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SHOP CASHMERE "FUR" COLLECTION

SHOP CASHMERE "FUR" COLLECTION

PRIVACY POLICY

Your privacy is a priority for the Ten Townsend website, operated by Ten Townsend, LLC (hereinafter referred to as “Ten Townsend,” “us,” or “we”), located at www.tentownsend.com (hereinafter referred to as the “Site”), and we want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device and that enable your identification (“Personal Information”). This Privacy Policy describes our practices with information that we (or our service providers) collect from a user (sometimes referred to as “you” or “your”) through the Site.

This Privacy Policy is incorporated into Ten Townsend’s Terms and Conditions by reference, as if set forth fully therein. By using the Site, you agree and consent to the Terms and Conditions and our processing of your Personal Information in accordance with this Privacy Policy.

Ten Townsend can be contacted at clientservices@tentownsend.com.

1. COLLECTION OF PERSONAL INFORMATION FROM USERS

When you interact with us through the Site, we may collect information from you as described below.

a. Information You Provide

We collect Personal Information that you knowingly choose to submit through the Site in order to benefit from specified features, place orders for retail items, or participate in certain activities, such as information that you knowingly provide when you contact us through the “Contact Us” or “Create an Account” portions of the Site. For example, if you order and purchase a Ten Townsend retail item, you may provide us with information such as your name, telephone number, and email address.

We may combine information you submit through the Site with other information we have collected from you, whether on-line or off-line. We treat the combined information in accordance with this Privacy Statement.

b. Passive Information Collection, Use, and Choices

Also, as you navigate the Site, certain Personal Information may be passively collected, meaning it is gathered without your actively providing it. This is done using the following techniques in the following ways:

IP Addresses: An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our Site, we may view the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what geographic regions our website visitors come. We also may use this information to enhance our Site.

Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.

Cookies: Like many companies, our Site may use “cookies” to help make sure the Site is meeting the needs of its users and to help us make improvements. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies set by us on the Site to tell us, for example, whether you have visited us before or if you are a new visitor, for payment processing purposes, and to allow access to our proprietary platform. We use third-party cookies set by our service providers to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site.

You can refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited.

You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies.

Changing your internet browser settings can prevent the use of cookies. Each browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how. Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers. You will also find details of how to delete cookies from your computer and other general information about cookies.

We do not track your behavior across third party websites. Our Site currently does not respond to “Do Not Track” (DNT) signals and we operate as described in this Privacy Policy whether or not a DNT signal is received, as there is no consistent industry standard for compliance.

c. Sensitive Information

We ask that you not send or otherwise disclose to us through the Site your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. Where you provide us with such information, we reserve the right to erase any such information at our discretion.

d. Information About Minors

The Site is not intended for persons under the age of 18. We do not knowingly collect Personal Information online from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.

2. HOW WE USE THE INFORMATION WE COLLECT

We use Personal Information submitted by you or otherwise collected through the Site and through other sources for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Generally, we use the information you provide to us for the reason for which it was provided. For example, if you sign up for our mailing list, we will contact you by email.  Specifically, we may use Personal Information from or about you:

i. to respond to your inquiries and fulfill your requests;

ii. to fulfill and manage purchases, orders, payments, returns/exchanges, or requests for information, or to otherwise serve you;

iii.  if you provide Personal Information in order to obtain access to or use the functionality of a part of the Site, we will use your Personal Information to provide you with such access or functionality;

iv. to send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies, and other administrative information;

v. to notify you about upcoming events that may be of interest to you;

vi. to promote our services, and the services of our affiliates; and

vii. for our business purposes, such as data analysis, audits, recordkeeping, developing new products or services, enhancing the Site, improving our services, identifying Site usage trends, and personalizing your experience on the Site.

We may use any information that does not personally identify you, your computer, or your device, for any purpose.

