Last updated: April 19, 2021

Grandin Road respects the privacy of our customers and has developed this Privacy Policy to demonstrate our commitment to protecting your privacy. This Privacy Policy is intended to describe for you, as an individual who uses the Grandin Road website, places orders by phone, uses our other services, or who otherwise provides us with information through phone, mobile application, fax, mail, at a retail store, or with information through various means ("Services"), the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.

We encourage you to read this Privacy Policy carefully when using our Services or otherwise transacting business with us. By using our Services or otherwise doing business with us, you are accepting the practices described in this Privacy Policy. Grandin Road is a part of a family of businesses that spans the full retail spectrum including television, catalogues, ecommerce, and brick & mortar retail."Affiliate Companies" means the family of businesses described in the previous sentence. Grandin Road may share with and receive data from its Affiliates.

Affiliates including the following kinds of companies:

• Subsidiaries: present and future companies that Grandin Road directly or indirectly owns
• Owners: present and future companies that directly or indirectly own Grandin Road
• Other Companies: present and future companies that may be directly or indirectly owned by Grandin Road’s Owners

Examples of Grandin Road's Affiliates include QVC, HSN, Zulily, Frontgate, Ballard Designs, and Garnet Hill.

We encourage you to read the Grandin Road Privacy Policy carefully when using our Services or transacting business with us. By using our Services or otherwise doing business with us, you are accepting the practices described in the Grandin Road Privacy Policy.

If you have any questions about our privacy practices, please refer to the "How to Contact Us" section of this Privacy Policy.

INFORMATION WE MAY COLLECT

As described more in this section, we may collect information that can identify you ("personal information"), such as your name, phone number, mailing address and e-mail address, (i) when you (or other users) provide it to us when using our Services, or (ii) from other Affiliate Companies, from our business partners, or from other third parties. We may combine the personal information that we receive from different sources. When you provide personal information through our Services, the information may be sent to servers located in the United States and other countries around the world.

• INFORMATION YOU PROVIDE. We may collect and store any personal information you enter on our online Services, provide to us by phone, furnish to our customer service department, or give to us in some other manner. This includes identifying information, such as your name, address, e-mail address, and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date, or other financial information). We also may request information about your interests and activities, your gender and age, your opinion about products and services that we offer, and other demographic information.
• INFORMATION FROM OTHER SOURCES. We may also periodically obtain both personal and non-personal information about you from other Affiliate Companies, business partners, contractors, and other third parties and add it to our account information or other information we have collected. Examples of information that we may receive include: updated delivery and address information, purchase history, and additional demographic information.
• INFORMATION ABOUT OTHERS. We may also collect and store personal information about other people that you provide to us. If you use our Services to send others (friends, relatives, colleagues, etc.) a product as a gift, information that may interest them, or messages (such as invitations) through our Services, we may store your personal information and the personal information of each such recipient.
• OTHER INFORMATION. We may also collect information that does not identify you.

We also may collect other types of information in the following ways when you use our online Services:

• INFORMATION COLLECTED AUTOMATICALLY. We automatically collect information from your browser when you use our online Services. This information may or can include your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below), and the referring website address.
• COOKIES. Cookies enhance our ability to serve you. Basically, they're pieces of text that a website stores on your computer—an identification code of sorts. This cookie can be accessed by the website when you revisit it.

  We use two types of cookies: session cookies and persistent cookies. Session cookies terminate shortly after you terminate your internet session. Persistent cookies are stored on your hard drive until they expire or are deleted. Both types of cookies help provide an enhanced user experience since they recall your use of the Internet and our services, shopping preferences, shopping cart information, and your password.

  We understand that not everyone wants to permit the use of cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting cookies and how to disable cookies, but we recommend that you leave cookies turned on so that you can take full advantage of the shopping features we offer.

  You may also review "HOW GOOGLE USES INFORMATION FROM SITES OR APPS THAT USE OUR SERVICES", (located at www.google.com/policies/privacy/partners/ ).

