Effective Date: August 12, 2025
Welcome to our political action campaign (the “Campaign,” “us,” “we,” or “our”) website, which is owned, operated, and controlled by ITG Brands, LLC (“ITGB”). This Privacy Policy applies to your use of our websites (including www.votersfortobaccofreedom.org), and to other information we collect online (together, our “Service”). If you are an employee, job applicant, or if we collected your Personal Information in the context of your employment at another business and you have questions about how we use your Personal Information, please contact us as provided below.
Please read our Privacy Policy and Terms of Use carefully before using the Service. By using the Service or otherwise providing Personal Information to us, you agree to the Service’s Terms of Use and consent to the Campaign’s data collection, use, and disclosure practices and other activities as described in this Privacy Policy. If you do not agree, please discontinue use of the Service.
Contents
Personal Information We Collect & Why We Collect It
How We Collect Your Personal Information
Information Collected Automatically
Information We Collect from Other Sources
How We Disclose Personal Information
Your Choices About Tracking & Communications
Cookies and Tracking Technologies
Analytics and Advertising Technologies
Personal Information We Collect, Why We Collect It, and How We Disclose It
Selling and Sharing for Targeted Advertising
Making a Privacy Rights Request
Additional Disclosures for California Consumers
Personal Information We Collect & Why We Collect It
“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes “Personal Data” as defined in certain privacy laws. Personal Information does not include information that is publicly available, de-identified, or aggregated.
The chart below summarizes the types of Personal Information we collect and why we collect it. These examples may vary depending on the nature of your interactions with us. The Campaign may use your Personal Information for any purposes not inconsistent with the Campaign’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including the purposes listed below.
| CATEGORY OF PERSONAL INFORMATION | PURPOSE(S) FOR COLLECTION |
| Contact Information and Identifiers, including real name, alias, account name, username, driver’s license number, signature, social security number, state identification number, postal address, unique personal identifier, online identifier, IP address, email address, telephone number, or other similar identifiers | To allow you to participate in the features we offer To maintain your accounts with us To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback To send you marketing materials and advertisements To recognize you when you use our services To show you relevant ads while you browse the internet or use social media To send you relevant coupons To allow you to participate in promotions, sweepstakes, contests, and rewards programs For auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes To detect and prevent fraud against you and/or us For litigation and other legal and regulatory requirements |
| Commercial Information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | To allow you to participate in the features we offer To provide you with appropriate products and recommendations To help you find relevant products more quickly To tailor our communications to you To provide customer service and support To send you relevant coupons To allow you to participate in promotions, sweepstakes, contests, and rewards programs To improve our services, and our products, marketing and advertising For auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To detect and prevent fraud against you and/or us |
| Demographic Information and Characteristics of Protected Classifications under State or Federal Law, including age, birth date, gender, languages spoken, marital status, and racial or ethnic origin | To allow you to participate in the features we offer To send you relevant marketing materials and advertisements To tailor our communications to you To improve our services, and our products, marketing and advertising For auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes To detect and prevent fraud against you and/or us For litigation and other legal and regulatory requirements |
| Internet or Other Electronic Network Activity Information, including internet or other similar activity, browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, social media account information or advertisements | To allow you to participate in the features we offer To provide you with appropriate products and recommendations To help you find relevant products more quickly To tailor our communications to you To provide customer service and support To send you relevant coupons To allow you to participate in promotions, sweepstakes, contests, and rewards programs To improve our services, and our products, marketing and advertising For auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes To detect and prevent fraud against you and/or us |
| Geolocation Data, including your physical location based on information you provide directly or that is inferred from your IP address | To allow you to participate in the features we offer To deliver coupons to you For auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To determine availability of products in your area and/or for shipping information To provide or restrict content specific to your location |
| Audiovisual Information, including audio recordings of customer care calls, video, or similar information | To provide you with customer service To improve our products and services For litigation and other legal and regulatory requirements |
| Communications with Us, including the contents of your communications with us via phone, email, text message, chat, or other means (such as survey responses, product reviews, and comments on our blog and social media pages) | To communicate with you about our products and services, your orders, and to provide customer service and support To improve our Service, products, and marketing To allow you to participate in our promotions, sweepstakes, contests, and loyalty programs To detect and prevent fraud against you and/or us For litigation and other legal and regulatory requirements |
| Inferences About You from Any Other Category of Information We Collect, including information reflecting your preferences, characteristics, trends, or attitudes | To provide you with appropriate products and recommendations To improve our services, and our products, marketing and advertising To provide you with a better Service experience For auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes To detect and prevent fraud against you and/or us |
We may collect, use, and disclose Personal Information for valid business purposes or in connection with threatened or pending litigation consistent with applicable laws.
