Privacy Policy
Last Revised: February 1, 2023
Occidental Leather (“Company,” “we,” “us,” or “our”) publish this Privacy Policy and Notice (“Policy”) regarding the collection, use, and disclosure of personal information and provides instructions for submitting data subject requests. Please read this Policy to understand how your information that you provide will be treated as you make use of our online offerings. When you submit information to or through our Website, you acknowledge that you understand and agree to the terms of this Privacy Policy and the Terms of Use. We advise you to read this policy before submitting any information to us.
This Policy is intended for use only by residents of the United States and includes information as required by law, including the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), and the Connecticut Data Privacy Act of 2022 (“CDPA”) and any and all regulations arising therefrom.
If you are unable to review or access this Policy due to a disability, you may contact private@occidentalleather.com to access this Policy in an alternative format.
Definitions Specific to this Policy
- “Consumer” means a natural person who resides in the United States and to whom we offer information, goods, or services. For purposes of this Policy, this term includes natural persons who reside in California and engage with us as part of business-to-business transactions.
- “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 Consumer or household. Personal Information includes “personal data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as defined below.
- “Sensitive Personal Information” means Personal Information that reveals a Consumer’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 6) Union membership; 7) Contents of email or text messages, unless we are the intended recipient; 8) Genetic data; 9) Biometric information used to uniquely identify the Consumer, and 10) Health, sex life, or sexual orientation. Sensitive Personal Information includes “sensitive data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA.
- “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.
- “Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for behavioral advertising purposes, whether or not for money or other valuable consideration.
- “Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the CCPA, CPA, VCDPA, UCPA, and CDPA.
- “Vendor” means a “service provider,” “contractor,” or “processor” which collects, stores, or otherwise handles data for us, as those terms are defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.
These definitions apply, whether terms are capitalized or not. Other terms used in this Policy and not defined under the CCPA, and no defined herein shall have the meanings described in the CCPA. These definitions apply, whether terms are capitalized or not. Other terms used in this Policy may be defined under the CCPA, CPA, VCDPA, UCPA, or CDPA, and they shall have the meanings described in those statutes. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state. For example, if you are a Colorado consumer, terms defined in the CPA shall apply to you if they are used in this Policy.
The Personal Information We Collect and Disclose
The chart below shows the categories of personal information we may collect; examples of personal information in each category; types of sources from which each category of personal information is collected; the business purposes for which each category of personal information is collected; and the types of Vendors or Third parties with whom that category of personal information is shared. As this chart shows, we may share or sell personal information to Third Parties or disclose certain personal information to Vendors for business purposes.
Category of Personal Information | Examples | Sources from Which This Personal Information is Collected | Business Purposes for Collection | Types of Vendors or Third Parties with Whom This Personal Information is Shared, Sold or Disclosed |
---|---|---|---|---|
Unique Identifiers | Real name, signature, alias, address, unique personal identifier, online identifier, IP address, email address, account name, cookies, pixels, web beacons | -Directly from you via our website such as signing up for email program, beginning an order, or completing an order -Direct communication with you -Social media interaction with you -Marketing agencies | -Provide you with goods and services -Managing your preferences -To finalize purchases if cart is abandoned -Marketing and transactional emails -Other promotions such as targeted marketing based on pixels -Provide personalized website experience | Disclosed: -Web site hosts -Event planners -Credit check firms -Third party email system Shared or Sold: -Business partners -Marketing providers -Analytic providers -Social media platforms |
Contact and Financial Information | Name, address, telephone, email, credit card number, debit card number, or any other financial information | -Directly from you via our website – collected by third-party payment processor -Claims management providers | -Complete transactions -Other services and discounts -Process claims -Prevent fraud | Disclosed: -Payment processors -Mailing houses -Lenders Shared or Sold: -None |
Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | -Directly from you via our website -Direct communication with you -Social media interaction with you -Marketing agencies | -Provide you with goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions | Disclosed: -Web site hosts -Payment processors -Marketing consultants -Contractors Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media platforms -Online influencers |
Internet or Other Electronic Activity | Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement | -Directly from you via our website -Direct communication with you -Social media interaction with you -Marketing agencies | -Provide you with goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions | Disclosed: -Web site hosts -Payment processors -Contractors Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media platforms -Online influencers |
Geolocation Data | Device location | -From your digital device -Direct communication with you -Social media interaction with you | -Provide you with goods and services -Customer service communications -Improve promotions | Disclosed: -Service providers Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media platforms |
Inferences Drawn from Other Categories to Create a Profile | Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | -Directly from you via our website -Direct communication with you -Social media interaction with you -Marketing agencies | -Provide you with goods and services -Customer service communications -Improve promotions | Disclosed: -Marketing consultants -Service providers Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media platforms |
Sensitive Personal Information We Collect and Disclose
Category of Sensitive Personal Information | Sources From Which This Sensitive Personal Information is Collected | Business Purposes for Collection | Types of Vendors or Third Parties with Whom This Sensitive Personal Information is Shared, Sold or Disclosed |
---|---|---|---|
Account log-in, financial account, debit card number, plus an access code | -Directly from you you via our website – collected by third-party payment processors | -Complete transactions -Offer services and discounts -Prevent fraud | Disclosed: -Web site hosts -Payment processor -Service Providers Shared or Sold: -None |
Retention of Data
We intend to retain each category of personal information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average consumer’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.