  We may allow third parties, including Affiliate Companies, advertising companies, and ad networks, to display advertisements on our online Services. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our online Services do not provide any other personal information to these third parties, but they may collect information about where you, or others who are using your computer or device, saw and/or clicked on the advertisements they deliver, and possibly associate this information with your subsequent visits to the advertised websites. They also may combine this information with personal information they collect from you. The collection and use of that information is subject to the third party's privacy policy. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

• OTHER TECHNOLOGIES. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our online Services and enable us to customize our online Services and advertisements. We also may include web beacons and other similar technologies in promotional or other e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer visitors to our online Services to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming, or other activities.

  Web beacons (also known as clear gifs, pixel tags, or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies which are stored on the user's computer hard drive or device, web beacons are embedded invisibly on the web pages (or in e-mail) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. We also may receive an anonymous identification number if you come to our online Services from an online advertisement displayed on a third-party website.

• MOBILE SERVICES: We may also collect information from your mobile device if you have downloaded any Affiliate mobile application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used may include, but are not limited to your geographic location, how you use the Affiliate application(s), and information about the type of device you use. To opt out of sharing this information, such as location, please review the terms and conditions before you download the application, review the settings on your mobile device, or you may choose at any time to uninstall the Affiliate application(s) from your mobile device.
• Personal information we collect from third partiesGrandin Road collects personal information from other companies. This can include updated address and shipping instructions information; credit information; information from advertisers; information from Facebook, Twitter and other similar platforms; information that is collected automatically through your use of our services; information from entities that provide information that supplements personal information we already have. The categories of third party sources may include advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers.

If you post information about yourself or others, or communicate with others using our Services, please note that we cannot control who reads your postings or what they do with the information you provide. We encourage you to use caution in posting personal information.

HOW WE MAY USE INFORMATION WE COLLECT

In General. We may use information that we collect about you to:

• Fulfill your requests for products and services;
• Offer products and services that may be of interest to you;
• Customize the advertising and content that you see on our Services and on other sites;
• Facilitate use of our Services; communicate with you by e-mail, postal mail, telephone, and/or mobile devices about products or services that may be of interest to you either from us, our Affiliates, or other third parties;
• Manage your account and your preferences and provide you with customer support;
• Perform research and analyze use of and improve our Services, products, and other services, including performing research and analysis about your use of, or interest in, our products, services, or content, or products, services, or content offered by others;
• Identify and protect against fraudulent transactions and other misuses of our Services;
• Verify your eligibility and deliver prizes in connection with contests and sweepstakes;
• Enforce our Conditions of Use and other terms and conditions;
• Manage our business; and
• Perform functions as otherwise described to you at the time of collection.

Financial Information. We may use financial information or payment method to process payment for any purchases or sales made on our online Services or by phone, to enroll you in the discount, rebate, and other programs in which you elect to participate, to pre-qualify you for credit card and other offers that you might find of interest, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

Please review "Your choices about collection and use of your information" below.

WITH WHOM WE MAY SHARE INFORMATION WE COLLECT

We will not share your personal information with others except as indicated below, or except when we inform you in advance and give you the opportunity to opt out. We may share personal information with:

• AUTHORIZED SERVICE PROVIDERS: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our online Services' functionality, and supporting contests, sweepstakes, surveys, and other features offered through our online Services, catalogs, by phone, or by mail. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
• AFFILIATES: We are part of a family of businesses. We may share information we collect, including personal information, with our Affiliate Companies. Sharing information with our Affiliate Companies enables us to provide you with information about a variety of products and services that might interest you. Our Affiliate Companies also will comply with applicable privacy and security laws and, at a minimum, in any commercial e-mail they send to you, will give you the opportunity to choose not to receive such e-mail messages in the future.
• BUSINESS PARTNERS: When you make purchases or engage in promotions offered through our online Services, catalogs, or through our other Services, we may share personal information with the businesses with which we partner to offer you those products, services, promotions, contests, and/or sweepstakes. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your e-mail address and other information to that merchant.
• DIRECT MAIL PARTNERS: From time to time we may share our postal mailing list with selected providers of goods and services that may be of interest to you.
• OTHER BUSINESSES : with which we partner or which we carefully select to offer you products, services, and promotions through our Services;
• OTHER SITUATIONS
  • o In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to comply with legal requirements; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property, or safety of our company, our customers, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our online Services' terms and conditions or other agreements or policies.
  • In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Any third parties to whom we may disclose personal information may have their own privacy policies that describe how they use and disclose personal information. Those policies will govern use, handling, and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of or to otherwise contact those third parties. These entities or their servers may be located either inside or outside the United States.

