EveryMarket and its subsidiaries and affiliates (collectively, “EveryMarket”),  respect your concerns about privacy. This Privacy Notice describes the types of personal information we collect, how we use the information, with whom we share it, and the choices you can make about our collection, use and disclosure of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

The phrase “personal information” refers to information by which you or the device you are using to connect to the Internet can be identified.

Information We Collect

We may obtain personal information about you from various sources, including this and other EveryMarket websites, mobile applications, shop in store, when you call or email us or communicate with us through third party social media sites, or when you participate in events, sweepstakes, survey or other promotions, sign up to receive our emails, request a catalog, request customer support, apply for a job or otherwise communicate with us. We also may obtain information about you from our parent, affiliate or subsidiary companies, business partners and other third parties.

The types of personal information we may obtain include:

• Your contact information (such as name, Twitter handle, postal and email address, or phone number)
• Contact information of friends or other people you would like us to contact
• Username and password for the account you may establish on our sites
• Payment details (including payment card number, security code, expiration date, cardholder name and billing address)
• Shipping information (including the shipping address and phone number)
• Demographic information (such as age, date of birth and gender)
• Information you provide by interacting with us through social media, including photographs
• Location information, such as the real-time geographic location of the device on which you install our mobile applications
• Shopping behavior and preferences, and a record of the purchases you make on our websites
• Other details that you may submit to us or that may be included in the information provided to us by third parties

In some cases, we may also collect information you provide about others, such as when you purchase a gift card for someone and request that we deliver it electronically, create and share a "wish list" or decide to purchase and ship products to someone. We will use this information to fulfill your requests and will not send marketing communications to your contacts unless they separately opt in to receive communications from us.

In addition, when you visit our websites or use our mobile applications, we may collect certain information by automated means, such as cookies and web beacons. A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We also may use third-party website analytics tools (such as Omniture or Google), that collect information about visitor traffic on our sites and mobile applications.

The information we may collect by automated means includes:

• Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser and operating system type)
• URLs that refer visitors to our sites
• Dates and times of visits to our sites
• Information on actions taken on our sites (such as page views and site navigation patterns)
• A general geographic location (such as country and city) from which a visitor accesses our websites
• Search terms that visitors use to reach our sites

How We Use the Information We Collect

We may use the information we obtain about you to:

• Register you for membership at our websites, in-store and manage and maintain your account on the sites
• Provide products or services you request
• Process, validate, confirm, verify, deliver and track your purchases (including by processing payment card transactions, arranging shipping and handling returns and refunds, and contacting you about your orders, including by telephone)
• Maintain a record of the purchases you make on our sites, Personalize your online experience and provide advertisements, content or features that match your profile and interests
• Respond to your questions and comments and provide customer support
• Communicate with you about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you
• Enable you to communicate with us through our blogs, social networks and other interactive media
• Publish your testimonials about ibspot, including on our websites and blogs, and on social networks (if we choose to publish your testimonial, we will include only your first name, last initial, city and state)
• Manage your participation in our events, sweepstakes and other promotions
• Tailor our products and services to suit your personal interests and the manner in which visitors use our sites, applications and social media assets
• Operate, evaluate and improve our business and the products and services we offer
• Analyze and enhance our marketing communications and strategies (including by identifying when emails sent to you have been received and read)
• Analyze trends and statistics regarding visitors’ use of our sites, mobile applications and social media assets, and the purchases visitors make on our sites
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users
• Enforce our Website Terms of Use and Terms and Conditions
• Carry out any other purpose for which the information was collected

Comply with applicable legal requirements and industry standards and our policies

In addition to the data uses described above, we may use the information collected through cookies and other automated means to uniquely identify the electronic shopping basket you may create on our sites and enable you to retrieve shopping baskets you previously created. We also may use cookies to identify and authenticate visitors.

We may combine the information we collect with publicly available information and information we receive from our parent, affiliate or subsidiary companies, business partners and other third parties. We may use that combined information to enhance and personalize your shopping experience with us, to communicate with you about products, services and events that may be of interest to you, for other promotional purposes, and for other purposes described in this section.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Information We Share

We do not sell or otherwise disclose personal information about you, except as described in this Privacy Notice.

