EFFECTIVE DATE OF CURRENT POLICY: OCTOBER 3, 2023
The terms “Pattern Brands”, “Pattern”, “us”, “we” or “our” refer to Pattern Brands, LLC, the owner of the Services. The terms “you” or “your” refer to the user or viewer of the Services.
Personal Information We Collect
For users of the Services, Personal Information may include the following:
- full name, login credentials, email address, physical address, and phone number;
- credit card and payment information; and
- interests, comments, requests, and other information you may offer.
We may also automatically collect other information as you interact with the Services. We collect data relating to the use of our Site, traffic logs, user conduct, or the results of Site usage. We may collect and maintain data about your usage of the Site and/or Services, your Internet Protocol (“IP”) address, Site and/or Services visits, page response times, download errors, length of visits to certain pages, and page interaction information (such as swipes, share lists, and recommendations). We also may automatically collect information from cookies that are placed throughout the Services. Generally, this information is collected in aggregate form, which means we cannot personally identify you through these mechanisms.
The above information may also be collected by third-party service providers, such as Shopify.
Which Collection Technologies We Use
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
How We Use Personal Information
We use Personal Information to facilitate the provision of your requested services, such as to fulfill orders. We also use Personal Information to track user behavior, improve our products and services, communicate with you regarding the Services, and generate statistics and trend data for internal and external business purposes, such as marketing campaigns and social media advertising. We also will use Personal Information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
Why We Share Personal Information
We do not share your information for commercial purposes.
We may share your information in the following ways:
- With service providers: We may share your information with third parties that perform tasks on our behalf and that help us better provide our Services to you.
- To protect us, our users, or to law enforcement officials: We may share your information to comply with legal processes (including to comply with the law, to enforce our Terms of Service, or to respond to subpoenas, discovery requests, or similar legal processes or proceedings), cooperate with law enforcement or when we believe it is prudent to share information with legal authorities, and investigate and prevent fraud or imminent harm to you, our users, or to us. We may also share your information to ensure the security of our network and services.
- In the event of a business transfer: We may share your information with another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy or we go out of business. User information is generally considered an asset that is transferred in one of these types of corporate transactions.
- With your consent: We may also share your information in other circumstances when we have obtained your consent.
Personal Information Shared with Third Parties
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics and Mixpanel, Inc. to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/ and how Mixpanel uses your Personal Information here: https://mixpanel.com/legal/privacy-policy.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Furthermore, we partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our Site through behavioral metrics, heatmaps, and session replay to improve and market our Services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of our Services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement found here: https://privacy.microsoft.com/en-US/privacystatement.
As described, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Consent to Data Processing in the United States
Personal Information is retained for an appropriate period of time depending on the purposes of processing your Personal Information and we will securely destroy your Personal Information once there is no longer a need to keep it, in accordance with applicable laws and regulations, unless and until you ask us to delete this information.
EU and UK Data Subject Rights
You can exercise the following rights by contacting Pattern Brands at firstname.lastname@example.org: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification and correction; (iv) the right to erasure; (v) the right to restrict processing and sharing; and (vi) the right to object.
Before processing the request, we may need to ensure the identity of the person making the request to avoid sharing data with an unauthorized person and may request additional information from you. As a European or United Kingdom Citizen, you have the right to file a complaint with a European Union supervisory authority, (or the Information Commissioner’s Office (ICO) if you are a resident of the United Kingdom), in the event you have reasonable doubt that we are not processing your Personal Information in compliance with applicable law and GDPR, or UK-GDPR. In such a case, we are asking you to contact us first by sending to email@example.com and we will make our best efforts to reply promptly.
If you would like to access, modify, or delete your personal information, you may submit a request to firstname.lastname@example.org For more information or to see if these rights apply to you, please contact us. We will promptly review all such requests in accordance with applicable laws.
If you are a California, Colorado, Connecticut, Nevada, Utah or Vermont resident, the law may provide you with additional rights regarding our use of your Personal Information. Please review our Supplemental Privacy Notice, attached hereto and made a part hereof as Exhibit A, to learn more about these rights.
Do Not Track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
The Site is not intended for individuals under the age of eighteen (18). Pattern Brands is highly sensitive to the privacy of children. Therefore, we will not knowingly collect Personal Information from children.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at email@example.com or by mail using the details provided below:
Pattern Brands, LLC
Attn: Privacy Compliance Officer
228 Park Ave S.
New York, NY 10003,
Updated as of: September 1, 2023
This US Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about consumers in the following states: (1) California, (2) Colorado, (3) Connecticut, (4) Nevada, (5) Utah, and (6) Virginia. This Supplemental Notice our practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests.
Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.
To the extent terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.
Supplemental Notice for California Residents.
This Supplemental Notice for California Residents applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”), effective as of January 1, 2023 (collectively, the “California Privacy Laws”). The California Privacy Laws provides California residents with the right to know what categories of Personal Information Pattern Brands has collected about them, the right to have Personal Information deleted, the right to opt out of the sale of Personal Information (if applicable), the right to opt in of the sale of Personal Information of consumers under the age of 16 (if applicable), the right to nondiscriminatory treatment for exercising any rights, the right to initiate a private cause of action for data breaches, the right to correct inaccurate Personal Information and the right to limit use and disclosure of sensitive Personal Information.