We may use and disclose Personal Information for any purpose if it is publicly available, deidentified, or aggregated with other information so that it can no longer identify you, as defined by applicable law. If we use Personal Information in deidentified form, we will not attempt to reidentify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements.
How We Collect Your Personal Information
We collect your Personal Information through various means, including when you directly provide it to us and automatically through your use of our Service. We may also collect Personal Information about you from our vendors and from other parties. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use features of our Service.
Information that You Provide
We collect Personal Information about you directly when you:
- Register or maintain an account with us
- Enter search terms or other information through our Service
- Subscribe to receive our notifications
- Exchange communications with us by mail, email, phone, etc.
- Post comments to our online communities
- Obtain customer service or technical support
- Participate in promotional activities (coupons, special offers, sweepstakes, loyalty programs, rewards, surveys, contests, etc.)
- Post reviews or other information about our products or Services
- Connect with us via social media
Information Collected Automatically
The Campaign and/or our vendors may also automatically collect Identifiers and Internet or Other Electronic Network Activity Information about you when you access or use our Service (“Usage Information”). Usage Information may include your IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computers or mobile devices), the domain name of the website that allowed you to navigate to the Service, search engines used, the length of time spent on the Service, the pages you looked at on the Service, the address (or “URL”) of the websites you visited before and after visiting the Service, the frequency of your visits to the Service, and certain other available information. The methods we use to collect Usage Information include:
- Log Files. Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which may be collected and stored in log files.
- Cookies. Cookies are small files that a website transfers to your device through a web browser that enable the site’s or a vendor’s systems to recognize your device and to collect certain information. Cookies vary in how long they last. “Session cookies” terminate shortly after you terminate your internet session. “Persistent cookies” are stored on your device until a set expiration date. We use session cookies, persistent cookies, and other tracking technologies (such as web beacons, discussed further below) to collect information about your interactions with our website, including information about your browsing behavior. Our website may also support third-party cookies.
- Web Beacons/Tracking Pixels. Web beacons/tracking pixels are small graphic images (also known as “Internet tags,” “clear GIFs,” or “Pixel Tags”) embedded in web pages and email messages which may be used to count the number of visitors to the Service, to place cookies, to monitor how users navigate the Service, and to count content and advertising views.
- Embedded Scripts. An embedded script is website code that runs automatically when you load a webpage and is designed to collect information about your interactions with the webpage. It is active only while you are connected to the Service.
- Location-Identifying Technologies. Geo-filtering and other location-aware technologies may make assumptions about your location from your IP address for purposes such as verifying your location (e.g., for shipping), or restricting/providing content based on your location. Content on our Service may also be personalized based on location so we can provide you with more location-relevant content.
- Device and Activity Monitoring. We may use technologies that monitor and record certain of your interactions with the Service, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as accessibility, identification, security, fraud prevention, troubleshooting, tracking and/or improving the Service and customizing or optimizing your experience on the Service.
In general, our Service uses information collected automatically as follows:
- Where necessary to run our Service, for example by allowing you to log in.
- To optimize the functionality of our Service, including by personalizing content for you, greeting you by name, and remembering your preferences (e.g., your choice of language or region).
- For analytics purposes—for example, to help us understand how our website is used, to see what products most interest you, and determine how best to market our products to you. More information on website analytics is provided below.
- For purposes of ad targeting and marketing to collect information about your browsing behavior on our Service to show you interest-based advertising when you visit other websites or use social media.
- To determine if you open or act upon our email messages. Information on unsubscribing from our commercial email communications is provided below.
- To obtain information about your interactions with our online advertisements, such as whether you clicked on an ad and the website where you may have seen the ad.
Information We Collect from Other Sources
The Campaign may also obtain information about you from other sources, including our vendors. We also may obtain your Personal Information from our parent, subsidiary, and sister companies. In some circumstances, we obtain Personal Information about you from other parties, including business partners, resellers, and data brokers, some of which may sell the information to us. To understand your rights and choices regarding Personal Information collected by other companies, please consult the privacy policies of the businesses that you interact with.
