Updated August 20, 2018
C. Types of Personal Information We Collect and How We Use It
This section provides an overview of the types of personal information we collect and how we use it. Universal Standard’s primary purpose in collecting information about you is to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), to provide you with the best shopping experience possible, and to ensure you enjoy and easily navigate our Services. The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Universal Standard and the requirements of applicable law. Below are some of the ways that Universal Standard may collect Personal Information:
- Personal Information may be provided by you directly to Universal Standard through interacting with the Services, making online or in-store purchases, participating in surveys, during events, participating in sweepstakes or giveaways, and requesting Services or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
- From third-party sources, including service providers such as Shopify, Paypal, and Google, and through your interactions with us on social media websites.
We aim to collect only information that is relevant for the purposes of Processing. An overview of the ways we collect Personal Information and how we use it are outline below.
1. Types of Personal Information We Collect
Universal Standard collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
A. Information You Provide Directly to US.
When you use the Services or engage in certain activities, such as registering for an Account with Universal Standard, making an online or in-store purchase, responding to surveys, entering contests/sweepstakes/giveaways, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Making a Purchase with US. When you make a purchase online or in a Universal Standard showroom, store or pop-up event, we may collect some or all of the following Personal Information, which can be used to identify you, such as your name, company, email address, postal address, phone number, credit card information (not processed or hosted by Universal Standard) and your order history.
- Create an Account. To create an Account, we’ll collect certain information that can be used to identify you, such as your name, postal address and phone number, as well as other optional information you may provide. If you create an Account using your login credentials from one of your third-party services accounts such as Facebook or Google (each an “Third-Party Account”), we’ll be able to access and collect your name and email address and other Personal Information that your privacy settings on the Third-Party Account permit us to access. If you create an Account through the Site or one of your Social Networking Services (“SNS”) Accounts, we may also collect your gender or date of birth.
- Communications with US. We may collect Personal Information from you such as name, email address, birthday, phone number or mailing address when you choose to request information about our Services, create an account, subscribe to Universal Standard’s emails/newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, provide us with feedback, or otherwise communicate with us.
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Site and/or services and in any manner consistent with the policies provided herein.
- Registration for Sweepstakes, Giveaways, Contests and Events. Occasionally, Universal Standard may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide certain Personal Information, such as contact information (e.g., an email address). If you participate in a sweepstakes or contest, your Personal Information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. In addition, occasionally, we will partner with third parties during events, on social media and online channels to sponsor giveaways and promotions. If you choose to share your information in order to participate in an event, giveaway or promotion, your entry information may be shared with such third parties.
B. Information Collected Automatically by US: Pixel Tags/Web Beacons, Cookies, Social Media Widgets, Embedded Scripts, Analytics Information, and Other Data Collection.
Universal Standard, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use pixel tags, cookies, local storage, or other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are small data files placed on your electronic device, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our Site, services, applications, messaging, and tools, and to recognize you across each device. These Technologies include, among others, the following:
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Embedded Scripts. Embedded scripts are programming code designed to collect information about your interactions with the website, such as the links you click. The code maybe temporarily downloaded onto your device from a web server or a third party service provider, and is active only while you are connected to the website.
- Analytics. When you browse or use the Services, we utilize commonly-used logging and analytics tools, including Shopify’s analytics tools and Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Services. For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
- Other Data Collection. We may collect certain information automatically through our Services or other methods of web analysis about how users use our Services (we refer to this information as “Event Data”). Event Data may include information such as an user’s Internet Protocol (IP) address, cookie identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, operating system, browser type and language, hardware type, the web page that a user was visiting before accessing our Services, the pages or features of our Services to which a user browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics.
- Our uses of such Technologies fall into the following below general categories. If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
- Targeting/Advertising Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
C. Information Provided from Other Users.
If you decide to invite a third party to create an account and/or purchase our merchandise, we will collect the Personal Information you provide (e.g., name and email address) for you and the third party in order to send a message to the third party and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to collect such information and contact the third party as described in the foregoing sentence. You or the third party may contact us at email@example.com to request the removal of this information from our database.
D. Information Collected from Third Parties.
We may receive personal information from third parties that we have engaged to provide services to us (including payment processors such as PayPal, Stripe, Amazon Pay, shipping platforms such as ShipStation to fulfill orders, and ecommerce platforms such as Shopify) as well as from third parties that provide web analytics and usage information to us (including platforms such as Google Analytics, Heap, and Hotjar, which may change from time to time). In addition, if you choose to interact with us or our partners on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and engage with our audience.
2. How Universal Standard Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
A. To Provide Products, Services, or Information Requested.Universal Standard may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage Individual information and Accounts;
- Respond to questions, comments, and other requests related to Universal Standard’s Services;
- Provide access to certain areas, functionalities, and features of Universal Standard’s Services;
- Contact you to answer requests for customer support or technical support; and
- Allow you to register for events.