AGGREGATED AND NON-PERSONAL INFORMATION. . We may share aggregated and non-personal information we collect under any of the above circumstances and also with advertisers and others. We may also share it with third parties and our Affiliates to develop and deliver targeted advertising on our online Services, on websites of third parties, or by other means. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our online Services and the most popular features or services accessed. This information does not contain any personal information and may be used to develop online Services or other content and services that we hope you and other users will find of interest and to target content and advertising.

THIRD-PARTY WEBSITES

There are a number of places on our online Services where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a link on our online Services, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.

Some third-party websites are co-branded with our trademarks and those of our business partners. They may have the look and feel of our online Services, but the URL in your browser window will indicate that you are visiting a different site. Our Privacy Policy applies only to information collected by Grandin Road.

HOW YOU CAN ACCESS YOUR INFORMATION

If you have an online account with us, you have the ability to review and update your personal information online by logging into your account. You can also review and update your personal information by contacting us by phone. More information about how to contact us is provided below.

If you have an account with us, you also may choose to close your account at any time by contacting Grandin Road customer service. After you close your account, you will not be able to sign in to our online Services or access any of your personal information on our online Services. However, you can open a new account at any time. If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our online Services or our customers, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.

YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION

You may choose:

• You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our online Services or our other services because such information may be required in order for you to register as a member; purchase products or services through our online Services or by phone; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions;
• To stop receiving promotional e-mails or newsletters from us, you can modify your e-mail subscription settings in My Account. You can also click Unsubscribe on any of the promotional emails you have received. Lastly, please contact Customer Service at the Company Contact Points below. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional e-mail communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
• Opt-out. We may share your name and mailing address with carefully selected businesses for purposes of sending you relevant catalog, magazine or fundraising offers in the mail. If you do not wish to receive mailings from other companies or to have personal information shared with other companies, for their own direct marketing, please contact us by phone, e-mail or mail.
• Under our Do-Not-Call policy you may instruct us not to call you for marketing purposes by contacting Grandin Road customer service. We will implement your instructions within 30 days. We have policies and procedures in place and train our employees to honor your request. Please note that we may still need to call you for servicing or other non-marketing purposes.
• Stop receiving promotional text messages by texting STOP to 75548. Stop receiving shipping alert and return status texts by texting NO to 866-735-4346. Consent to receiving text messages is not a condition of purchase. To delete or decline cookies (which are discussed above) by changing your browser settings, although if you do so, some of the features or services of our online Services may not function properly;
• To review and update your personal information by contacting us at the e-mail address below or, if you have an online account for our Services, by logging into that account.

Our Company Contact Points
Toll Free: 1-888-263-9850
Email: cs@grandinroad.com
Mail: Grandin Road
Attn: Customer Serivce
5566 West Chester Road
West Chester, OH 45069

HOW WE PROTECT YOUR PERSONAL INFORMATION

We take appropriate security measures (including physical, electronic, and procedural measures) to help safeguard your personal information from unauthorized access, alteration and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information.

We want you to feel confident using our online Services to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure. You should also take care with how you handle and disclose your personal information and should avoid sending personal information through insecure e-mail. Please refer to the Federal Trade Commission's website at www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

USER-SUBMITTED CONTENT (BLOGS, BULLETIN BOARDS, REVIEWS, PROFILES, CHAT ROOMS, ETC.)