How We Disclose Personal Information
We may disclose your Personal Information for any purposes not inconsistent with this Privacy Policy, our written statements at the point of collection, or applicable law. In general, we disclose Personal Information as follows:
- Within our group of companies including with our affiliates, subsidiaries, locations, and brands.
- With our agents, vendors, consultants, and other business providers for them to provide their services to us, including to provide customer service, improve our products and customer service, help run our promotions (including coupons and rewards programs), process payments, perform auditing and quality control, communicate with you, and otherwise operate and improve our business and the Service.
- With our business partners, includingfor co-marketing purposes, to improve our products and services, or to provide you with other products and services that may interest you.
- With our advertising and data analytics partners, including for the purposes of ad targeting, remarketing, and customized advertising content.
- To third parties, as necessary, for the following purposes: to comply with any legal process, law, regulation, or court order; to respond to requests from public and government authorities; to enforce our terms and conditions; to protect our operations and protect our rights, privacy, safety, or property, and/or that of you or others; to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a threatened or pending case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel; in connection with disciplinary actions/investigations; and to allow us to pursue available remedies or limit the damages that we may sustain.
- With our insurers and professional advisers, including for the purposes of managing risks, obtaining professional advice, and exercising or defending against legal claims.
- With other businesses in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).
- When you direct us to disclose your Personal Information, including when you direct us to provide your Personal Information to a business partner to determine product availability in your area, to facilitate delivery of a purchase, or to complete a transaction. Please note that when you direct us to disclose your Personal Information to a business partner under these circumstances, your Personal Information is subject to the privacy policies and privacy notices of that party. The Campaign has no control over the privacy practices of third parties and we encourage you to review their privacy policies before using their services.
Social Features
Certain functionalities on the Service permit interactions that you initiate between the Service and certain other services, such as social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and another’s service; “liking” or “sharing” the Campaign’s content; logging in to the Service using your social media account; and to otherwise connect the Service to another service (e.g., to pull or push information to or from the Service). If you use Social Features, information you post or provide access to may be publicly displayed on the Service or by the social media service that you use. Similarly, if you post information on a social media service that references the Service (e.g., by using a hashtag associated with the Campaign or one of our brands in a tweet or status update), your post may be used on or in connection with the Service or otherwise by the Campaign and/or our affiliates. Also, both the Campaign and the social media service may have access to certain information about you and your use of the Service and any social media service.
Analytics
Our website uses analytics technology provided by our vendors to understand how users interact with the site, improve our web experience, and better market our products. Analytics services in use on our website include Google Analytics. These analytics services use cookies and other Tracking Technologies to collect information about how you use the Service. Personal Information collected by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these providers on servers in the U.S. (or elsewhere). See below for more information on your choices regarding analytics services.
Your Choices About Tracking & Communications
Cookies and Tracking Technologies
Our website offers a cookie preference center that allows you to exercise your choices on these technologies. You may access the cookie preference center by clicking “My Privacy Choices” in the footer of our webpages. Cookies may also generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Please review your browser’s Help menu for instructions or visit www.allaboutcookies.org for more information. Please note that if you disable all cookies, some features of our Service may not function properly.
Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. We do, however, respond to the Global Privacy Control (“GPC”) signal for California residents wishing to opt-out of the “sale” or “sharing” of their Personal Information.
Analytics and Advertising Technologies
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. We also use advertising services provided by Google Ad Services, such as remarketing with analytics and interest-based ads. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to, e.g., deliver advertisements, measure your interests, and/or personalize content. For more information on how Google Analytics uses data collected through our services, visit http://www.google.com/policies/privacy/partners. To opt out of Google Analytics cookies, visit https://tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-Out Browser Add-On.
You may choose not to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and providers that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or the Network Advertising Initiative (“NAI”). To learn more about how you can exercise certain choices regarding interest-based advertising, including use of cross-device data for serving ads, visit http://www.aboutads.info/choices/. To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that opting out only means that those selected members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).
Depending on your device settings, you may also opt out of certain interest-based advertising through the device’s “Limit Ad Tracking” or equivalent feature. Refer to your device for more information on what this opt out affects. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID.
In addition, we may serve ads on other online services that are targeted to reach people on those services who are also identified in one of more of our databases (“Matched List Ads”). This is done by using tracking technologies or by matching common factors between our databases and the databases of the other online services such as Facebook/Meta or Twitter. We are not responsible for these services, including without limitation the security of the data they hold about you. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, to find out what options Facebook offers you to control such ads. If we use Twitter Matched List Ads, you should be able to review your ad options in your account settings on Twitter.
