Interchange Brands | Privacy Policy

Updated: January 27, 2020

INTRODUCTION

Kyocera Industrial Tools, Inc. (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, interchangebrands.com (the “Site”).

This Privacy Policy applies to information we collect:

On this Site.
In email, text, and other electronic messages between you and this Site.
Through mobile and desktop applications downloaded from, or connected to, this Site, which provide dedicated non-browser-based interaction between you and this Site.

This Privacy Policy does not apply to information collected by:

Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries).
Any third party, including through any application or content that may link to or be accessible from or on the Site.

Please read this Privacy Policy carefully. BY ACCESSING OR USING THIS SITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Updated” date shown at the top of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

INFORMATION WE COLLECT

The information we may collect on the Site includes:

PERSONAL INFORMATION

Personally identifiable information, such as your name, billing address, shipping address, email address, telephone number, and company name (“personal information”).

PAYMENT INFORMATION

Payment information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange our products, or request information about our services from the Site.

SHOPPING INFORMATION

Shopping information, such as the items you have in the compare product list, products viewed, categories viewed, pages viewed on the Site, items in your Wishlist, items in your shopping cart, and search queries submitted, that we may collect when you view information about our products on the Site.

HOW WE COLLECT YOUR INFORMATION

We collect the foregoing information:

When you provide it to us.
Automatically as you navigate the Site.

INFORMATION YOU PROVIDE TO US

We collect information you provide directly to us, for example, when you create an account, participate in interactive features of the Site (such as online chat or message boards), fill out a form, respond to a survey, request customer support, or otherwise communicated with us via the Site. Such information may include personal information, payment information, and any other information you choose to provide.

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SITE

When you access or use the Site, we automatically collect information about you, including the following:

We log information about your use of the Site, including the type of browser you use, access times, pages viewed, items added to your shopping cart, your search queries, click-through statistics, name of domain and host from which you access the Internet; your IP address, and the page you visited before and after navigating to the Site.

We use various technologies to collect information, including sending cookies to your computer or mobile device and placing web beacons on pages of the Site.

Cookies are small data files stored on your hard drive or in device memory that help us to improve the Site and your experience, see which areas and features of the Site are popular, and count visits. Most browsers are set to accept cookies by default.

Web beacons are small electronic files (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content, and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their respective privacy policies and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, If you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor’s website or Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

HOW WE USE YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

Assist law enforcement and respond to subpoenas.
Create and manage your account.
Deliver targeted advertising, coupons, newsletters, and promotions, and other information regarding the Site and our mobile application to you.
Communicate with you regarding your account or order.
Send you technical notices, updates, security alerts, and support and administrative messages.
Fulfill and manage purchases, orders, payments, and other transactions related to the Site.
Generate a personal profile about you to make future visits to the Site more personalized.
Increase the efficiency and operation of the Site.
Monitor and analyze usage and trends to improve your experience with the Site.
Notify you of updates to the Site.
Offer new products, services, and/or recommendations to you.
Perform other business activities as needed.
Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
Process payments and refunds.
Request feedback and contact you about your use of the Site.
Resolve disputes and troubleshoot problems.
Respond to product and customer service requests.
Provide, maintain, and improve the Site.
Process and deliver contest entries and rewards.
Link or combine with information we get from others to help understand your needs and provide you with better service.
Fulfill any other purpose for which you provided the information.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

BY LAW OR TO PROTECT RIGHTS

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

THIRD-PARTY SERVICE PROVIDERS

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. Such third parties are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

AFFILIATES

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

OTHER THIRD PARTIES

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

SALE OR BANKRUPTCY

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline to honor commitments we make in this Privacy Policy.

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content, privacy and security practices, or policies of any third parties, including other websites, services, or applications that may be linked to or from the Site.

SOCIAL SHARING FEATURES

The Site may offer social sharing features and other integrated tools (such as the Facebook “Like” button and the Twitter “Follow” button), which let you share actions you take on the Site with other media. The use of such features enables the sharing of information with your friends or the public, depending on the privacy settings you establish with the entity that provides the social sharing feature.