We may provide areas on our online Services where you can post information about yourself and others, create a profile, and communicate with others, as well as post reviews of products, establishments, contractors, and the like, or upload content (e.g., pictures, videos, audio files, etc.). Such postings are governed by our Conditions of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your e-mail address, you may receive unsolicited messages. We cannot control who reads your posting or what others may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you will not be able to edit or delete such information.

CHILDREN'S PRIVACY

As the General Terms of Use require customers be 18 years of age or older to use our platforms, we do not knowingly collect personal information from children under the age of 13.

VISITING OUR ONLINE SERVICES FROM OUTSIDE THE UNITED STATES

This Privacy Policy is intended to cover collection of information on our online Services from residents of the United States. If you are visiting our online Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

NO RIGHTS OF THIRD PARTIES

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our Services.

CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile, or registration (unless we do not have such an e-mail address), and/or by prominently posting notice of the changes on our online Services. We recommend that you check our online Services from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

HOW TO CONTACT US

If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us by e-mail or postal mail as follows:

Privacy Contact
Grandin Road
5566 West Chester Road
West Chester, OH 45069
ps@grandinroad.com

YOUR CALIFORNIA PRIVACY RIGHTS

California Residents:

• If you are a resident of California, in addition to the rights set forth above, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties and Affiliates for their direct marketing purposes. California law gives you the right to send us a request at a designated address to receive the following information:
  1. the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
  2. the names and addresses of the third parties that received that information; and
  3. if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.

  We may provide this information in a standardized format that is not specific to you. The designated e-mail address for these requests is ps@grandinroad.com.

• Currently, our online Services do not recognize automated browser signals regarding "do not track" instructions. If we develop this capability in the future, we will describe how we do so in the Grandin Road Privacy Policy. Please note that third parties may collect personal information about your online activities over time and across different websites when you use our online Services or browse other websites. For more information about "Do Not Track," please visit www.allaboutdnt.com.

YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

This "Your Rights Under the California Consumer Privacy Act" section is referred to as the "CCPA Notice", and this CCPA Notice is effective on January 1, 2020. The California Consumer Privacy Act (“CCPA”) provides certain new rights to "consumers" who are residents of California, and this CCPA Notice explains how Grandin Road enables those rights for California residents who are customers or prospective customers using our services, and explains our California personal information practices as required by CCPA.

CCPA requires a summary of personal information practices for the prior twelve months, updated annually, and that summary for calendar year 2019 is reflected in this CCPA Notice. We may update our Privacy Statement more frequently than annually, or provide additional notice such as at the point of collection, to reflect material changes in how we collect and use personal information.

This CCPA Notice supplements our other privacy notices and policies and shall govern in the event of a conflict between this CCPA Notice or other privacy notices and policies. However, if any other notice about CCPA is provided at the point of collection, then that other notice shall govern in the event of a conflict with this CCPA Notice as permitted by applicable law.

NOTE FOR NON-CUSTOMERS. Please note that this CCPA Notice does not apply to certain human resources data or business-to-business communications data, or those data subjects. If you would like information about human resources data or business-to-business communications data, please reach out to your contact at Grandin Road.

COLLECTED PERSONAL INFORMATION.

Categories of Personal Information. Grandin Road may collect personal information about customers and other users of our services who are California consumers including, during calendar year 2019, personal information within the following categories: identifiers; individual records; characteristics of protected classifications under California or federal law; commercial information; biometric information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; professional or employment-related information; and inferences information. The personal information described in this paragraph reflects categories of personal information, disclosure of which is required by CCPA.

Other Personal Information.

We may collect other information that meets CCPA’s definition of personal information but is not reflected by a category. If we do collect such other information, we will treat it as personal information as required by the CCPA, but will not include it when we are required to describe our practices by category of personal information.

Non-Personal Information. As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as personal information, and we reserve the right to convert, or permit others to convert, personal information into deidentified data or aggregate consumer information. Also, as permitted by applicable law, we may choose not to treat publicly available information as personal information. CCPA does not require us to re-identify information or to keep personal information longer than we need it to respond to requests.

