WILTON PRIVACY POLICY

Updated and effective 27/06/2017

This privacy policy ("Privacy Policy") applies when you access, visit or use any of the websites, mobile applications, features, widgets or other online services that are owned and operated by Wilton Brands LLC or its affiliates or subsidiaries, including Wilton Brands International LLC (collectively, "Wilton," "we", "us" or "our") and post a link to this Privacy Policy (each a "Site" and collectively, the "Sites").  By accessing, visiting, using or submitting information to the Sites, you agree to the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Sites. Please also review our Terms and Conditions, which governs your use of the Sites, and which is accessible here

If you have questions about this Privacy Policy or the way we collect, use, process or share your information, please contact us at privacy@wilton.com. 

This Privacy Policy explains: 

1. Information Collected By Wilton.

2. Third Party Analytics Providers, Ad Servers, and Similar Third Parties.

3. Submission Features, Community Forums, and User Content.

4. Social Networking Features

5. Use of Information Collected By Us.

6. Sharing of Information with Third Parties.

7. Children.

8. Security.

9. Corrections/Information Removal/Opt-Out.

10. Closing Your Account; Retention of Information.

11. Third-Party Links & Content.

12. International Transfer of Personal Information.

13. Changes to the Privacy Policy.

14. Contact Information.

1. Information Collected By Wilton. Wilton gathers the following types of information:

A. Information You Directly and Voluntarily Provide to Us:

Wilton may ask you to provide “Personal Information” (i.e., information that identifies you as a specific, identifiable individual) when you visit our Sites. Personal Information may include, but is not limited to, name, email address, postal address, and phone number. If you register to use the Sites you may be required to submit Personal Information and create a user name and password. If you place an order through the Sites, you will be asked to provide your billing information, including without limitation payment card, PayPal or other financial account information. You may also be able to save your payment method in your profile which can be used for subsequent purchases and eliminate the need for you to repeatedly enter your payment information.We may also collect information that you provide to us when you communicate with any of our departments such as customer service, sales or technical services.

We may also collect non-Personal Information such as demographic information (i.e. age and gender), and information regarding the use of the Sites.  If we combine non-Personal Information with Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.  In some cases, we may render Personal Information (generally, email address) into a form of non-Personal Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests.

If you use an "email a friend" functionality on the Sites (for example, to provide information or send a gift certificate), we may ask you for that person's Personal Information (i.e. name and email address). If you provide your friend's name and email address as part of "email a friend" we will automatically send the friend an email from you and we do not add that email address to our database or use the email you provide to send any communication other than the email you send to your friend

If you do not provide us with the information that we request, we may not be able to provide you with the products and services offered through the Sites.

B. Information That We Automatically Collect From You: We or our Service Providers (defined below) (including any third-party content, advertising, and analytics providers) may automatically or passively collect certain information from you whenever you access or interact with the Sites (“Usage Information”) using tracking technologies such as "cookies"  and "web beacons."

Cookies and other forms of local storage are pieces of information (data files) transferred to a browser when a user visits a website. These technologies are able to store a unique identifier for a device to allow a certain Internet site to recognize the device whenever the device is used to visit the site. We may use these technologies for various purposes, including remembering information that will make your use of the Sites more convenient and to track the total number of visitors to our Sites on an aggregate basis. You can find more information about cookies and how they work at www.allaboutcookies.org.

Small graphic images or other web beacons (also known as “pixel tags,” “1x1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, to count visitors to the Sites, to monitor how users navigate the Sites, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

Usage Information may include

  • the areas you visit within the Sites;
  • the date and time of your visit to the Sites;
  • the websites or advertisement you visit before or after visiting the Sites;
  • the search terms you entered into a search engine that lead you to our Sites;
  • the Internet Protocol (IP) address, mobile device identifier, or other unique identifier (“Device Identifier”) for any computer, mobile phone, or other device used to access the Sites;
  • your computer and connection information such as your browser type and version, operating system and platform; and/or
  • whether you open an email and whether you click on any link contained in an email message that we send you.

