’47 BRAND, LLC PRIVACY POLICY

1.        ABOUT US

1.1  We are ‘47 Brand, LLC (‘47 Brand), of 15 Southwest Park, Westwood, Massachusetts 02090 USA and our data protection officer can be contacted regarding this privacy policy at DPO@47brand.com. Any personal information processed by ‘47 Brand is controlled by us and we are regarded as the data controller of your personal information.

2.        DATA PROTECTION LAWS

2.1  We have to comply with all relevant data protection laws and regulations, including but not limited to, the EU General Data Protection Regulation (EU) 2016/679 and the California Consumer Privacy Act of 2018 (CCPA) when processing personal information about you.

3.        ABOUT THIS PRIVACY POLICY

3.1  We are committed to protecting your personal information and respecting your privacy.

3.2  This policy explains about the personal information that we collect from you, use and otherwise process in connection with your relationship with ‘47 Brand as a customer or potential customer. In particular, we explain the kinds of personal information that we collect from you, how we collect it, what we use it for and who we may share your personal information with. 

4.        CATEGORIES OF INFORMATION WE COLLECT

4.1  We collect personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably linked, directly or indirectly, with a particular consumer or household (“Personal Information”) such as your name, contact details, purchase history, information about how you use our services and about how you use our website at www.47brand.com (Website). This may include information that you provide to us directly or through companies or agents we work with, as well as information which we collect from and about you when you use our services. 

5.        HOW WE COLLECT YOUR INFORMATION

5.1  We collect Personal Information about you whenever you use our services or buy our products (whether such services or products are provided directly by us or by other companies or agents acting on our behalf), or when you use our Website or contact our customer service providers.  Personal Information may be obtained through the following categories of sources: (i) directly from you (i.e. products you purchase, information you fill out, etc.); (ii) indirectly from you (i.e. information collected through the course of processing sales, etc.); (iii) directly and indirectly from activity on the Website (for example, from submissions through the Website and/or Website usage details collected automatically); (iv) from third-parties that interact with us in connection with the products we offer for sale; (v) through tracking technologies when you access the Website, including cookies, web beacons, embedded scripts, browser fingerprinting, ETags or Entity Tags, recognition technologies and location identifying technologies.

6.        USES OF PERSONAL INFORMATION

6.1  We may use the categories of Personal Information that we collect from consumers for the following business and commercial purposes:

• (i) to fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a product, we will use that information to process your payment and facilitate delivery.  We may also save your personal information to facilitate new product or service orders or to process returns;
  
  

• (ii) to provide you with information or products that you request from us and/or to communicate with you about other services you have asked us to provide;

• (ii) to provide, support, personalize and develop our website, products and services;

• (iv) to create, maintain, customize and secure your account with us.

• (v) to process your requests, purchases, transactions and payments, and to prevent transaction fraud;

• (vi) to provide you with support and to respond to your inquiries, including to investigate and address your concerns, and to monitor and improve our responses.

• (vii) to personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party websites and via electronic mail and/or text message (with your consent, where required by law);

• (viii) to provide you with marketing and offers from us and to provide you with alerts or other notices via electronic mail and/or text messages concerning our products, services, events, or news that may be of interest to you;

• (ix) to help maintain the safety, security and integrity of our website, products and services, databases and other technology assets, and business;

• (x) for testing, research, analysis and product development, including to develop and improve our website, products and services.

• (xi) to consider you for employment per your request and application;

• (xii) to process your registration with any of our services, including verifying your information is active and valid;

•  (xiii) to contact you with regard to your use of any of our services and, in our discretion, changes to any of our services and/or any of our services’ policies.

•  (xiv) to respond to law enforcement requests a required by applicable law, court order, or local, state, or federal government regulations and to comply with our security and legal obligations; and

•  (xv) as necessary or appropriate to protect our rights, property, or safety and the rights, property or safety of our clients and others.

7.        WHO ELSE MAY HAVE ACCESS TO YOUR INFORMATION

7.1 To best serve you, we may share your personal information with Service Providers that provide support services to us or that help us market our products and services. Service Providers are third parties which perform services on our behalf. They are contractually restricted from using your personal information in any manner other than in helping us to provide you with the products and services available from ’47 Brand. In addition to the foregoing, we may share Personal Information with our 3rd Party Marketing Partners  for commercial use. If you wish to opt out of your data being shared with our 3rd Party Marketing Partners  please email us at DPO@47brand.com.

 7.2  We may also disclose your personal information to a third party when you ask us to do so or when we believe it is required by law.

8.        YOUR CONSENT

8.1  When you came to our Website, you were asked to tick a box confirming you had read this privacy policy and that you agree to us collecting your personal information and using it in the ways and for the reasons explained in this privacy policy. You can view this notice again by clicking here: Cookies Policy.

9.        COLLECTING YOUR PERSONAL INFORMATION LEGALLY

9.1   We are able to legally collect and use your personal information either because:

9.2    you have provided us with your consent to do so as explained above; 

 we are required to do so in order to comply with an EU, Federal or State legal obligation or to enforce our rights and defend claims; and/or

        9.1.1     collecting and using your personal information is necessary for us to:

        9.1.2     process any purchases made by you via our Website; or

        9.1.3     carry out our legitimate business interests in order to carry out any requests or orders made by you via our Website.

