This Privacy Policy was last updated on July 23, 2020.

1. Our Policy

Welcome to the web site (the “Site”) of Halsbrook, Inc. (“Halsbrook”, “we”, “us” and/or “our”). This Site is operated by Halsbrook and has been created to provide information about our company and to provide quality fashion retail products and services (the “Halsbrook Services”) to our Site visitors (“you”, “your”). This Privacy Policy sets forth Halsbrook’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from Site visitors.

Before using the Site or submitting any Personal Data to us, please review this Privacy Policy carefully and contact us if you have any questions. By voluntarily providing us with Personal Data or otherwise interacting with us via the Site, you are consenting to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Halsbrook Services.

The Site is hosted in the United States and intended for use by users in the United States. If you provide Personal Data to this Site from outside of the United States, you consent to the transfers of your Personal Data to the offices and servers of Halsbrook and the authorized third parties referred to herein.

2. Information We Collect

When you interact with us through the Site, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Site: There may be times (such as when you purchase or order a product, register with the Site, contact us with inquiries, participate in contests, sweepstakes or promotions or surveys) when we ask you to provide certain Personal Data about yourself. This Personal Data may include your name, shipping/billing address, telephone number, email address, your date of birth, your clothing sizes and preferences, payment information and other information. We may also maintain a record of your product purchases and transactions conducted on the Site.

Non-Identifiable Data: When you interact with Halsbrook through the Site, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Halsbrook may store such information itself or such information may be included in databases owned and maintained by Halsbrook affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

Cookies and Other Tracking Technologies: In operating this Site, we may use cookies and other tracking technologies. These technologies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use tracking technologies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.

In addition, this Site may enable the use of the Adobe Flash Player. Adobe’s Flash Player is used by the vast majority of websites that offer video and other interactive content. By default, your use of the Adobe Flash Player generates “flash cookies” (also known as “persistent identification elements” or “local shared objects”). The Adobe Flash Player (and similar applications) use flash cookies to remember user settings, preferences and usage similar to the browser cookies referenced above. You can disable, delete and control the degree to which you accept flash cookies by accessing your Adobe Flash Player management tools directly through the settings manager for Adobe Flash, located here. If you do not allow flash cookies to take any disc space on your computer, you may not be able to take advantage of or participate in certain features on this Site. This Privacy Policy covers the use of cookies, flash cookies, and similar files by Company only and does not cover the use of cookies, flash cookies, and similar files by any third-party advertisers or websites linked to this Site.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

3. Our Use Of Your Personal Data and Other Information

We may use Personal Data and the other information collected via the Site for the following purposes:

• To respond to your inquiries, comments, feedback, or questions;
• To send administrative information to you, for example, information regarding the Site or Halsbrook Services and changes to our terms, conditions, and policies
• In connection with the reason for which it was provided;
• To process, complete, and deliver your order;
• To better understand our users and how they interact with the Site;
• To maintain and improve the content, functionality, or security of the Site and the Halsbrook Services;
• To serve you advertisements on third party sites;
• To contact you to tell you about offers and services we believe will be of interest to you;
• To prevent fraud, criminal activity, or misuses of the Site, and to ensure the security of our IT systems, architecture, and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Marketing: Halsbrook may use your Personal Data to contact you in the future to tell you about information, news, events, offers, products, or services we believe may be of interest to you. If we do so, each communication we send you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

De-Identified Data: Halsbrook may aggregate Personal Data so that such data no longer identifies a particular individual and/or otherwise de-identify Personal Data (such date, the “De-Identified Data”). Halsbrook may analyze such De-Identified Data internally to better understand our customers, to improve our products and services and to advance other business purpose of Halsbrook. We may also disclose De-Identified Data to our affiliates, agents, business partners, potential investors and other third parties.

4. Our Disclosure Of Your Personal Data and Other Information

There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. In addition, we may disclose Personal Data to a potential investor and their or our legal and business advisors in contemplation of and/or preparation for a proposed acquisition of or investment in our company.

Agents, Consultants and Related Third Parties: Halsbrook, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include processing payments, mailing information, maintaining databases, shipping services, marketing services, advertising networks and social media platforms. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Halsbrook may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or government request, (ii) protect and defend the rights or property of Halsbrook, (iii) verify compliance with or enforce our Terms of Service, (iv) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (v) protect against legal liability.

5. Your Choices

You can use the Site and browse the products without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Halsbrook Services like purchase items or set aside items for later purchase.

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via this Site.

For California Residents, see the “Additional Information for California Residents” section below to understand the rights you have with respect to your Personal Data.

6. Exclusions; Third-Party Payment Processors

This Privacy Policy does not apply to any Personal Data collected by Halsbrook other than Personal Data collected through the Site. This Privacy Policy shall not apply to any unsolicited information you provide to Halsbrook through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as comment and review areas (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Halsbrook shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Halsbrook uses PayPal to process payments. This third-party payment processor (and not Halsbrook) is responsible for collecting and processing credit card and other payment information and Halsbrook does not collect or store your credit or debit card number. We suggest contacting PayPal directly for information on its privacy policies. You can find PayPal’s user agreement and privacy policy here.

