PRIVACY NOTICE

 

Last Updated: February 12, 2024

 

This Privacy Notice applies to the processing of personal information by Engelbert Strauss Inc, and its affiliates and subsidiaries (“Strauss,” “we,” “us,” or “our”) on our website available at https://strauss.la/ (which for reference, we will refer to as the “Services”).   

 

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”), please see Annex A – Supplemental CCPA Privacy Notice.

  1. UPDATES TO THIS PRIVACY NOTICE
  2. PERSONAL INFORMATION WE COLLECT
  3. HOW WE USE PERSONAL INFORMATION
  4. HOW WE DISCLOSE PERSONAL INFORMATION
  5. YOUR PRIVACY CHOICES AND RIGHTS
  6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
  7. RETENTION OF PERSONAL INFORMATION
  8. CHILDREN’S INFORMATION
  9. THIRD-PARTY WEBSITES/APPLICATIONS
  10. CONTACT US

          ANNEX A - SUPPLEMENTAL CCPA PRIVACY POLICY

     

    1. UPDATES TO THIS PRIVACY NOTICE

    We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.

     

    2. PERSONAL INFORMATION WE COLLECT

    We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

     

    A. Personal Information You Provide to Us Directly

    We may collect personal information that you provide to us.

     

    • Account Creation. We may collect personal information in connection with the creation or administration of your account, such as your name, email address, phone number, mailing or shipping address, professional details, and other information.

     

    • Purchases. We may collect personal information and details associated with your purchases, including payment information and order data. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (for example, your billing details).

     

    • Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email.

     

    • Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

     

    • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”

     

    • Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

     

    • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

     

    • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

     

    • Job Applications. If you apply for a job with us, we will collect any personal information you provide with your application, such as your contact information and CV.

       

      B. Personal Information Collected Automatically

      We may collect personal information automatically when you use the Services.

       

      • Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).

       

      • Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

       

      • Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
        • CookiesCookies are small text files stored in device browsers.
        • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

       

      See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

       

      C. Personal Information Collected from Third Parties

      We may collect personal information from other sources, including third-party services, social networking sites (such as Instagram), and publicly available sources.

      Our Services may offer various tools and functionalities that allow you to provide personal information about others through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

       

      3. HOW WE USE PERSONAL INFORMATION

      We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

       

      A. Provide the Services

      We use personal information to fulfill our contract with you and provide the Services, such as:

      • Managing your information;
      • Providing access to certain areas, functionalities, and features of the Services;
      • Answering requests for support;
      • Communicating with you;
      • Processing your financial information and other payment methods for products and Services purchased;
      • Processing applications if you apply for a job we post on our Services; and
      • Allowing you to register for events.

       

      B. Administrative Purposes 

      We use personal information for various administrative purposes, such as:

      • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
      • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
      • Carrying out analytics;
      • Measuring interest and engagement in the Services;
      • Improving, upgrading, or enhancing the Services;
      • Developing new products and services;
      • Creating de-identified and/or aggregated information. 
      • If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
      • Ensuring internal quality control and safety;
      • Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
      • Debugging to identify and repair errors with the Services;
      • Auditing relating to interactions, transactions, and other compliance activities;
      • Enforcing our agreements and policies; and
      • Carrying out activities that are required to comply with our legal obligations

         

        C. Marketing

        We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

        Some of our marketing activities may be considered a “sale” or “targeted advertising” under applicable privacy laws.

        If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

         

        D. With Your Consent or Direction

        We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information with your consent, or as otherwise directed by you.

         

         

        4. HOW WE DISCLOSE PERSONAL INFORMATION

        We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

         

        A. Disclosures to Provide the Services

        We may disclose any of the personal information we collect to the categories of third parties described below.

         

        • Vendors and Service Providers. We may disclose personal information to our third-party service providers and vendors that assist us with the provision of the Services. This includes service providers and vendors that provide us with analytics, marketing services, IT support, hosting, customer service, and related services.

           

          Some of the service providers we may use include:

          • Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here

           

          • Business Partners.We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

           

          • Affiliates. We may share your personal information with our corporate affiliates.

           

          • Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising” or "targeted advertising".

           

          Some of the advertising Technologies we may use include:

          • Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.

           

          B. Disclosures to Protect Us or Others

          We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

           

          C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

          If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

           

          5. YOUR PRIVACY CHOICES AND RIGHTS

          Your Privacy Choices. The privacy choices you may have about your personal information are described below.