10.      RETENTION OF YOUR PERSONAL INFORMATION

10.1  We will only retain your personal information for as long as it is necessary to process your purchases, keep you up to date with ‘47 Brand promotions unless you have asked us not to do so and/or to provide you with the best customer experience possible. Processing is therefore necessary for the purposes of our legitimate interests, or where we are required to do so by law. 

11.      YOUR RIGHTS

11.1   You have the right to:

          11.1.1  be informed about and request that we disclose to you the personal information we collect from you and use, which this privacy policy seeks to do;

          11.1.2. obtain confirmation from us that your personal information is being collected and used by us and to access the personal information held about you by us;

          11.1.3  have your personal information corrected if it is inaccurate or incomplete at any time;

          11.1.4   erasure, or the right to be forgotten, which means that you can request the deletion or removal of any personal information we hold about you at any time;

          11.1.5  block or suppress us collecting and using your personal information, which means we can continue to store your personal information but we cannot further collect or use it in any way;

           11.1.6 obtain and reuse any personal information we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from ‘47 Brand to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and

        11.1.7  object to us collecting or using your personal information where this is based on:

• (a) a legitimate interest or the performance of a task in the public interest; or

• (b) direct marketing.

11.2   To make any requests as listed above, please contact us at DPO@47brand.com.

11.3   We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.

 

12.      WITHDRAWAL OF YOUR CONSENT

12.1  You can tell us to stop collecting and using your personal information at any time by emailing us at DPO@47brand.com.

12.2  If you tell us to stop collecting and using your personal information, the consequences of doing so are that:

         12.2.1  you will be unable to make a purchase through our Website;     

          12.2.1  we will be unable to update you on our promotions and product news;

         12.2.3  we will be unable to provide you with the best user experience possible to our Website; and

         12.2.4  we will generally be unable to provide you with the customer experience which we would like to provide you with.

13.      COOKIES, WEB BEACONS, AND OTHER SIMILAR TECHNOLOGIES

13.1 We have instituted a policy that governs our Website’s use of “cookie” and “web beacon” technology.  Please click here to review our Cookie Policy.

14.     CHILDREN’S PRIVACY

14.1 We do not knowingly collect any information from anyone under 16 years of age.  Our Website, products and services are all directed to people who are at least 16 years old or older.

14.2  If you are under 16, do not use or provide any information on our Website or on or through any of its features and do not register on the Website, make any purchases through the Website or provide any information about yourself to us, including your name, address, telephone number or email address. 

14.3  If we learn we have collected or received personal information from a child under 16 years of age, we will delete that information. 

14.4  If you believe that we might have any information from or about a child under 16 years of age, please contact us at DPO@47brand.com.

15.      LINKS TO OTHER WEBSITES AND SERVICES

15.1  Our Website may include links to other Internet sites, content, or videos (embedded or direct links) maintained by third parties (Linked Sites).  We provide Linked Sites to you solely as a convenience, and the inclusion of Linked Sites does not imply endorsement by us of the Linked Sites.  You access Linked Sites at your own risk and by accessing them you leave our Website.  Linked Sites are not under our control and we are not responsible for the contents of any Linked Site, including the privacy policies or tracking technologies they may use.  We encourage you to check the applicable privacy policy to determine how they will handle any personal information they collect from you.

16.      YOUR INFORMATION, YOUR CHOICE

16.1  To update us with your information-sharing preferences, you may contact us using one of the following methods:

• Email: orders@47brand.com; or

• Mail your request to: '47 Brand, LLC, 132 Campanelli Industrial Drive, Brockton, MA 02301 USA

17.      SECURITY

17.1  We implement appropriate technical and organisational measures to ensure a level of security appropriate to potential risks, including:

       17.1.1  the pseudonymisation and encryption of your personal information where appropriate;

       17.1.2  ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;

       17.1.3  ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and

       17.1.4  regular testing, assessment and evaluation of the effectiveness of our technical and organisational measures to ensure your personal information is secure. 

 17.2  We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us using our Website.  We do not store any credit card information on our servers.  Please note that email is not encrypted and is not considered to be a secure means of transmitting credit card information.

18.      BUSINESS TRANSITIONS

18.1  As we continue to develop our business, we may undergo a business transition such as acquiring another company, merging with an existing company, or selling a portion of our assets.  In such transitions, customer information is typically one of the business assets that is transferred or acquired by a third party.  In the unlikely event that ‘47 Brand or substantially all of its assets are acquired or are subject to court proceedings relating to the sale or acquisition of the business, you acknowledge that such transfers may occur and that your personal information can continue to be used as set forth in this privacy policy.

19.      POLICY CHANGES

19.1  This policy replaces all previous disclosures we may have provided you about our information practices and is effective on the date noted at the start of this policy.  We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted or otherwise required by law.  If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our Website.

20.      MAKING A COMPLAINT

20.1  We pride ourselves on excellent customer service, but if you would like to make a complaint about the way we have collected or used your personal information, please contact us at DPO@47brand.com or by any of the other mechanisms more fully detailed in Section 16 of this policy.

21.      INFORMATION FOR EU AND UK RESIDENTS

21.1    Countries Having Access to Your Information 

            21.1.1 For data storage reasons we are unable to store all of your personal information in the United Kingdom. Our servers, storing and keeping your information secure, are located in countries which have an adequate level of protection or with companies with which we have signed agreements incorporating the Model Contract Clauses.

21.2    Complaint Procedure

          21.2.1  If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: https://ico.org.uk/concerns/ or telephoning the ICO helpline, which is (from the UK) 0303 123 1113.