Use of Aggregated Information
We may use information gathered through our Website to create a compiled, aggregate view of our Website’s audiences and their visitors’ usage patterns. We use aggregated information to operate our services and to better understand our audience as we develop new products and services. We may also share aggregated information with our third-party service providers as well as with potential investors, advertisers, and subscribers so they can better understand and/or market to our audience.
Your Rights to Your Personal Information
Consumers have certain rights with respect to the collection and use of their personal information. Those rights vary by state. We provide detailed information below regarding the data subject rights available to consumers.
You have the right to submit requests related to the personal information we have collected about you. You may make such a request twice in a 12-month span. Please note there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request, or we may find that providing a full response conflicts with other legal obligations or regulatory requirements. We will notify you if this is the case.
Our website contains links to other websites. We encourage all of our partners, contributors, and third parties to implement policies and practices that respect the privacy of our users. However, we are not responsible for the privacy practices or content of such websites.
Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:
- The categories of personal information to be collected;
- The purposes for which the categories of personal information are collected or used;
- Whether or not that personal information is sold or shared with Third Parties or disclosed to Vendors;
- If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
- The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.
We have provided such information in this Policy, and you may request further information about our privacy practices by using the contact information provided below.
Right Know and Right to Access. You have the right to request certain information we have collected about you. You have the right to request:
- Specific pieces and categories of personal information we collected about you;
- The categories of sources from which personal information was collected;
- The purposes for which personal information was collected, shared, sold, or processed;
- The categories of personal information we shared, sold or disclosed; and
- The categories of Vendors or Third Parties with whom we shared, sold or disclosed personal information.
Right to Delete. You have the right to request that we delete certain personal information that we have collected.
Right to Correct. You have a right to request that we correct any inaccurate personal information we may retain about you.
Right to Opt-Out of the Sale and Sharing of Your Personal Information. You have the right to opt-out of the sale and sharing of your personal information with Third Parties, and the right to opt out of the processing of personal information for targeted advertising purposes, as defined in the CCPA.
We sell and share personal information, or process personal information for targeted advertising purposes. In the past 12 months, we have sold or shared the categories of consumer personal information as listed in this Policy. As a consumer, you have the right to opt-out of the sale and/or sharing of your personal information and of the processing of personal information for the purpose of targeted advertising. We do not knowingly sell or share personal information of consumers under 16 years of age. To submit an opt-out request, please email us at private@occidentalleather.com.
If you opt-out of the sale of your personal information, we will wait at least 12 months before asking you if we may sell or share your personal information. You have the right to opt-in to the sale of your personal information after you have opted out. If you would like to opt-in to the sale or sharing of your personal information, please email us at private@occidentalleather.com. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.
In addition, if you would like to opt-out of having interest-based information collected by certain entities during your visits to our Website or other websites, please visit http://www.aboutads.info/choices/. You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on our Website do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies.
Right to Consent to or Limit the Use of Your Sensitive Personal Information. You have the right in CA to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average consumer or for specific business purposes defined by law.
We do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA, or beyond your consent.
Right to Non-discrimination. You have a right to exercise the above rights, and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests.
Instructions to Exercise your Rights. If you would like to make any of the data requests listed above, please email us at private@occidentalleather.com.
You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.
Right to Appeal. You have the right to appeal our decisions about your data subject requests. If you choose to appeal, your request will move from Operations to our Legal Department for review. If you would like to appeal a decision regarding your data request, please email us at private@occidentalleather.com. Please state that your request is an “Appeal,” and describe the date and nature of your original request.
Verification Process
When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.
If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:
- Verify your identity with us directly.
- Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.
We may deny a request from an agent purportedly acting on your behalf if we request, and the agent does not submit, proof that he, she, or it has been authorized by you to act on your behalf.
Personal Information of Minors
Our online content is not intended for minors under the age of sixteen years. Accordingly, we do not knowingly collect or store information from minors under the age of sixteen years, except as required by law. If you believe that a child has submitted personal information to us, please email us at private@occidentalleather.com and we will delete the information.
Additional California Privacy Rights
Shine the Light Request. California Civil Code Section § 1798.83 permits users of our website who are California residents to request information about our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please email us at private@occidentalleather.com with the subject “Shine the Light Request.”
Security
We maintain reasonable administrative, physical, and technical measures to protect the security of your personal information you submit on or through this Website. However, no website, server or database is completely secure or “hacker proof.” Therefore, we cannot guarantee that your personal information will not be disclosed, misused or lost by accident or by the unauthorized acts of others.
Changes to Our Policy
Company reserves the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post an updated policy on our website with the effective date.
Additional Information
If you would like additional information regarding our Policy, please email us at private@occidentalleather.com.