Last Updated: January 1, 2020
Silver Star Brands, Inc. (“Company,” “we,” “us,” or “our”), and its service providers may collect or receive the types of information described below in connection with your access to and use of the Site (together, “Collected Information”).
Categories of Personal Information We Collect
We may collect the following categories of Personal Information, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information” or “Personal Data“):
- Identifiers: Identifiers such as: a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, or other similar identifiers.
- Customer Records: Any of the following types of information: bank account number, credit card number, debit card number, signature, telephone number, and any other financial information.
- Commercial Information: Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet Activity. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation Data. Information which can be used to identify your location.
- Inferences. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
This Policy does not apply to any Personal Information that is publicly available.
Categories of Sources of Personal Information We Collect and How We Collect It
We may collect all categories of Personal Information listed above from the following categories of sources:
- Information that you voluntarily provide to us, for example, your contact information, payment information, and product reviews.
- Information that we collect through your use of the Site, for example, account activity, data collected by the servers used to operate the Site (e.g., IP addresses), data collected by cookies, and data collected by analytics and advertising services.
Information That You Voluntarily Provide to Us
Account Information. To create an online Company account, you will need to submit your name and email address and you may be required to select and answer security questions.
Rewards Program. To participate in our rewards program you will need to meet any applicable eligibility criteria that apply and you will need to submit your name, physical address, email address, and telephone number.
Information We Collect When You Opt In to Marketing Communications. If you sign up or otherwise opt in to receive promotions or other communications from us, you will need to submit your email address. You may also provide your physical address. We will use this information to provide you with promotional and other electronic and hard copy communications (e.g., catalogs). You may opt out of receiving promotional emails from us at any time by following the unsubscribe instructions contained in the applicable email and you may opt out of receiving hard copy mailings from us by contacting us using the contact information provided below under “Contact Us.”. We may use third-party email providers to deliver these communications to you.
User-Generated Content. You are responsible for any comments, data, text, images, video, audio, and other content (e.g., product reviews) that you create, post, transmit, upload, distribute, submit, or otherwise provide using the Site (together, “User-Generated Content”). User-Generated Content you provide is posted on the Site at your own risk. We cannot guarantee that User-Generated Content will not be viewed by unauthorized persons. You understand that any User-Generated Content you provide will be publicly available via the Site. You understand that, even after removal, copies of User-Generated Content that you have provided may remain viewable in cached and archived pages and may have been copied or stored by Internet archives and other Site users.
Categories of Information that We Collect Through Your Use of the Site
IP Addresses, Location Data, and Related Data. When you visit or use the Site, we may automatically collect certain information from your device. Under certain applicable laws, including countries in the European Economic Area (“EEA”) and in the State of California, this information may be considered Personal Information or Personal Data under applicable data protection laws. Specifically, the servers used to operate and provide the Site may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Site, including Internet protocol (“IP”) addresses assigned to the computers and other devices from where you access the Internet, your Internet service provider (ISP), your device ID number, your approximate geographic location, your browser type, the pages you access on the Site, the websites you access before and after visiting the Site, the length of time you spend on the Site, date and time stamps, and clickstream data. Company may use this information to administer the Site and its servers, to generate statistical information, to monitor and analyze Site traffic and usage patterns, to serve personalized advertising, to monitor and prevent fraud, to investigate complaints and violations of our policies, and to improve the Site’s content and the products, services, materials, and other content that we describe or make available through the Site. We may combine this information with other Personal Information and information obtained from third parties for the purposes discussed below. The suppliers that we use to provide the Site may collect information about your visits to the Site and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained further below under “Cookies.”
- Operationally necessary. These are cookies that are required for the operation of the Site. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of the Site to make use of its functions, for example, shopping carts, saved search, and similar functions. Without these cookies, Sites that you have requested cannot be provided.
- Functionality related. These cookies allow us to offer you enhanced functionality when accessing or using the Site. This may include remembering choices you make, remembering your username, preferences, or settings, remembering if you reacted to something on or through the Site so that you are not asked to do it again, remembering if you have used any feature of the Site before, restricting the number of times you are shown a particular advertisement, remembering your location, and enabling social media components. As described above, you may disable functional cookies, but if you do so then various functions of the Site may be unavailable to you or may not work the way you want them to.
- Performance related. These cookies assess the performance of the Site, including as part of our analytic practices to help us understand how visitors use and interact with the Site, for example, which pages on our website users visit most often. These cookies also enable us to personalize content and remember your preferences (e.g., your choice of language, country, or region). These cookies help us improve the way our websites work and provide a better, personalized user experience. Some of our performance-related cookies are managed for us by third parties.
- Advertising or targeted related. These cookies record your visits to the Site, the pages you have visited on our websites, and the links you have clicked. They are used to gather information about your browsing habits and remember that you have visited a particular website. Company and its third-party advertising platforms or networks may use this information to make the Site, its content, and advertisements displayed on our websites more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed below). These types of cookies are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. To find out more about interest-based ads and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.
