data may be located in countries other than the country in which your personal data originally was collected. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, including the USA, we will protect that personal data as described in this privacy policy and in compliance with applicable law. If you are a resident of the European Economic Area (“EEA”), please see the ”Note to EEA Residents” section below.

Retention of your Personal Data

Your personal information will be retained for as long as is necessary to carry out the purposes set out in this privacy policy (unless a longer retention period is required by applicable law). In general, this means that we will keep your personal data for as long as you keep your account with us. For personal data related to product purchases, we retain this longer to comply with legal obligations (such as tax and sales laws and for warranty purposes).

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

You have the right to request: (i) access to your personal data; (ii) an electronic copy of your personal data (portability); (iii) correction of your personal data if it is incomplete or inaccurate; or (iv) deletion or restriction of your personal data in certain circumstances provided by applicable law. These rights are not absolute. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.

The Controlling the Assault of Non-Solicited Pornography And Marketing Act (“CAN-SPAM Act”)

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have commercial emails stopped from being sent to them, and spells out penalties for violations.

We may collect your email address in order to:

Send information, respond to inquiries, and/or other requests or questions.
Process orders and to send information and updates pertaining to orders.
Send you additional information related to your product and/or service.
Market to our mailing list or continue to send emails to our customers after the original transaction has occurred.

To be in accordance with CAN-SPAM, we agree to the following:

Not to use false or misleading subjects or email addresses.
To identify the message as an advertisement in some reasonable way.
To include the physical address of our business or site headquarters.
We monitor third-party email marketing services for compliance, if one is used.
We honor opt-out/unsubscribe requests quickly.

Opting Out of Direct Marketing

You may at any time unsubscribe or opt-out from receiving our marketing communications by:

Following the instructions at the bottom of one of your emails from us and we will promptly remove you from the email list.
Contact us by using the contact details in the “Question and Feedback” section below.

We reserve the right to send you transactional or relationship based emails or notices even if you opt out of all voluntary emails. This includes information about your account, such as information regarding delivery of goods and services you have already agreed to and ordered, service announcements and administrative messages, information about warranty, recall, safety or security information, or notices about changes in terms or features of the Services.

Note to EEA Residents

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us using the contact details in the “Question and Feedback” section below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

THIRD PARTIES

Linked Sites

Our Services may provide links to other (third-party) websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.

Advertising and Analytics Services Provided by Others

We allow other companies to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information is 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 Services and other websites and online services and better understand your online activity. Please see our “Cookies and Pixel Tags” section below for more details on how you may be able to opt out of receiving interest-based ads via our Services.

COOKIES AND PIXEL TAGS

This section explains more about how we use cookies and your choices concerning cookies.

What Are Cookies?

Like most websites, we use cookies and similar technologies to remember things about you so that we can provide you with a better experience.

Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). For example, we partner with third-party analytics providers, like Google, which set cookies when you visit our websites. This helps us understand how you are using our Services so that we can improve them.
Pixels are small images on a web page or in an email. Pixels collect information about your browser or device and can set cookies.
Local storage allows data to be stored locally on your browser or device and includes HTML5 local storage and browser cache.

How We Use Cookies

We use cookies for a number of reasons, like helping us see which features are most popular, counting visitors to a page, improving our users' experience, keeping our services secure, and generally providing you with a better experience. The cookies we use generally fall into one of the following categories.

Category of cookies	Why we use these cookies
Technical	These cookies are essential for our Services to function properly. Like the other cookies we use, technical cookies may be either first-party cookies or third-party cookies.
Preferences	We use these cookies to remember your settings and preferences.
Security	We use these cookies to help identify and prevent security risks.
Performance	We use these cookies to collect information about how you interact with our Services and to help us improve them. For example, we may use these cookies to determine if you have interacted with a certain page.
Analytics	We use these cookies to help us understand and improve our Services. For example, we can use these cookies to learn more about which features are the most popular with our users and where we may need to make improvements.
Advertising	We and our advertising partners use these cookies to deliver advertisements, to make advertisements more relevant and meaningful to visitors to our website, and to track the efficiency of our advertising campaigns, both on our Services and on other websites.

Your Choices

You have a number of options to control or limit how we and our partners use cookies and similar technologies, including for advertising.

Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies. If you disable cookies, however, some of the features of our services may not function properly.
To prevent your data from being used by Google Analytics, you can install Google's opt-out browser add-on.
For information on how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit http://optout.aboutads.info/. European users may opt out of receiving targeted advertising through the European Interactive Digital Advertising Alliance.

Contact Us

If you have any questions about our use of cookies, please contact us by any means in our “Questions and Feedback” section below.

YOUR CALIFORNIA PRIVACY RIGHTS

California Consumer Privacy Act

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.” The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning.

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the “What Personal Data Do We Collect And When?” section above. We collect this information for the business and commercial purposes described in the “Why And How Do We Use Your Personal Data?” section above. We share this information with the categories of third parties described in the “Sharing Of Your Personal Data” section above. We do not sell the personal information we collect and will not sell it without providing a right to opt out. Please note that we do use third-party cookies for our advertising purposes as further described in the “Cookies And Pixel Tags” section above.

Subject to certain limitations, the CCPA provides California consumers the right to request (a) more information about the categories and specific pieces of personal information we have collected and how we use and disclose this information, (b) deletion of their personal information, and (c) to opt out of any “sales” that may be occurring. We will not discriminate against you if you exercise your rights under the CCPA.

California consumers may make a request pursuant to their rights under the CCPA by contacting us by any means in our “Questions and Feedback” section below. To help protect your privacy and maintain security, we take steps to verify your identity before granting access to information or complying with a request. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent's permission to do so and verify your identity directly.

California Online Privacy Protection Act (“CalOPPA”)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting personal information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared.

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.
We will include a link to this privacy policy on our home page or as a minimum, on the first significant page after entering our website.
Our privacy policy link includes the word 'Privacy' and can easily be found on the page specified above.
You will be notified of any privacy policy changes through an adjustment made on our privacy policy page.

You can change or update your personal information by any of the means described in our “Questions and Feedback” section below.

“Do Not Track” Signals Under CalOPPA

Our Site does not support “Do Not Track” browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

CHANGES TO OUR PRIVACY POLICY

Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Services. If we materially change the way in which we process your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our privacy policy and keep yourself informed of our practices. This privacy policy was last modified on January 30, 2020.

QUESTIONS AND FEEDBACK

We welcome questions, comments, and concerns about our privacy policy and privacy practices.

Contact

If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal data, you may contact us:

By Email: support@occasionbrands.com
By Phone: (302) 279-1052

If you contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner. You also have the right to lodge a complaint with the relevant supervisory authority in the country in which you reside.

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