7. Children

Halsbrook does not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Site without their permission. If you think that a child under the age of 16 has provided Personal Data to Halsbrook through this Site, please contact us, and we will endeavor to delete that information from our databases.

8. Links To Other Web Sites

This Privacy Policy applies only to the Site. This Site may contain links to other web sites not operated or controlled by Halsbrook (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from this Site do not imply that Halsbrook endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

9. Social Media

Through the Site, you can choose to access certain social media websites and services that are owned and/or controlled by third parties (like Facebook and Twitter) (such websites and services, collectively, the “Social Media Services”). When you elect to access and use the Social Media Services, you will be sharing your information (which will include personal information if you elect to share such information) with those Social Media Services. As with other Third Party Sites, the information that you share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by the policies and procedures we describe here. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including Halsbrook.

When you use Social Media Services in conjunction with the Site, we will collect relevant information necessary to enable the Site to access that Social Media Service, however you will provide your login information, like your password, directly to such Social Media Service (and not to Halsbrook). As part of such integration, the Social Media Service will provide Halsbrook with access to certain information that you have provided to such Social Media Service, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of the applicable Social Media Services provider, and, as a result, Halsbrook shall not have any liability or responsibility for the privacy practices or other actions of Social Media Services that may be enabled within and/or otherwise accessible through the Site.

10. Security

Halsbrook takes reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to Halsbrook via the Internet.

11. Additional Information for California Residents

In accordance with the California Consumer Privacy Act (“CCPA”), this section is intended to inform California residents of (1) the Personal Information that we collect and how we disclose that information, and (2) the privacy rights California residents may have relating to their Personal Information and how those rights can be exercised. As used in this section “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household, as further defined by CCPA.

Personal Information Collection and Disclosure

The following disclosures are intended to provide additional information about (1) the categories of Personal Information we collect, and (2) how and to whom we disclose that Personal Information. Nothing in this section limits our ability to use or disclose information as described elsewhere in this Privacy Policy.

• Categories of Personal Information Collected: In the past 12 months, we have collected the following categories of Personal Information, as described in greater detail in the “Information We Collect” section above:
  • Identification Information, such as your name, email address, shipping/billing address, account information and password.
  • Demographic Information, such as your date of birth and your clothing sizes and preferences.
  • Commercial Information, such as purchase, payment (e.g., credit card or bank account information), and billing information if you choose to purchase products through the Site or Halsbrook Services.
  • Online Activity Information, such as the date and time of your visit, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Site you use, your internet service provider (ISP), browser language, browser type, operating system, the device and location from which you access the Site.
• Sources of Personal Information: We collect the above categories of Personal Information from you, our analytics providers, vendors, service providers, and as otherwise described in the “Information We Collect” section above.
• Purposes of Collection and Disclosure: We collect and disclose the above categories of Personal Information for the business and commercial purposes described in the “Our Use of Your Personal Data and Other Information” and “Our Disclosure of Your Personal Data and Other Information” sections above
• Categories of Personal Information Disclosed for a Business Purpose: In the past 12 months, we have disclosed for a business purpose all of the above categories of Personal Information to service providers and as described in the “Our Disclosure of Your Personal Data and Other Information” section above.
• Categories of Personal Information Sold: Halsbrook does not make your Personal Information available for purchase or otherwise share your information in exchange for monetary compensation. Certain sharing of your information, however, may be considered a “sale” under the CCPA’s broad definition. In particular, in the last 12 months, if you have visited our Site, we may have shared your Identification Information and Online Activity Information with advertising partners and social media platforms to match and serve our targeted advertisements on third-party websites. (You can find additional information about how you can control cookies here.) See below for information about how to opt out of the sharing of your Personal Information for these purposes.

California Privacy Rights

To the extent provided for by the CCPA and subject to applicable exceptions and exclusions, California residents have the following privacy rights in relation to the Personal Information we collect:

• The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information.
• The right to request deletion of your Personal Information.
• The right to opt out of the sale of your Personal Information.
• The right to be free from discrimination for the exercise of your privacy rights.

Additionally, under California Civil Code Section 1798.83, California residents may have the right to request the categories of Personal Information we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties. At this time, we do not disclose Personal Information to third parties for their own direct marketing purposes.

Exercising Your Rights: California residents can exercise the above privacy rights by filling out the form here, calling 855-448-2332, or emailing us at [email protected]

Verification: In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents: You may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, we may require the agent to present signed written permission to act on your behalf and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

12. OTHER TERMS AND CONDITIONS

Your access to and use of this Site is subject to the Terms of Use.

13. CHANGES TO HALSBROOK’S PRIVACY POLICY

The Site and our business may change from time to time. As a result, at times it may be necessary for Halsbrook to make changes to this Privacy Policy. Halsbrook reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.