Disclosure for California Consumers:
Unless specifically stated, we have not sold or shared Personal Information about California consumers to third parties for their own use in the past twelve (12) months. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age. However, we may share your Personal Information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions. That said, we may share information with third-party advertising partners or analytics providers for the purpose of promoting our Services as described above, including for cross-context behavioral advertising. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your Personal Information shared with such advertising partners or analytics providers by emailing us here: firstname.lastname@example.org. For purposes of California law, a “sale” is the disclosure of Personal Information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Additional Privacy Rights for California Residents:
- Right to Access. If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period: (i) categories of Personal Information we have collected about you; (ii) categories of sources from which we collected the Personal Information; (iii) our business or commercial purpose for collecting Personal Information; (iv) categories of third parties with whom we share Personal Information; (v) categories of Personal Information we disclose about you for business purposes; (vi) categories of Personal Information we sell or exchange for consideration about you; and (vii) the specific pieces of Personal Information we have collected about you.
- Right to Delete. If you are a California consumer, you have the right to ask us to delete the Personal Information about you we have collected. We may deny the request if the information is necessary to: (i) complete a transaction, including providing a requested or reasonably anticipated good or service, or fulfill a contract between the consumer and Pattern ; (ii) detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity; (iii) debug to identify and repair errors impairing intended functionality; (iv) comply with the California Electronic Communications Privacy Act; (v) engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent; (vi) enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with Pattern; (vii) comply with a legal obligation; or (viii) otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information.
- Right to portability. A consumer has the right to request Personal Information about the consumer be disclosed in a common file format.
- Right to Opt-in or Opt-out of the sale of Personal Information. If a business sells Personal Information to third parties, California consumers have the right, at any time, to opt in or out of the sale or disclosure of their Personal Information to third parties.
- Right to designate an authorized agent. You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us. Right to non-discrimination. The CCPA grants California consumers the right not to be discriminated against for exercising your privacy rights. If you exercise your privacy rights, we will not discriminate against you, for example, by denying you access to our shop or charging you different rates or prices for the same Services, unless that difference is reasonably related to the value provided by your data.
California Privacy Rights Act. In addition to the rights provided by the CCPA, California residents are provided with the following rights through the California Privacy Rights Act: (i) the right to request that incorrect or outdated Personal Information be corrected but not deleted; (ii) the right to restrict a business’s ability to process sensitive data about the consumer; and (iii) prohibition against a business making decisions about a consumer based solely on an automated process without human input.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties.
Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your Personal Information to other entities for their own direct marketing purposes.
Supplemental Notice for Colorado Residents. The Colorado Privacy Act provides Colorado residents with the following rights: (i) the right to opt out of the processing of Personal Information concerning the consumer; (ii) the right to confirm whether a business is processing Personal Information concerning the consumer and to access the consumer's Personal Information; (iii) the right to correct inaccurate Personal Information collected from the consumer; (iv) the right to delete Personal Information concerning the consumer; (v) the right to restrict a business’s ability to process Personal Information about the consumer, specifically to opt-out of processing for profiling/targeted advertising purposes; (vi) a prohibition against a business making certain decisions about a consumer based solely on an automated process without human input; and (vii) the right to data portability. When exercising the right to access Personal Information, a consumer has the right to obtain the Personal Information in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hinderance. A consumer may exercise this right no more than two times per calendar year.
Supplemental Notice for Connecticut Residents. The Connecticut Data Privacy Act provides Connecticut residents with the following rights: (i) the right to confirm whether a business is processing Personal Information concerning the consumer and to access the consumer's Personal Information; (ii) the right to request that incorrect or outdated Personal Information be corrected but not deleted; (iii) the right to delete Personal Information concerning the consumer; (iv) the right to restrict a business’s ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (v) the right to request Personal Information about the consumer be disclosed in a common file format; (vi) the right to opt out of the sale of Personal Information about the consumer to third parties; and (vii) prohibition against a business making certain decisions about a consumer based solely on an automated process without human input.
Supplemental Notice for Nevada Residents. We generally do not disclose or share Personal Information for profit. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. To exercise this right, if applicable, you or your authorized representative may submit a request to email@example.com. If you have any questions, please contact us at firstname.lastname@example.org. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.
Supplemental Notice for Utah Residents. The Utah Consumer Privacy Act provides Utah residents with the following rights: (i) the right to confirm whether a business is processing Personal Information concerning the consumer and to access the consumer's Personal Information; (ii) the right to delete Personal Information concerning the consumer; (iii) the right to restrict a business’s ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (iv) the right to request Personal Information about the consumer be disclosed in a common file format; and (v) the right to request to opt out of the sale of Personal Information about the consumer to third parties.
Supplemental Notice for Virginia Residents. The Consumer Data Protection Act provides Virginia residents with the following rights: (i) the right to confirm whether or not a controller is processing the consumer's Personal Information and to access such Personal Information; (ii) the right to delete Personal Information provided by or obtained about the consumer; (iii) the right to obtain a copy of the consumer's Personal Information that the consumer previously provided to the business in a portable and, to the extent technically feasible, readily usable format; (iv) the right to opt out of the processing of the Personal Information for purposes of, targeted advertising, the sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer; and (v) the right to restrict a business’s ability to process Personal Information about the consumer, specifically to opt-out of processing for profiling/targeted advertising purposes.
Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers: Unless specifically stated, we do not sell or share Personal Information to third parties for their own use. However, we may share or process one or more of the above categories of Personal Information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CTDPA. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.
Changes to this Supplemental Notice: We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Supplemental Notice on our website and listing the effective date of such updates.