PRIVACY POLICY

Last updated October 30, 2018

The Peebles Corporation (“Peebles,” “us,” our” or “we”) is committed to protecting your privacy.  Our privacy policy, which applies to all users of our Website and Service, is designed to explain the information we collect and how we use it to provide our services and give users a better experience (“Privacy Policy”).  Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use.  This Privacy Policy is part of, and incorporated into, the Terms of Use.

By accessing and using the Website and/or Service, you consent to our collection, storage, use and disclosure of your personal information and other information as described in this Privacy Policy.  

1.         Types of Information We Collect

We collect both “Personal Information” and “Anonymous Information” about our users. Personal Information is information that can be used to contact or identify you, such as your full name and email address, as well as information that is linked to such information. Anonymous Information is information that cannot be used to contact or identify you and is not linked to information that can be used to do so.  It includes passively collected information about your activities on the Website and Service, such as usage data, to the extent that information is not linked to your Personal Information.

Website visitors can access and browse a majority of the Website without disclosing Personal Information, although, like most website providers, we passively collect certain information from your devices, such as your IP address, browser information and/or unique device identifier (“UDID”). 

a.         Voluntarily submitted information

We collect information that you voluntarily provide to us during your use of the Website and/or Service, including when you reach out to us via the Contact Us form.

b.         Information collected via technology

·       We may collect information from your use of the Website and Service, including your hardware model, browser type, operating system, Internet Protocol (IP) address and domain name.  If you are using a mobile device, Peebles may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use tools such as cookies to gather information as well. “Cookies” are small pieces of information that a website sends to your device while you are viewing the website.  

 

·       We use third party services, such as Google Analytics, to track and analyze online behavior data of Users.  We do this to better understand how you use the Website and Service, with a view toward offering improvements for all Users, and to tailor our business and marketing activities accordingly.  If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en.  Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.

2.         How We Use Your Information

a.         Personal Information

We may use your Personal Information for the following representative purposes:

·       Respond to messages you’ve sent us via the Contact Us form

·       Send communications and administrative emails

·       Send you promotional/marketing information, newsletters, offers or other information

·       Improve the quality of the Website and Service and perform internal operations, including fraud detection

·       Analyze, benchmark and conduct research on user data and interactions with the Service

b.   Anonymous Information

We may use Anonymous Information for the following representative purposes:

·       Perform internal operations on the Website

·       Improve the Website and Service and customize the user experience

·       Aggregate the information collected via Google Analytics to use in statistical analysis to help us track trends and analyze patterns

3.         How We Share and Disclose Information

We know how important it is to keep your information confidential. We will not rent, sell or share your Personal Information with third parties except as specifically approved by you at the time of disclosure or under the circumstances described in this Privacy Policy. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Website or provide your Personal Information at any time.

In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information.

a.         Service Providers 

We share Personal Information with vendors, consultants and other third party service providers who perform services on behalf of - and at the request of - Peebles, including without limitation, companies that provide email services and host the Website and Service. Peebles has selected companies who maintain high standards with respect to privacy and agree to use the Personal Information only to perform specific services on behalf of Peebles and in accordance with the terms and conditions of this Privacy Policy.

b.         Compliance with Laws, Law Enforcement and Safety

We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend Peebles’, or a third party's, rights or property. 

c.         Anonymous information

Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties.

d.         Business transactions

We may share all or some of your Personal Information with any of our subsidiaries, joint venturers, or other companies under common control, in which case we will require them to honor this Privacy Policy.  Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Privacy Policy.

4.         Your Choices

By submitting Personal Information, you consent to receive certain communications from us. You may modify or opt out of receiving messages sent for marketing purposes, or certain other communications, by following the unsubscribe instructions in such messages. Please note that despite any indicated marketing preferences, we may send you administrative emails regarding the Website or Service, including, for example, notices of updates to our Privacy Policy.

5.         Updating Your Personal Information

You may revise your Personal Information by contacting us directly at TValentin@peeblescorp.com. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from our active database, but may remain in our archives. We may retain your information for fraud detection or similar purposes. Note that if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures. 

6.         Children

This Website is not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13.  If we later obtain actual knowledge that a User is under 13 years of age, we will take steps to remove that User’s Personal Information from our systems.  If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at TValentin@peeblescorp.com so that we may delete and remove such information from our system.

7.         Security and Data Retention

We are very concerned with safeguarding your information. We employ all reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email and/or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. Your consent to such purpose remains valid after termination of our relationship with you.

8.         Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out.  Your continued use of the Service after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly.

9.         California Privacy Rights

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at TValentin@peeblescorp.com.

10.       Contact Us

If you have any questions regarding our Privacy Policy, you can contact us via email at TValentin@peeblescorp.com or write to us at The Peebles Corporation, 7 World Trade Center, 46th Floor, New York, NY 10007.