3. OUR DISCLOSURE OF YOUR INFORMATION

Ten Townsend does not sell your Personal Information. We may share your Personal Information with third parties only as described in this Privacy Policy or as otherwise described at the point where we collect the information from you, including:

i. to our affiliates for the purposes described in this Privacy Policy; or

ii. to the companies or individuals that we hire to provide services to us, such as website hosting services;

iii. to a third party in the event of any reorganization, 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 proceedings); and

iv. to a third party at your request, or if you consent to the disclosure.

Note that, if you choose to make an online purchase through our website, your payment will be processed by Shopify Inc. (“Shopify”), a third-party company that specializes in processing online payments.  Since we use Shopify’s payment processing service, we will only see minimal details about your credit or debit card (such as the last 4 digits); however, your complete payment information will be available to Shopify. Please see their privacy policy at https://www.shopify.com/legal/privacy for more information about how they process and use your Personal Information.

4. USES AND DISCLOSURES TO COMPLY WITH LAWS

In addition, we use and disclose Personal Information collected through the Site as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

5. LINKS TO THIRD PARTY SITES

The Site may contain links to other Web sites for the convenience of users in locating information, products, or services that may be of interest. If you access a third party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. Ten Townsend is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. Ten Townsend does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

6. WHERE YOUR INFORMATION IS PROCESSED

Ten Townsend is based in the United States. No matter where you are located, you consent to the processing and transfer of your Personal Information in and to the United States and other countries.  The laws of the United States and other countries governing data protection may not be as comprehensive or as protective as the laws in the country where you live.

7. SECURITY

Ten Townsend will take reasonable steps to protect the information collected and provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  However, you should understand that no transmission over the Internet is ever fully secure. Also, Ten Townsend uses reasonable efforts to ensure that the Site is generally available. However, there will be occasions when access to the Site will be interrupted or unavailable. Ten Townsend will use reasonable efforts to minimize such disruption where it is within its reasonable control. You agree that Ten Townsend shall not be liable to you for any modification, suspension or discontinuance of the Site.

8. DATA RETENTION

We generally retain Personal Information for so long as it may be relevant for the purposes identified in this Privacy Policy or at the time the information is collected, unless a longer period of time is required by law.

9. LAWFUL BASES FOR PROCESSING YOUR PERSONAL INFORMATION

The laws in some countries require us to tell you about the lawful grounds we rely on to collect, use, disclose, and otherwise process your Personal Information. To the extent those laws apply, our lawful bases for processing your Personal Information are:

i. to enter into and perform a contract with you: We may process Personal Information to meet our contractual obligations to you, or to take steps in anticipation of entering into a contract. For example, we process Personal Information on this basis to create an account or process retail orders.

ii. to comply with a legal obligation: We need to use and disclose Personal Information in certain ways to comply with legal obligations or legal processes, respond to requests from government and other public authorities, and to pursue available remedies or limit damages we or other third parties may sustain.

iii.  for our legitimate interests, where those interests are not overridden by your fundamental rights and freedoms:  In many cases, we handle Personal Information because it furthers our legitimate business interests. This includes:

Providing a safe user experience on our Site; customer service; sending communications to you to let you know about information you have told us is important to you; protecting users, our workers, and our property; analyzing and improving our operations (e.g., optimizing the design and operation of our Site); and, managing legal issues.

iv. with your consent: Where permitted by law, we handle Personal Information on the basis of your implied or express consent. If we are using your Personal Information on the basis of consent, you may withdraw your consent at any time (which will not affect the lawfulness of the processing before consent was withdrawn) by emailing us atclientservices@tentownsend.com.

Also, this Privacy Policy is issued on behalf of Ten Townsend as controller of your Personal Information under applicable data protection laws. A “controller” is the person or organization who alone or jointly determines the purposes for which, and the manner in which, any Personal Information is, or is likely to be, processed.

10. YOUR DATA RIGHTS AND CHOICES

You can unsubscribe from certain emails by clicking on the “unsubscribe” link they contain. You can opt-out of the use of certain cookie-related processing by following the instructions in Section 1(b) above (Passive Information Collection, Use, and Choices).