You may be able to set your web browser to reject cookies or to notify you when you are sent a cookie. However, your web browser may not be able to refuse or remove flash cookies. A Flash cookie is a data file placed on a device via the Adobe Flash plug-in that may be built into or downloaded by you onto your device. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you set your browser to limit or remove cookies or to adjust your Flash privacy settings on your device, some features of the Sites may be unavailable or unable to function properly.

We will retain the information that we automatically collect from your computer only for as long as necessary to provide you with access to the Sites and our services, and to comply with our legal obligations, to resolve disputes and to enforce our rights. Information collected using cookies will normally only be retained for a one (1)-month period.

C. Information Received from Mobile Devices. When you access the Sites through a mobile device we, or third party Service Providers will receive and collect the device type and Device Identifier, as well as other Usage Information. We may use Usage Information to track your use of the Sites. If you access the Sites through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device's location services settings. For instructions on changing the relevant settings, please contact your mobile service provider or device manufacturer.

D. Information Third Parties Provide About You. We may receive information about you from third parties and we may supplement the information we collect with outside records in order to provide you with information, services, or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may interest you, and for other purposes. We may combine the information we receive from those other sources with information we collect through the Sites. In those cases, we will apply this Privacy Policy to the combined information.

2. Third Party Analytics Providers, Ad Servers, and Similar Third Parties.

Wilton works with (or may in the future work with) network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Sites (including pages viewed and the actions taken when visiting the Sites), to serve our advertisements elsewhere online, and to provide us with information regarding the use of the Sites and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Sites and other websites and services and may use this information to target advertising to you.

These service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you. Some of these parties may collect Personal Information over time when you visit the Sites or other online websites and services. Cookies and web beacons, including those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information, such as Usage Information and Hashed Information, with third-party advertising companies, analytics providers and other vendors for similar purposes.

3. Submission Features, Community Forums, and User Content. The Sites may provide you the opportunity to submit information to us, through interactive features, and through other communication functionality, including without limitation, product review or discussion forums ("Submission Features").  You may choose, through such features or otherwise, to submit or post “User Content” (which means any and all information and content that you submit or post to the Sites, including, without limitation, photos, audio, video, messages, text, files, or other content you provide us and as further described in our Terms and Conditions).

 Please note that certain information, such as your name, and/or state of residence, may be publicly displayed on the Sites along with your User Content. Your use of Submission Features is subject to our “Acceptable Use Policy” and other provisions of the Sites’ Terms and Conditions. Note that anything you submit through a Submission Feature may be made public – others will have access to your User Content and may use it or share it with third parties. We are not responsible for the actions of third parties and the use of your information and other User Content by such third parties is not subject to the protections of this Privacy Policy. Please see the "User Content" section of our Terms and Conditions, which contains important information about User Content that you submit to the Sites – including a license that you grant to Company and certain other parties in any such User Content. In accordance with that license, please be aware that, if you choose to submit User Content, we may use your User Content (or any excerpt therefrom) in connection with our advertising, marketing, publicity and promotional activities. That means that, among other things, it may be published online or offline.

 4. Social Networking Features. Functionality on the Sites may permit interactions that you initiate between the Sites and a third-party website or service such as Twitter or Facebook (“Social Networking Features”). Examples of Social Networking Features include enabling you to “like” or “share” content from the Sites or to “like” or “share” our page on a third-party service; to automatically or selectively show your social media posts/tweets on the Sites; to create a Wilton account or Wilton personal profile using existing login information from a social-network (known as a social login); and to otherwise connect the Sites to a third-party website or service. If you choose to share content or to otherwise post information through the Sites to a third-party site or service, or vice versa, that information may be publicly displayed. Similarly, if you post information on a third-party platform that references Wilton, for example, by using a Twitter hashtag associated with Wilton in your Tweet), your post may be published on the Sites in accordance with the terms of that third party. Also, both we and the third party may have access to certain information about you and your use of the Sites and the third-party site or service. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third-party website or service. If you choose to use a social login, we may collect Personal Information including your name and email address. The information we collect in connection with Social Networking Features is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party website or service.