Use these social sharing features at your own risk. No security measures, including the privacy settings referenced in the paragraph above, are perfect or impenetrable. We cannot and do not guarantee that the information you share using such features will not be viewed by unauthorized persons. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction, including Secure Sockets Layer 256-bit encryption. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

We do not retain your information for longer than is necessary for our business purposes. When we no longer need your information, we dispose of it safely.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

YOUR CHOICES

ACCOUNT INFORMATION

You may at any time review, correct, or delete the information in your account or terminate your account by:

Logging into user account settings and updating the user account.
Contacting us using the contact information provided below.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal requirements.

EMAILS AND COMMUNICATIONS

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

Noting your preferences at the time you register your account with the Site.
Logging into your account settings and updating your preferences.
Contacting us using the contact information provided below.

If you opt-out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting those third parties directly.

COOKIES AND WEB BEACONS

Most web browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis. Be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

OTHER

You can always choose not to provide information when you are prompted to do so. Note that if you do not provide us with certain mandatory information, then you may be unable to take advantage of certain features on the Site.

INTERCHANGEBRANDS PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020

Last Reviewed on: January 27, 2020.

This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Site has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete.
Indirectly from you. For example, from reports of your activity on our Site.
From third parties, for example, our business partners.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Site, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers through our Site and via email (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category K: Inferences drawn from other personal information.

Sales of Personal Information

We do not sell personal information. Therefore, in the preceding twelve (12) months, we have not sold the following categories of personal information:

A. Identifiers.

B. California Customer Records personal information categories.

C. Protected classification characteristics under California or federal law.

D. Commercial information.

E. Biometric information.

F. Internet or other similar network activity.

G. Geolocation data.

H. Sensory data.

I. Professional or employment-related information.

J. Non-public education information.

K. Inferences drawn from other personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Sending an email to privacy@southerncarlson.com, or
Calling us at 1.800.745.6735.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

GDPR Notice

In compliance with the European Union (“EU”) General Data Protection Regulation (“GDPR”), we may rely upon one or more legal bases defined in the GDPR to collect, use, share and otherwise process the personal information of individuals located in the EU, including where:

Necessary to perform a contract we have with you, such as our terms of engagement, and to provide the services;
You have consented to the processing (in which case you may revoke your consent at any time);
Necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims;
Necessary to protect your vital interests or those of others;
Necessary in the public interest; and
Necessary for the purposes of Company’s or a third party’s legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms.

Where we collect, use, disclose and otherwise process your information based on legitimate interests, we may rely on the following interests:

Marketing our products: We use your information as necessary to pursue our legitimate interests in marketing our products to you. For example, where permitted by digital marketing law, we may contact you by email to let you know of products you might be interested in.
Providing, improving and developing our products: We use your information as necessary to pursue our legitimate interests in tailoring and improving our products. For example, we may send you a survey or questionnaire to understand your experience in purchasing from us.

If you are located in the EU, under certain circumstances, you may have certain legal rights under the GDPR, including:

To access the personal data we maintain about you
To receive information about how we process your personal data
To correct your personal data
To have your personal data erased
To object to or restrict how we process your personal data
To request your personal data be transferred to a third party
To withdraw any consent you may have given us to process your personal data

If you are an EU resident, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below. If you are located in the EU and you believe that we have infringed your rights under the GDPR, please contact us by sending an email to privacy@southerncarlson.com.

You have the right to lodge a complaint with a supervisory authority, in particular in your applicable Member State.

CONTACT US

You have the right to access, correct, and delete inaccuracies in your personal information and privacy preferences on the Site at any time by signing into your account and editing your personal information in your account profile. You may also do so by contacting us via telephone, postal mail, or email. If at any time you wish to opt-out of our use of your information for internal marketing purposes, or if you have questions or comments about this Privacy Policy, please contact us at:

Interchangebrands.com

privacy@southerncarlson.com

10840 Harney Street

Omaha, NE 68154

1.800.745.6735