The laws in some states and countries may give you particular rights with respect to your Personal Information, including the right to access the Personal Information that we maintain, and the right to object to certain processing of Personal Information by Ten Townsend. If you would like to submit a data access, correction, restriction, or deletion request, or if you would like to object to certain processing, you can do so by contacting us by email at clientservices@tentownsend.com and we will process such request with respect to any Personal Information that we are able to link to you individually based on the information that you can provide to us. These rights and options that you have with respect to Personal Information are subject to limitations and exceptions under applicable law. In addition to those rights, if you live in certain jurisdictions, you have the right to submit a complaint to your relevant supervisory authority. However, we encourage you to contact us first by emailing clientservices@tentownsend.com  and we will try to resolve your concerns.

THE CALIFORNIA CONSUMER PRIVACY ACT

When we collect personal information from California residents we become subject to, and those residents have rights under, the California Consumer Privacy Act or “CCPA”. This section of our statement is used to allow us to fulfill our CCPA obligations and explain your CCPA rights. For purposes of this section, the words “you” and “your” mean only such California residents.

What did we collect from California Residents?

We collect the following categories of personal information: identifiers such as name, address, IP address, and other similar identifiers; personal information described in subdivision (e) of Section 1798.80 (California customer records statute) such as a name, address, telephone number, credit card number; commercial information such as products or services purchased; internet/electronic activity such as browsing history and search history; geolocation data including geographic coordinates/physical location; and audio, video, electronic or other similar information.  We have disclosed these categories of personal information for a business purpose within the last 12 months (see “Our Disclosure of Your Information” above for information about the categories of third parties with which personal information is shared, and “How We Use the Information We Collect” for information about the business purposes for which personal information is used). We do not sell, and within the last 12 months have not sold, personal information to third parties. We obtain the personal information collected from the following categories of sources: directly from you or your agent; directly and indirectly from the Site; from affiliates or third parties that interact with us; and/or from publicly available information.

Rights of California Residents

In summary, you have the following rights under the CCPA: disclosure, access, correct and delete, subject to certain exceptions. More information can be found here. It’s important to us that you know that if you exercise these rights, we will not “discriminate” against you by treating you differently from other California residents who use our sites and mobile resources or purchase our services but do not exercise their rights. You can exercise these rights up to two different times every 12 months. To do so, just contact us at clientservices@tentownsend.com or 877-836 8696.  We may ask you to fill out a request form. The CCPA only allows us to act on your request if we can verify your identity or your authority to make the request so you will also need to follow our instructions for identity verification. Only you or a person that you authorize in writing to act on your behalf may make a verifiable consumer request related to your personal information. You (or your authorized agent) must provide documentation signed by you demonstrating that an agent is authorized to submit a verifiable consumer request on your behalf

If you make a verifiable request per the above, we will confirm our receipt and respond in the time frames prescribed by the CCPA.

In other jurisdictions, with similar data privacy regulations, we may collect from you the categories of personal information already described. We collect and manage (including disclose) such data in compliance with applicable local law(s). As noted, we do not sell any of your personal information to third parties nor do we use it for automated decision making.

11. RIGHT TO CHANGE PRIVACY POLICY

Ten Townsend reserves the right at any time to modify, alter, or update this Privacy Policy. Your use of the Site following any changes means that you agree to follow and be bound by the Privacy Policy as changed, subject to limitations under applicable law. Any change to this Privacy Policy shall be effective as to any user who has visited the Site before the change was made. Please review this policy periodically, and especially before you provide any Personal Information to us. The Privacy Policy was last updated on the date indicated below.

12. CONTACTING US

Please feel free to contact us if you have any questions or concerns about this Privacy Policy or our information practices. You may contact us as follows:

clientservices@tentownsend.com

or

Ten Townsend
Attn: Legal & Compliance Department
506 2nd Ave., 20th Floor
Seattle, WA 98104

Last Updated: January 1, 2022