5. Use of Information Collected By Us. We may use information collected, including Personal Information and Usage Information:  

(a) to enable you to use our Sites and its features, including fulfilling any transactions, orders or payments, and to process information you provide via our Sites, including verifying that your email address is active and valid;

(b) to communicate with you and, with your consent, send you information by email, postal mail, telephone or other means about our products, services, contests and (You may opt-out of receiving emails from us by contacting us in accordance with Section 10 below, or following the "unsubscribe" instructions in the applicable email); 

(c) to contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms and Conditions, or any of our other Wilton policies;

(d) to tailor content, recommendations, and offers we display to you, both on the Sites and elsewhere online and to analyze trends and statistics;

(e) to provide customer service, including responding to your questions, complaints, or comments and sending surveys and processing survey responses;

(f) for internal business purposes such as to improve our Sites, products, and services and to comply with regulatory and legal obligations;

(g) to assess your employment application for a position with Wilton (or an entity related to Wilton) and prepare related governmental and internal statistics reports; and

(h) for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

 

6. Sharing of Information with Third Parties. We may share non-Personal Information, including Hashed Information, Usage Information and aggregated user statistics, with third partiesfor the purposes described in this Privacy Policy or separately. We may share the information we have collected about you (including Personal Information): (i) as disclosed at the time you provide your information, (ii) with your consent, (iii) as described elsewhere in this Privacy Policy, or (iv) in the following circumstances:

  1. Service Providers: We may employ other companies or individuals ("Service Providers") to provide certain services to us or on our behalf, such as operating and supporting the Sites, processing payments and fulfilling orders you place through the Sites, analyzing data, or performing marketing or consulting services. For example, if you sign up to receive newsletters from us we may share your email address with a third party service provider who will send the newsletters to you on our behalf. We may give these Service Providers access to your information (including Personal Information) so that they can carry out the services they are performing for you or for us.  Unless otherwise indicated when the information is collected, information shared with Service Providers will be subject to this Privacy Policy. 
  2. When You Agree to Receive Information from Third Parties or Request That We Share Your Information: We do not share Personal Information with third parties for those third parties’ own direct marketing purposes unless we first provide you with the opportunity to opt-in to such sharing. You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared by opting-in,your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. We are not responsible for the privacy policies and practices of third parties.  We will not share any email or credit card information which you have given us with any third party for their own marketing purposes. In addition, if you would like us to stop providing your information to our third party marketing partners, you may opt-out by emailing us at privacy@wilton.com, sending a letter to Wilton Brands LLC, Attention: Chief Information Officer, 535 E. Diehl Road, Suite 300,  Naperville, IL 60563 or calling us at (630) 963-7100.
  3. Third Party Transaction-Level Data: If you visit the Sites from a third-party website the third-party website may be able to access select information from your individual transaction information. In order to track and credit your transaction the third-party website may give you a unique code, cookie or graphic which will uniquely identify you. This will only happen if you link directly from a third party website to the Sites. Any transactions made at the Sites while this type of code is active will be reported back to the third party website. We will only report information that does not identify you personally to these websites, such as the date of the transaction, the product(s) purchased and the amount spent. We will not report any information to these third party websites that will allow them to personally identify you. The presence of a third party navigation bar at the top of any page on the Sites is an indication that the third party website may be able to see your activity on the Sites.  
  4. Law Enforcement and Protection of Users: To the extent permitted by law, we will disclose your information to government authorities or third parties pursuant to a legal request, subpoena or other legal process. We may also use or disclose your information as permitted by law to perform charge verifications, report or collect debts owed, fight fraud or protect our rights or property as well as those of our affiliates or customers. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
  5. Sweepstakes, Contests, & Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's terms or official rules (such as on a winners list).
  6. Business Transfers and Transitions. Wilton may share your information, including Personal Information, with its subsidiaries, or affiliates, primarily for business and operational purposes. In the event that Wilton goes through a transition, such as being sold, has all or a portion of its assets acquired or transferred, whether voluntarily or involuntarily such as through bankruptcy, or merges or becomes affiliated with any other division, individual or entity (including, without limitation, during the course of any due diligence process), any customer information owned or under the control of Wilton (including your Personal Information) will likely be one of the transferred assets. We reserve the right, as part of this type of transaction, to transfer or assign your information (including Personal Information) and other information we have collected from users of the Sites. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent, to the extent permitted by law.