B. Administrative Purposes.
Universal Standard may use Personal Information about you for its administrative purposes, including to:
- Measure interest in Universal Standard’s products and Services;
- Develop new products and Services;
- Verify Individual identity;
- Ensure internal quality control;
- Communicate about Individual Accounts and activities on Universal Standard’s Services and systems, and, in Universal Standard’s discretion, changes to any Universal Standard policy;
- Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
- Process payment for products or services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities; and
- Enforce our Terms.
C. Marketing Universal Standard Products and Services.
Universal Standard may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Universal Standard may provide you with these materials by phone, postal mail, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described herein.
D. Research and Development.
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes. We may contract with third parties who provide us with other information about you, which we may then combine with the information we receive from you. We use this information to better provide our Services, to customize our advertisements to you and other customers, and to provide direct marketing to you, including by mail.
E. Content Submitted.
You agree that Universal Standard is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Universal Standard will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
From time to time, Universal Standard may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
G. Direct Mail, Email.
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, or mailings from us with information on Universal Standard’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to opt-out of any direct mail or email communications with Universal Standard.
H. Services via Mobile Devices.
From time to time, Universal Standard may provide Services that are specifically designed to be compatible and used on mobile devices. Universal Standard may collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Now or in the future, mobile versions of Universal Standard’s Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with Accounts.
I. Anonymous and Aggregated Information Use.
Universal Standard may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified location information, de-identified demographic information, information about the computer or device from which you access Universal Standard’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Universal Standard may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Universal Standard and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
J. Sharing Content with Friends.
K. Other Uses.
Universal Standard may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
We Process Personal Information for, or based on, one or more of the following: (i) based on your consent; (ii) as required or permitted by law; (iii) for our legitimate business purposes; (iv) as necessary to perform a contract with you, complete a transaction or provide you with information or services you have requested or authorized; and/or (v) to fulfill our legal responsibilities, in each case as provided in this Privacy Statement.
D. Social Media Platforms and Third-party Websites
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Universal Standard does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Universal Standard’s Services may, now or in the future, include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
E. Third-Party Payment Processing
When you make purchases through the Services, we process your payments through a Third-Party application and we use the payment services of Stripe, PayPal, Amazon Pay and other payment services from time to time. The Third-Party application may collect certain financial information from you to process a payment on behalf of Universal Standard, including your name, email address, address and other billing information. We do not process, record or maintain your credit card or bank account information and we will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to privacy policies of Stripe, PayPal, Amazon Pay and Google Pay.
F. Onward Transfer—Universal Standard May Disclose Your Information
A. Information Shared with Our Vendors and Service Providers.
B. Business Partners.
Universal Standard may share Personal Information with our business partners for our internal business purposes or to provide you with a product or service that you have requested. Universal Standard may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you.
C. Marketing – Interest-Based Advertising and Third-Party Marketing.
Through our Services, Universal Standard may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Universal Standard related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.
D. Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures).
We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Universal Standard policies or contracts; (v) to collect amounts owed to Universal Standard; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
E. Merger, Sale, or Other Asset Transfers.
G. Opt-Out and Right to Restrict Processing
We offer you choices regarding the collection, use and sharing of your Personal Information, and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services. You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Universal Standard’s Processing of your Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting firstname.lastname@example.org. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
1. Email Communications
2. Do Not Track (“DNT”)
DNT is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
3. Cookies and Interest-Based Advertising
You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here: https://tools.google.com/dlpage/gaoptout.
H. Rights of Access, Rectification, Erasure, and Restriction
Although Universal Standard makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Universal Standard is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Universal Standard determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Universal Standard will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
I. Data Retention
J. Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use, or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
K. International Users and Data Transfers
All Personal Information collected via or by Universal Standard may be stored anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers (e.g., Shopify) and partners. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Universal Standard, you consent to the storage of your Personal Information in these locations.
If you are visiting from the European Union or other regions/countries with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By using the Site, or providing us with any information, you acknowledge and consent to this transfer, processing and storage of your information in countries where the privacy laws may be less stringent than those in the country where you reside or are a citizen.
L. Children’s Privacy
The Services are not directed to children under 13 years of age, and Universal Standard does not knowingly collect Personally Identifiable Information from children under 16 years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child’s Account.
M. California Privacy Rights
California 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.
N. Redress/Compliance and Accountability
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Universal Standard or to which Universal Standard discloses Personal Information for use on its behalf.
- “partners” means affiliates, service providers, licensors, vendors, manufacturers, distributors, or other third parties with which we have a business relationship.
- “Personal Information” is any information relating to an identified or identifiable natural person.
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Universal Standard or Universal Standard’s Agents.