           

          • Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

           

          • “Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

           

          • Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

             

            Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.

             

            The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

            Please note you must separately opt out in each browser and on each device.

             

          Your Privacy Rights. In accordance with applicable law, you may have the right to:

           

          • Confirm Whether We Are Processing Your Personal Information;

           

          • Request Correction of your personal information;

           

          • Request Deletion of your personal information;

           

            • Request Restriction of or Object to our Processing of Your Personal Information;

             

            • Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws),  if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and

             

            • Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

            If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

            Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

            To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

            Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

             

            6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

            All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

             

            7. RETENTION OF PERSONAL INFORMATION

            We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

            To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

            8. CHILDREN'S PERSONAL INFORMATION


            The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

            If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

            9. THIRD-PARTY WEBSITES/APPLICATIONS

            The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each 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. Providing personal information to third-party websites or applications is at your own risk.

             

            10. CONTACT US

            If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: service@strauss.la

             

            ANNEX A - SUPPLEMENTAL CCPA PRIVACY POLICY

            This Supplemental CCPA Privacy Notice supplements our Privacy Notice and only applies to our processing of personal information that is subject to the CCPA. 

             

            Notice at Collection

            At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.

            • Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.
            • Uses of Personal Information. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.
            • Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. If we have previously “sold” personal information or “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “sell” or “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising’ for instructions on how to opt-out of these activities.
            • How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
            • Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notie titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA.

             

            CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED 

            We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources.

             

            Overview of Personal Information Collected, Disclosed, sold, and/or shared

            The CCPA provides California residents with the right to know what categories of personal information Strauss has collected about them, whether Strauss disclosed that personal information for a business purpose (e.g., to a service provider), whether Strauss “sold” that personal information, and whether Strauss “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

            Category of Personal Information Collected by Strauss

            Category of Third Parties To Whom Personal Information is Disclosed to for a Business Purpose

            Category of Third Parties To Whom Personal Information is Sold and/or Shared

            Identifiers

            ·      Vendors and Service Providers

            ·      Business Partners

            ·       Advertising Partners

            Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

            ·     Vendors and Service Providers

            ·      Business Partners

            N/A

            Protected classification characteristics under California or federal law

            ·     Vendors and Service Providers

            N/A

            Commercial information

            ·     Vendors and Service Providers

            ·      Business Partners·       

            ·       Advertising Partners

            Internet or other electronic network activity

            ·      Vendors and Service Providers

            ·       Advertising Partners

            Professional or employment-related information

            ·      Vendors and Service Providers

            N/A

             

            USES OF PERSONAL INFORMATION 

            We may use and disclose the personal information that we collect for the following business and commercial purposes:

            • Providing the Services as further described in our Privacy Notice;
            • Processing for administrative purposes as further described in our Privacy Notice;
            • Processing for marketing purposes as further described in our Privacy Notice;
            • Processing with your consent or direction as further described in our Privacy Notice;
            • Processing to carry out automated decision making as further described in our Privacy Notice;
            • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
            • Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;
            • Debugging to identify and repair errors that impair existing intended functionality;
            • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with Strauss;
            • Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar Services;
            • Providing advertising and marketing services; or
            • Undertaking internal research for technological development and demonstration;

            RIGHT TO OPT OUT OF "SALES" OF PERSONAL INFORMATION AND/OR "SHARING" FOR "CROSS-CONTEXT BEHAVIORAL ADVERTISING"

            We “sell” your personal information or “share” your personal information for “cross-contextual behavioral advertising” to provide you with “cross-context behavioral advertising” about Strauss’s products and services.

            California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.”

             

            DISCLOSURE REGARDING INDIVIDUALS UNDER THE AGE OF 16

            Disclosure Regarding Individuals Under 16

            Strauss does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Strauss does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

             

            DISCLOSURE REGARDING SENSITIVE PERSONAL INFORMATION

            Strauss only uses and discloses sensitive personal information for the following purposes:

            • To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
            • To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
            • To resist malicious, deceptive, fraudulent, or illegal actions directed at Strauss and to prosecute those responsible for those actions.
            • To ensure the physical safety of natural persons.
            • For short-term, transient use.
            • Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
            • To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Strauss, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Strauss.
            • For purposes that do not infer characteristics about individuals.

             

            NON-DISCRIMINATION

            California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.