SOURCES OF PERSONAL INFORMATION. Grandin Road collects personal information from different sources., including, during calendar year 2019:

Personal information we collect from you. Grandin Road collects some personal information that you provide directly to us. This can include contact information, payment information, order information, communication information, feedback information, preferences information, pictures and videos that you send to us, and other information you provide to us. In addition, a customer may share personal information about other people with us, including recipients of purchases.

Personal information we collect automatically. Grandin Road collects some personal information automatically when you use our services. This can include browsing and use information; information about devices that you use to access Grandin Road's services; information collected through cookies, pixels, and similar technology.

Personal information we create. Grandin Road creates some personal information when you use our services or in the operation of our business. This can include analytics information; and inferences information.

Personal information we collect from third parties. Grandin Road collects personal information from other companies. This can include updated address and shipping instructions information; credit information; information from advertisers; information from Facebook, Twitter and other similar platforms; information that is collected automatically through your use of our services; information from entities that provide information that supplements personal information we already have. The categories of third party sources may include advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers.

USES OF PERSONAL INFORMATION. Grandin Road collects, sells and uses personal information for the following business or commercial purposes:

Business Purposes:

• Performing Services, including:

  • Account provision and maintenance, including creating and managing your account with Grandin Road; providing customer service; verifying customer information; and providing other services in the course of Grandin Road's business operations;

  • Product sales and fulfillment, including selling products; processing and shipping orders to you or to recipients you designate; managing returns; processing refunds; managing warranties

  • Customer service and communications, including responding to requests, comments, or questions through email, text message, telephone calls, postal mail, chat functions; providing interest-based advertising and other advertising, marketing and promotional content and messaging, managing and communicating through Grandin Road presences on social media platforms and other platforms; maintaining user forms and product review capabilities; reviewing recorded calls or content of other communications for quality or customer service purposes; responding to requests for information and taking action that may be requested under CCPA

  • Personalizing user experience and marketing, including targeted product display; targeted marketing and advertising through the services; marketing through emails, text messages, and other communications methods; re-targeted marketing and advertising across other websites, devices, and platforms; auditing related to the performance of Grandin Road's advertising and marketing efforts; engaging in analytics to personalize user experience;

  • Payment-related activities, including processing payments, checking credit-worthiness, evaluating payment options, managing installment payment programs, and managing private label credit card programs

• Maintaining and improving services and user experience, including:

  • Creating and updating applications, websites, and other features or functionality used by Grandin Road;

  • Debugging to identify and repair errors that may affect how the services function;

  • Engaging in analytics related to improving services or user experience; and

  • Product safety or quality activities.

• Fraud prevention and information security, including :

  • Measures to verify identity when an account is used for ordering or when the account is otherwise accessed;

  • Detecting and responding to fraud or security incidents; and

  • Protecting against other malicious, deceptive, or illegal activity

• Short-term, transient use permitted under CCPA

• Internal research, including:

  • Conducting research, analytics, surveys, and focus groups to improve customer experiences, develop services and products, provide better marketing and advertising.

• Other Business Purposes for which we provide notice, including:

  • Legal obligations, including prosecuting people responsible for fraudulent, malicious, deceptive or illegal activities; defending claims; notifying of product recalls or other issues related to products; enforcing and notifying of Grandin Road's terms and conditions, privacy statement and other policies and changes to such terms and conditions, privacy statement and other policies; and for records retention purposes.

  • Disclosures that are exempt from the definition of “sale” under the CCPA, including disclosures at the consumer’s direction, use of identifiers to manage opt-outs, disclosures to our qualified service providers and disclosures as part of a merger, asset sale or other qualifying corporate transaction.

• Any other of our operational purposes consistent with our applicable privacy statements

• Commercial Purposes:To make disclosures that are treated as a sale under the CCPA as more fully described in the next section.