Advertising Networks, Personalized Advertising, Remarketing, and Retargeting. From time to time the Site may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including, as discussed below, Google AdWords. These services collect information about your visits to and interactions with the Site and other websites and will use that information to target advertisements for goods and services. The information collected may be associated with your Personal Information. These targeted advertisements may appear on the Site or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of Internet browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Site and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.
We use Google AdWords, an online advertising service provided by Google, to serve ads on our behalf across the Internet and sometimes on the Site. Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Site and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the
National Advertising Initiative Consumer opt-out page
Digital Advertising Alliance Self-Regulatory Program
. Please remember that changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time.
Single Sign-On. You may sign up for and log into your account on the Site using your Amazon.com account by providing your Amazon log-in information on the Site when prompted. If you choose to use this feature, Company may access, handle, and store any content and other information that you have provided through Amazon and make that information available on the Site. This feature may require us to implement cookies, plug-ins, and application protocol interfaces (APIs) provided by Amazon to facilitate those communications and features. We do not and cannot control any policies or terms of any third-party service, including those of Amazon. All information you have provided to Amazon is subject to the Amazon Privacy Notice.
Social Media. The Site may allow you to connect to and share information with various social media platforms, for example, Facebook. These features may require us to implement cookies, plug-ins, and application protocol interfaces (APIs) provided by those social media platforms to facilitate those communications and features. We may share information that you provide us or that we may collect about your use of the Site with those platforms and that information will be subject to their privacy policies. We encourage you to review those platforms’ privacy policies: see Facebook’s Data Policy. In addition, by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third party platform. As a result, we cannot be responsible for any use of your information or content by a third party platform, which you use at your own risk.
The Site may also use the advertising services and networks offered by those social media platforms to deliver advertising content. Use of these services requires social media platforms to implement cookies or pixel tags to deliver ads to you while you are logged into the platform.
If you do not wish a social media platform to collect information relating to you via the Site, we suggest that you: (a) hide social media platform plug-ins using an ad blocker; (b) always log off completely from the social media platform before visiting other websites and delete all related cookies; and, (c) where the option made available by the social media platform, disable the advertising services and networks operated by that platform.
The Company is active on social media, including Facebook. You have the opportunity to comment on those social media platforms regarding the Company and the products and services we offer. Company reserves the right to post on its websites and social media pages any comments or content that you post on our social media pages.
Purpose for Collecting Personal Information
How We Use and Share Collected Information
Purpose Collected. We will use and share your Personal Information for the purpose for which it was collected, for example, to process your orders for products, in connection with your account and payment, and to provide you with information and communications that you request. If you place an order through the Site, we will use Personal Information to communicate with you regarding your order. In accordance with your preferences, your location information will be used to add location information to your account, if applicable, and to understand where our users are located. If you contact us for support or assistance in using the Site, we may use Personal Information to determine whether or not your system meets the minimum requirements needed to access and use the Site and otherwise to contact you regarding your request.
Communication with You. When you contact our customer service department we may ask you to provide or confirm Personal Information so that we can better serve you. We may use Personal Information to notify you of changes made to the Site (for example, changes to our
Sharing Personal Information with Other Third Parties. We may share, rent, license, or sell Personal Information with third parties who have or offer products or services we think may be of interest to you. You may opt out of receiving communications from any such third party pursuant to such third party’s policies. We do not control any third party or their policies.
aggregate data. We may aggregate Personal Information to create aggregate data on Site users, which describes users as a group but does not reveal the identity of individual users. We may use aggregate data to understand Site users’ needs, to determine Site user demographics and usage patterns, to determine what kinds of products and services we can provide, and to improve and enrich our products, our services, and the Site.
Evaluation and Improvement of the Site. We may use Personal Information: to analyze, develop, and improve the content, materials, products, and services that we make available through the Site and the Site’s functionality; to inform marketing and communication plans and strategies; to evaluate user needs and customize Site content, promotional emails, and your browsing experience; and for other legitimate and lawful business purposes.
To Protect Company and Others. We may share your Personal Information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services, and other necessary third parties for legal, protection, security, and safety purposes, including: (a) to comply with laws or regulatory requirements and to respond to lawful requests and legal process; (b) to perform credit checks, report or collect debts owed; (c) to protect the rights and property of Company, its agents and customers, and others, including to enforce our agreements, policies, and terms and to protect our network and physical assets; and (d) to protect the safety of our employees, agents, and customers, and any other person.
Business Transactions. We may choose to buy or sell assets from time to time. We may share Personal Information in connection with the evaluation of those transactions. We may transfer Personal Information if we enter into those transactions. Also, if we (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change of control or reorganization, Personal Information and Aggregate Data could be one of the assets transferred to or acquired by a third party.
International Transfers of Your Personal Information
Company does not guarantee that loss, misuse, or alteration of Personal Information will not occur, but we take appropriate technical and organizational security measures in place to help protect against the loss, misuse, and alteration of Personal Information under our control. Specifically, on our shopping cart and payment pages, Secure Socket Layers technology is used to encrypt information passed between your browser and our systems. While we are focused on the security of your Personal Information and follow strict standards, processes and procedures that are designed to protect your Personal Information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.
How Long We Retain Your Personal Information
For Personal Information that we process on behalf of our customers, we will retain that Personal Information in accordance with the terms of our agreement with them, subject to applicable law.