The Campaign is not responsible for the effectiveness of any other parties’ opt-out options or the accuracy of their statements regarding their programs.
Email Communications
You may unsubscribe from our marketing email communications by clicking the “unsubscribe” link found in every commercial email we send, or by sending a request to unsubscribe to privacy@itgbrands.com. Unsubscribing from our marketing communications will not affect the level or quality of service we provide to you.
Text/SMS Messages
You may opt-in to receiving text messages and alerts on the mobile phone number(s) you provide to us. Once you opt-in, we may send you text messages (i) regarding your account; (ii) about our products and promotions (including advertisements, sales, and special offers); (iii) to investigate or prevent fraud; and (iv) to alert you in the event of an issue with any of your purchases. You do not have to opt-in to text messages and alerts to use and enjoy our Service or products. If you opt-in, standard text messaging charges may apply. You may choose to opt-out from our text messages and alerts at any time. For more information regarding our text messaging and alerts, please contact us at privacy@itgbrands.com or 1 (888) 342-6567.
Security & Passwords
We take commercially reasonable measures to protect Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and electronic storage are not completely secure, and the Campaign cannot guarantee the security of your Personal Information. You are responsible for maintaining the secrecy of any credentials used to access your account with us. If you suspect any unauthorized activity associated with your account, please report that activity to us immediately.
Age Restrictions
The Service is intended for adults not less than twenty-one (21) years of age, and our website uses age-verification to exclude under-age individuals. If you are under twenty-one (21) years of age, you are not permitted to use the Service and should not send any Personal Information to us. The Campaign does not knowingly collect Personal Information as defined by the Children’s Online Privacy Protection Act (“COPPA”). If we learn that we collected Personal Information in a manner not permitted by COPPA, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with Personal Information, please contact us by email at privacy@itgbrands.com.
Nevada Privacy Notice
Nevada law allows residents to opt out of the sale of certain Personal Information, called “covered information.” At the Campaign, we do not sell covered information as defined under Nevada law and we have no plans to change that practice. If you want to be notified if we do change that practice, you may submit your request through our webform.
State Consumer Privacy Notice
This State Consumer Privacy Notice (“State Notice”) supplements this Privacy Policy and provides additional information for residents of states with comprehensive privacy laws, including California (each, a “Covered State”). This State Notice applies to Personal Information we collect from Covered State residents through our Service and in other contexts, including offline.
California residents who apply for jobs with the Campaign should review our California Applicant Privacy Notice.
Personal Information We Collect, Why We Collect It, and How We Disclose It
We may obtain the Personal Information listed in the “Personal Information We Collect & Why We Collect It” section above from offline sources as well, including from the following sources:
- Directly from you. For example, when you sign up to receive information from us, when you place an order, or any other time you submit Personal Information to us voluntarily.
- Other parties. For example, we may receive Personal Information from service providers who provide us with IT services, advertising services, or help facilitate our sales.
In addition to the types of Personal Information listed in the “Personal Information We Collect & Why We Collect It” section above, we may collect the following categories of Personal Information from online and offline sources:
| CATEGORY OF PERSONAL INFORMATION | PURPOSE(S) FOR COLLECTION |
| Professional or Employment-Related Information If you are a ITGB employee who is a California resident, please contact Human Resources for additional disclosures. Job applicants who are California residents can find additional disclosures here. | For litigation and other legal and regulatory requirements |
| Non-Public Education Information, including school(s) attended and degrees obtained | For litigation and other legal and regulatory requirements |
| Personal Records (including Personal Information described in Cal. Civ. Code § 1798.80(e)), including name, address, telephone number, state identification card number, and bank account number, credit card number, debit card number, or other financial payment information Some Personal Information included in this category may overlap with other categories | To allow you to participate in the features we offerTo maintain your accounts with usTo communicate with you, including about our products, updates to our terms and policies, and to obtain your feedbackTo send you marketing materials and advertisementsTo recognize you when you use our servicesTo show you relevant ads while you browse the internet or use social mediaTo send you relevant couponsTo allow you to participate in promotions, sweepstakes, contests, and rewards programsFor auditing, research and analysis, to maintain and improve our services, and for any other internal business purposesTo detect and prevent fraud against you and/or usFor litigation and other legal and regulatory requirements |
| Social Security, Driver’s License, State Identification Card, or Passport Number This is considered Sensitive Personal Information or Sensitive Data under certain Covered State privacy laws | To allow you to participate in the features we offerTo maintain your accounts with usTo communicate with you, including about our products, updates to our terms and policies, and to obtain your feedbackTo send you marketing materials and advertisementsTo recognize you when you use our servicesTo show you relevant ads while you browse the internet or use social mediaTo send you relevant couponsTo allow you to participate in promotions, sweepstakes, contests, and rewards programsFor auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes To detect and prevent fraud against you and/or usFor litigation and other legal and regulatory requirements |
| Personal Information that Reveals a Consumer’s Race This is considered Sensitive Personal Information or Sensitive Data under certain Covered State privacy laws | For product testingFor litigation and other legal and regulatory requirements |
| Personal Information Collected and Analyzed Concerning a Consumer’s Health This is considered Sensitive Personal Information or Sensitive Data under certain Covered State privacy laws | For litigation and other legal and regulatory requirements |
We disclose the above categories of Personal Information as described in the “How We Disclose Personal Information” section above.