DISCLOSURES AND SALES OF PERSONAL INFORMATION We may disclose personal information to further the business purposes stated above, such as to our service providers. In addition, we may disclose personal information in a manner that CCPA treats as a “sale.” The concept of a "sale" under CCPA is different from what has traditionally been considered a "sale", e.g., selling a customer list for money. Under CCPA, a "sale" potentially includes other uses or disclosures of personal information to third parties outside Grandin Road in a commercial context where an exception to “sale," as provided by CCPA, does not exist. Because the concept of "sale" is arguably so broad under CCPA, Grandin Road may conceivably be deemed to "sell" personal information described in the categories below, even if such "sales" are not the exchange of that personal information for money. As the General Terms of Use require customers be 18 years of age or older to use our platforms, we have no actual knowledge of sales of information of consumers under 16 years of age.

Please note that Grandin Road will treat your direction to Grandin Road to complete a transaction with us as your direction to have Grandin Road provide certain related personal information that may be included in your transaction to a small group of vendors who provide services to fulfill your transaction, and we do not treat that as a sale. These include payment processors, fraud prevention service providers, credit verification or risk assessment service providers, and shippers.

In calendar year 2019 we disclosed personal information for business purposes, or disclosed personal information in a manner that CCPA may treat as a sale as follows:

CATEGORIES OF PERSONAL INFORMATION DISCLOSED OR SOLD	CATEGORIES OF THIRD PARTIES TO WHICH PERSONAL INFORMATION WAS DISCLOSED OR SOLD
Identifiers	Shipping companies  Order fulfillment companies  Payment processors Advertising and marketing companies  Social media platforms  Fraud detection, fraud prevention, and security companies  Research and analytics companies  Technology services providers  Temporary Staff Providers
Individual records	Shipping companies  Order fulfillment companies  Payment processors Advertising and marketing companies  Social media platforms  Fraud detection, fraud prevention, and security companies  Research and analytics companies  Technology services providers  Temporary Staff Providers
Commercial information	Shipping companies  Order fulfillment companies  Payment processors Advertising and marketing companies  Social media platforms  Fraud detection, fraud prevention, and security companies  Research and analytics companies  Website and application developers  Technology services providers  Analytics companies  Temporary Staff Providers
Internet or other electronic network activity information	Payment processors Advertising and marketing companies  Social media platforms  Fraud detection, fraud prevention, and security companies  Research and analytics companies  Technology services providers  Temporary Staff Providers
Geolocation data	Payment processors Advertising and marketing companies  Social media platforms  Fraud detection, fraud prevention, and security companies  Temporary Staff Providers
Audio, electronic, visual, or similar information	Shipping companies  Order fulfillment companies  Payment processors Advertising and marketing companies  Social media platforms  Fraud detection, fraud prevention, and security companies  Research and analytics companies  Website and application developers  Technology services providers  Analytics companies  Temporary Staff Providers
Professional or employment-related information	Advertising and marketing companies  Research and analytics companies  Temporary Staff Providers
Characteristics of protected classifications under California or federal law	Advertising and marketing companies  Research and analytics companies  Temporary Staff Providers
Biometrics	Service providers such as market research vendors assisting us with focus group research Temporary Staff Providers
Inferences	Payment processors Advertising and marketing companies  Social media platforms  Fraud detection, fraud prevention, and security companies  Research and analytics companies  Temporary Staff Providers

CCPA RIGHTS

RIGHT OF DELETION. If you are a consumer (as defined in CCPA), you have the right to request that Grandin Road delete any personal information about you that Grandin Road has collected from you, but CCPA permits Grandin Road to exclude some personal information from a deletion request if that personal information is necessary for Grandin Road to maintain for certain permitted purposes under CCPA. Accordingly, Grandin Road will comply with deletion requests made under CCPA, but some personal information about you may be retained by Grandin Road, as permitted under CCPA.

How to exercise right of deletion: If you are a consumer (as defined in CCPA), you may exercise your right to request deletion of your personal information by clicking here or by calling (866) 668-5962.To verify your identity when submitting a rights request, we may ask you for information you have provided or that we have collected as part of your account registration, recent transactions, or recent interactions with Grandin Road.