Opt-Out of Marketing Communications
You may opt out of marketing communications we send you at any time by clicking on the “unsubscribe” or “opt out” link in the marketing e-mails we send you. To opt out of other forms of marketing, such as postal marketing or telemarketing, if applicable, then please contact us using the contact information provided below under “Contact Us.”
Categories of Personal Information Disclosed For a Business Purpose
In the last 12 months we shared the following categories of Personal Information for our Business Purposes: Identifiers, Customer Records, Commercial Information, Internet Activity, Geolocation Data and Inferences. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category. Under the CCPA, a “Business Purpose” means the use of Personal Information for use of a Company or its service provider’s operational purposes. Examples include auditing related to a current interaction with the consumer and concurrent transactions, protecting/detecting security incidents, and performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of thebusiness or service provider.
Sale of Categories of Personal Information
In the last 12 months, the Company has provided certain categories of Personal Information for Sale, as defined under California law. Under the CCPA, a “Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing or by electronic or other means a consumers Personal Information to another business or a third party for monetary consideration or other valuable consideration. We may have sold the following categories of Personal Information over the past 12 months: identifiers, Customer Records, Commercial Information, Internet Activity, Geolocation Data or Inferences.
Access by Children
The Site is not directed at children under 16 years of age. Company does not knowingly collect or use information from children under 16 through the Site. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Site, please contact us at email@example.com and we will use commercially reasonable efforts to delete that information.
FOR INDIVIDUALS RESIDING IN THE EUROPEAN ECONOMIC AREA (EEA )
Legal Basis for Processing Your Personal Data
If you are an individual from the EEA, our legal basis for collecting and using Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where: (a) we have your consent to do so; (b) where we need the Personal Data to perform a contract with you (e.g., to deliver products or services you have requested); or (c) where the processing is in our or a third party’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided further below provided below under “Contact Us.”
Your Data Protection Rights
You have the following data protection rights if you are a resident of the EEA:
- If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by visiting your Company account or contacting us at firstname.lastname@example.org.
- You can object to the processing of your Personal Data, you can ask us to restrict processing of your Personal Data, and you can request portability of your Personal Data. You can exercise these rights by visiting your Company account or contacting us at email@example.com
- If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information please contact your local data protection authority.
Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have additional rights with regard to their Personal Information. The right to know and the right to request deletion are subject to certain exceptions and subject to our ability to verify your identity. We have provided a summary of those rights below:
Right to Know. You have a right to access any of the following information for the 12-month period prior to the date of your request: (a) the categories of Personal Information we collected from you, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or selling your Personal Information, (d) the categories of third parties with whom we shared your Personal Information, (e) the specific pieces of Personal Information we collected from you (i.e. “data portability”), and (f) a list of categories of Personal Information which were subject to a Sale or disclosed for a Business Purpose in the last 12 months. This request may be made no more than twice in a 12-month period.
Right to Request Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
Right to Opt-Out of Sale of Personal Information to Third Parties. You have the right to direct us not to sell your Personal Information at any time. You may submit your opt-out request following the process described below.
Right to Non-Discrimination. We will not discriminate against you for exercising your rights under the CCPA by charging you different pricing or providing a different quality of products.
How to Exercise Your Rights Under CCPA
To exercise your rights under the CCPA, you may submit a request to us by contacting us at any of the following:
- By email to firstname.lastname@example.org
- Write us at Silver Star Brands, Inc., 250 City Center, Oshkosh, Wisconsin 54906.
Please include the phrase “California Privacy Request” in the subject line of any email request or in your letter. Please include your name, email address, and mailing address in any request. We reserve the right not to respond to requests submitted in ways other than those specified above.
Who May Exercise Your Rights. You may only make a request to exercise your rights on behalf of yourself. A parent or legal guardian may make a request on behalf of their child. If you are a California resident, only you or a person you authorize to act on your behalf may make a request related to your Personal Information.
Authorized Agents. You may designate an authorized agent to make a request on your behalf to exercise your rights under the CCPA by doing the following: (1) provide the authorized agent written permission to do so; and (2) verify your own identity (per the process stated above), as well as the identity of the authorized agent directly. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
Verifiable Consumer Request. In order to verify your request, you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information. You must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
When and How Will We Respond. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
How to Opt-Out of Sale of Personal Information
You may submit your opt-out request by following this link: https://www.mileskimball.com/contact-us.
To opt-out online, please send us an e-mail to: email@example.com, or send a mail request to Silver Star Brands, Inc., 250 City Center, Oshkosh, Wisconsin 54906. However, if you opt-out of a “Sale” of your Personal Information, ads you view may not be as tailored to your Interests.
California’s “Do-Not-Track” Requirement
We currently do not honor “do not track” requests.
Shine the Light.
Silver Star Brands does not share Personal Information as defined by California Civil Code Section 1798.83 (“Shine the Light”) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us by email firstname.lastname@example.org or by sending a letter to Silver Star Brands, Inc. 250 City Center, Oshkosh, Wisconsin 54906. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year pursuant to this provision, and we are not required to respond to requests made by means other than through this email address or mail address.