We may share the personal information we collect with our parent, affiliate and subsidiary companies, business partners, ad network vendors and their participants, and other third parties for the purposes described in this Privacy Notice, including to communicate with you about products and services, offers, events and promotions that we believe may be of interest to you. We also may share personal information with our service providers who perform services on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose information about you (i) if we are required to do so by law or legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell, merge or transfer all or a portion of our business or assets. Following such a sale, merger or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

Your Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

You may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to EveryMarket's use or disclosure of your personal information will mean that you cannot take advantage of certain EveryMarket offerings or site features.

Here are the choices we offer:

Sharing Information with Business Partners

You may direct EveryMarket not to share your personal information with our business partners for those partners’ own purposes. To do so, please email us at cs@everymarket.uk. If you opt out, we will continue sharing your information as otherwise described in the “Information We Share” section of this Privacy Notice, including with our service providers, to fulfill your requests and to comply with legal requirements. 

Marketing Emails

You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in the marketing emails or by adjusting your email preferences using the online account you may establish on our sites.

Web Analytics

You may opt out of the aggregation and analysis of data collected about you on our sites by our web analytics vendor and selecting the opt-out link at the bottom of the linked site. 

Targeted Advertising

We may engage with advertising networks that are members of organizations or programs that manage the privacy choices these ad networks offer consumers. For example, you may opt out of receiving certain marketing communications through the Network Advertising Initiative member ad networks, and learn about additional online advertising opt-out options. Please note that we also may work with ad networks that offer their own opt-out mechanisms and may not honor the opt-outs we linked above.  You can opt-out of targeted ads on Facebook. 

Geo-Location Information

When you use an EveryMarket application on your mobile device, you may choose not to share your geo-location details with us by adjusting the device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

Cookies

Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of our sites’ features. In addition, disabling cookies may cancel opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs.

When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Your New York Privacy Rights

If you are a New York resident, you may request that we provide to you (i) a list of the categories of personal information about you that EveryMarket has disclosed to third parties for the third parties’ direct marketing purposes during the calendar year preceding your request, (ii) the names and addresses of such third parties, and (iii) if the nature of the third parties’ business cannot reasonably be determined from their names, examples of the products or services marketed, if known to us, sufficient to give you a reasonable indication of the nature of the third parties’ business. To submit your request, please email cs@everymarket.uk, with the subject line "New York Privacy" and your request in the body of your email.

Access and Correction

You may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information using the online account you may establish on our websites. In addition, if you believe other personal information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section of this Privacy Notice. If we deny an access request, we will notify you of the reasons for the denial.

Links to Other Websites

Our websites may contain links to other sites for your convenience and information. These sites may be operated by companies not affiliated with EveryMarket. Linked sites may have their own privacy notices, which you should review if you visit those websites. We are not responsible for the content of any websites not affiliated with EveryMarket, any use of those sites, or those sites’ privacy practices.

Data Transfers

This is a U.S. website subject to U.S. laws, including those governing the privacy and security of your information. When we obtain personal information about you, we may process the information outside of the country in which you are located, including in the United States. The countries in which we process the information may not have the same data protection laws as the country in which you are located. We will protect your information as described in this Privacy Notice.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to assist us in protecting the personal information we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we use Secure Sockets Layer encryption to protect certain of your purchase information while in transit.

Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.

To further protect yourself, you should safeguard your EveryMarket account user name and password and not share that information with anyone. You should also sign off your account and close your browser window when you have finished your visit to our sites. Please note that we will never ask for your EveryMarket  account user name or password via email.

Children’s Privacy

EveryMarket does not direct its websites to children under the age of thirteen. We require registered users of the site to be at least eighteen years old. If we learn that a user is under eighteen years of age, we will promptly delete any personal information that the individual has provided to us.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. EveryMarket permits California residents to opt out of having their information shared with third parties for direct marketing purposes. To opt out, please contact us.

Safe Harbor Statement

EveryMarket recognizes that the European Union ("EU") and Switzerland have implemented omnibus data protection regimes established pursuant to the European Data Protection Directive (95/46/EC) and the Swiss Federal Act on Data Protection, respectively. Among other things, these laws require "adequate protection" for the transfer of certain individually identifiable data about individuals in EU member countries and Switzerland to EveryMarket's operations in the United States of America ("U.S."). EveryMarket complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information from EU member countries and Switzerland. EveryMarket has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program and to view EveryMarket’s certification, please visit www.export.gov/safeharbor/.

Updates to this Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Notice and indicate at the bottom of the notice when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update the information we have about you or your preferences, please contact us by email at cs@everymarket.uk.

Effective Date: June 30, 2020