RIGHT TO OPT-OUT OF SALES. Grandin Road may sell certain personal information that Grandin Road has collected about you as described above in the "Sales of Personal Information" section above. You can opt-out of sales of personal information by clicking below. However, please note that the concept of a CCPA "sale" is still evolving, and that will affect what uses of personal information are considered a "sale" and how an opt-out of a CCPA "sale" is implemented, particularly where information may be exchanged or accessed through the use of cookies and similar technologies.

There is not yet a consensus or guidance from the State of California as to if the collection of personal information (e.g., device ID and usage info) by third party cookies and technologies associated with our service is a sale by us of your personal information unless being done in a manner that the CCPA qualifies as a service provider activity or is otherwise exempt from sale. Accordingly, we currently are employing technology that will disable non-service provider cookies associated with our services, or signal to them to act only as a service provider, if you exercise an "opt-out of sale" request. We may modify our approach to cookies as the law develops. Please note further that some browsers, applications, and other platforms may have signals that may be characterized as "do not track" signals, but we do not understand them to operate in a way that indicates an "opt-out of sale" expression by you under CCPA. Accordingly, we currently do not recognize these as an "opt-out of sale" request. We understand that various parties are developing do not sell signals to enable "opt-out of sale" requests, and we may recognize certain such signals if we conclude such a program is appropriate.

How to exercise right to opt-out of sales: If you are a "consumer" as defined under CCPA, you have the Right to Opt-Out of some sales of your personal information, and you may exercise your Right to Opt-Out by clicking here or by calling (866) 668-5962.

RIGHT TO REQUEST TO KNOW. If you are a "consumer" as defined in CCPA, then you have the right to request that Grandin Road disclose to you the following information:

1. Specific pieces of personal information that a business has collected about the consumer;
2. Categories of personal information the business has collected about the consumer in the prior 12 months, along with the following additional information:
• Categories of sources from which the personal information is collected;
• The business or commercial purpose for which the business collected or sold the personal information;
• The categories of third parties with which the business shares personal information, and
• for personal information that the business sold , the categories of personal information sold, and for each category the categories of third party recipients; and
• for personal information that the business disclosed for a business purpose, the categories of personal information disclosed, and for each category the categories of third party recipients



How to exercise the right to know:If you are a "consumer" as defined in CCPA, you may exercise your right to request a copy of the information described under this "RIGHT TO REQUEST TO KNOW" section by clicking here or by calling (866) 668-5962. To verify your identity when submitting a rights request, we may ask you for information you have provided or that we have collected as part of your account registration, recent transactions, or recent interactions with Grandin Road. We require a higher level of verification for a request for specific pieces of personal information than for a categories request and will evaluate a right to know request that fails to meet the level of verification required to obtain a copy of your personal information as a categories request. If we cannot verify you to a reasonable degree of certainty we will not provide any consumer-specific information and instead refer you to this privacy notice where you can learn about our data practices generally.

RIGHT TO NON-DISCRIMINATION. If you are a "consumer" as defined in CCPA, then you have the right that a business shall not discriminate against you because you exercised rights under CCPA. However, we reserve the right to provide loyalty programs and other differential pricing and services as permitted by the CCPA, which will be subject to applicable terms and conditions of such programs.


LIMITATION OF RIGHTS; COMPLIANCE WITH APPLICABLE LAW.Notwithstanding anything to the contrary in this CCPA Notice, we may collect, use and disclose personal information as required or permitted by applicable law and this may override CCPA rights. In addition, we need not honor any requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

AUTHORIZED AGENTS. Authorized Agents as defined under the CCPA may submit requests on a consumer's behalf by submitting the request through the same means listed under the rights above. Agents must establish their qualification to act as an agent and Grandin Road will still require verification directly from the consumer, unless the Authorized Agent possesses a power of attorney pursuant to Probate Code sections 4000 to 4465.NEVADA RESIDENTS If you are a Nevada resident and would like to make a request under Chapter 603A of the Nevada Revised Statutes, you may email us at ps@grandinroad.com. Please include "Nevada" in your email subject line, and include the following information in your email: your name, Nevada resident address, and email address.