Selling and Sharing for Targeted Advertising
We may share your Personal Information for cross-context behavioral or targeted advertising (“Targeted Advertising”). Targeted Advertising may be considered a sale under certain Covered State privacy laws. We may process your Personal Information for targeted advertising. To opt out, please use our webform .
We may sell or share for Targeted Advertising the following categories of Personal Information with advertisers and analytics vendors for the purposes of Targeted Advertising: Identifiers, Internet or Other Electronic Network Activity, and Geolocation Data. When we use the terms sell, sold, or sale, we mean for valuable consideration and not monetary value.
We offer you the ability to opt out of sales and sharing of your Personal Information for Targeted Advertising as set forth in the “Right to Opt-Out” section below.
We do not have actual knowledge that we sell or share the Personal Information of consumers under twenty-one (21) years of age.
Making a Privacy Rights Request
If you are a resident of a Covered State, you may have the right to submit certain requests relating to your Personal Information as described below, depending on your state of residence. To exercise any of these rights, please submit a request through our webform or call us at 1 (888) 342-6567. Please note that we may need to authenticate your identity before your request can be processed. For authentication, you may be asked to log into your account or to provide two-to-three (2-3) pieces of Personal Information that we will match against our records. Residents of certain Covered States may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. To submit a request as an authorized agent, please click here.
Right to Access, Confirm, and Data Portability. You may have the right to confirm whether we are processing your Personal Information, to access your Personal Information, and to obtain a copy of Personal Information you provided to us in a portable format. Residents of certain Covered States may also request details about third parties to which we have disclosed Personal Information.
Right to Correct. You may have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes for processing it.
Right to Request Deletion. You may have the right to request that we delete your Personal Information, subject to exceptions.
Right to Opt-Out of Sales and Targeted Advertising. You may have the right to opt out of sales and/or Targeted Advertising. To opt-out of Targeted Advertising and sales through tracking technologies, please update your settings in the cookie preference center . If you choose to use the Global Privacy Control (“GPC”) browser signal, you will only be opted out of online Targeted Advertising and sales, and will need to turn it on for each browser you use. To submit a request to opt out of offline sales and Targeted Advertising which would not otherwise be controlled by the cookie preference center or GPC, please use our webform.
Right to Opt-Out of Profiling. We do not process Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects.
Right to Appeal. Sometimes we are unable to process requests relating to your Personal Information, in which case, your request will be denied. If you are a resident of a Covered State whose privacy rights request has previously been denied by us and you believe we denied it in error, you may have the right to appeal for reconsideration of your request using our webform or by calling us at 1 (888) 342-6567.
Please note that if you make a privacy rights request, we will retain the Personal Information submitted in connection with your request for recordkeeping purposes.
Additional Disclosures for California Consumers
These disclosures apply to California residents, including pursuant to the California Consumer Privacy Act, as amended (the “CCPA”). Unless otherwise noted, the disclosures in this Privacy Policy cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
California Privacy Rights
California residents have the following privacy rights under the CCPA, in addition to applicable rights describe above:
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information was collected;
- Our business purposes or commercial for collecting, selling, or sharing Personal Information;
- The categories of recipients to which we disclose Personal Information;
- The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information;
- The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information; and
- The specific pieces of Personal Information we have collected about you.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
How Long We Keep Your Personal Information
The chart below shows how long we retain the categories of Personal Information we collect and maintain in the ordinary course of business. For each category, our retention period is determined by the purposes for which we use the information and any legal obligations that require us to retain it.