7. Children. The Sites are intended for a general audience. We do not knowingly collect information from children younger than the age of 16. 

8. Security. The Sites take commercially reasonable steps to secure information.  For example, within our checkout process, information is encrypted using SSL (Secure Socket Layer) technology to help protect the communications between our computer and yours. No computer system is fully secure, however, and there are inherent risks associated with Internet transactions. You use the Sites and submit information to us at your own risk.

9. Corrections/Information Removal/Opt-Out. If your name, email or postal address, telephone number or other information changes, you may update, correct or delete the relevant information by contacting us at privacy@wilton.com. We will make good faith efforts to implement requested changes in our active databases. Note, however, that we may keep information you update or change for Wilton’s administrative purposes. Also, it is not always possible to completely remove or delete all of your information from our databases, and residual data may remain on backup media or for other reasons.

In addition, if you no longer wish to receive promotional communications from us you may opt-out by emailing us at privacy@wilton.com, or by clicking on the unsubscribe link within any marketing email you receive from us.

You may also request information about how, where and why we collect and use your information, including information about how we share your information with third parties, by contacting us at privacy@wilton.com.

If you wish to access the information collected and stored by us, or to instruct us to stop disclosing information about you, you can email us at privacy@wilton.com, but note that if you do so, we may not be able to provide you with some or all of our products, services and customer support.

You may file a complaint with us in connection with the collection, use or processing of your information under this Privacy Policy by contacting us at privacy@wilton.com. We will take reasonable steps to remedy any issues resulting from our failure to comply with our obligations relating to your information.

10. Closing Your Account; Retention of Information. If you have created a user account through the Sites, we will close your account upon your request.  To request that we close your account, email us at privacy@wilton.com. We may also close or deactivate accounts that are inactive for more than 2 years or accounts that are used in violation of our Terms and Conditions or any applicable law. We will retain information from closed or inactive accounts to the extent and as long as it is necessary and relevant for our operations and to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions, and take other actions otherwise permitted by law. In general, information from closed or inactive accounts may be deleted or anonymized within two (2) years after the account is closed or deactivated unless we have reasonable grounds to believe that the information should be retained for one of the purposes identified above.

11. Third-Party Links & Content.

The Sites may contain links to other web sites that Wilton does not control, and the Sites may contain advertising and other content hosted and served by third parties. Wilton is not responsible for the privacy practices of any third party.

12. International Transfer of Personal Information. If you are located outside the United States and choose to provide information to us, know that Wilton transfers Personal Information to the United States and other jurisdictions for processing, which may not have the same data protection laws as the country in which you reside. When we transfer your information to the U.S. or other jurisdictions, we will protect it as described in this Privacy Policy. By visiting the Sites, or providing Wilton with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States and other jurisdictions.

Wilton protects personally identifiable information from residents of the European Union, other European Economic Area countries, and Switzerland in accordance with applicable law (including, as applicable, reliance upon your consent and model data protection contract clauses approved by the European Commission). 

13. Changes to the Privacy Policy. From time to time, Wilton may change this Privacy Policy and will notify you of material changes by posting the changed or modified Privacy Policy on our Sites. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified and your continued use of the any of the Sites after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes.

14. Contact Information. If you have any questions or concerns about this Privacy Policy, please email us at privacy@wilton.com.

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