We generally retain the categories of Personal Information and sensitive Personal Information described below for as long as one of the following apply:
- Retention is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the Personal Information or sensitive Personal Information;
- Retention is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information or sensitive Personal Information was collected;
- Retention is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your Personal Information or sensitive Personal Information by applicable laws or regulations.
Where Personal Information or sensitive Personal Information is used for more than one purpose, it will be retained at least as long as the latest period provides. If collected, we may maintain Personal Information or sensitive Personal Information indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes.
| Category of Personal Information | Retention Period |
| Contact Information and Identifiers | Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including: active period plus six (6) years for records related to the purchasing of products or services;seven (7) years for records relating to accounting for money owed by customers; indefinite retention for record information related to customer incentive payments; andindefinite retention for applicable legal or regulatory holds. |
| Commercial Information | Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including: active period plus six (6) years for records related to the purchasing of products or services;seven (7) years for records relating to accounting for money owed by customers; andindefinite retention for record information related to customer incentive payments. |
| Demographic Information and Characteristics of Protected Classifications under State or Federal Law | Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including: indefinite retention for record information related to consumer demographics; andindefinite retention for applicable legal or regulatory holds. |
| Internet or Other Electronic Network Activity Information | We do not generally maintain this type of Personal Information, and our record retention schedule does not prescribe a retention period for it. |
| Geolocation data | Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including: seven (7) years for records relating to accounting for money owed by customers; andindefinite retention for information related to select marketing material. |
| Audiovisual Information | Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including: indefinite retention for record information related to consumer marketing activity; andindefinite retention for applicable legal or regulatory holds. |
| Communications with Us | Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including: indefinite retention for record information related to customer sales; andindefinite retention for applicable legal or regulatory holds. |
| Inferences | We do not generally maintain this type of Personal Information, and our records retention schedule does not prescribe a retention period for it. |
| Professional or Employment-Related Information | Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including: indefinite retention for record information related to consumer survey reports; andindefinite retention for applicable legal or regulatory holds. |
| Non-Public Education Information | We do not generally maintain this type of Personal Information, and our records retention schedule does not prescribe a retention period for it. |
| Personal Records (including Personal Information described in Cal. Civ. Code § 1798.80(e)) | Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including: active period plus six (6) years for records related to the purchasing of products or services;seven (7) years for records relating to accounting for money owed by customers; indefinite retention for record information related to consumer demographics; andindefinite retention for applicable legal or regulatory holds. |
| Social Security, Driver’s License, State Identification Card, or Passport Number | Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including: active period plus six (6) years for records related to the purchasing of products or services;seven (7) years for records relating to accounting for money owed by customers; and indefinite retention for record information related to consumer demographics; andindefinite retention for applicable legal or regulatory holds. |
| Personal Information that Reveals a Consumer’s Race | Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including: indefinite retention for record information related to consumer survey reports; andindefinite retention for applicable legal or regulatory holds. |
| Personal Information Collected and Analyzed Concerning a Consumer’s Health | Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including: indefinite retention for record information related to consumer survey reports; andindefinite retention for applicable legal or regulatory holds. |
California “Shine the Light”
Separate from your CCPA rights, you may obtain a list of the recipients to which we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for direct marketing purposes, if applicable. To submit a request, please email us at privacy@itgbrands.com or send a letter to us at 628 Green Valley Road, Suite 500, Greensboro, NC 27408-7018 (Attn: Legal Department). Requests must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mail address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
International Visitors
Our Service is directed solely to residents of the United States. If you access the Service from outside of the U.S., please be aware that Personal Information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any Personal Information to us constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. as set forth in this Privacy Policy.
Changes To This Policy
By using our Service, you consent to the terms of this Privacy Policy and our Terms of Use . We may change our Privacy Policy from time to time, as indicated by the “Effective Date” at the top of this Privacy Policy. Your use of our Service indicates your consent to the Privacy Policy posted at the time of use. We will notify you of material changes to this Privacy Policy as appropriate and required by applicable law, which may be through email or a website notification.
How To Contact Us
If you have any questions about this Privacy Policy, please contact us by email at privacy@itgbrands.com, by mail to 628 Green Valley Road, Suite 500, Greensboro, NC 27408-7018 (Attn: Legal Department), or toll-free by phone at 1 (888) 342-6567.
Oregon residents, please note that the controller of your Personal Information is ITG Brands, LLC.