Baffin Privacy Policy

Effective Date: February 23, 2024

INTRODUCTION

The following is the privacy policy (the “Privacy Policy”) of Baffin Inc. and Canada US, Inc. (together “Baffin”, “we”, “us” or ”our”). Baffin recognizes the importance of your right to privacy, and we are committed to safeguarding Personal Information (as defined below) that Baffin collects, uses, and discloses from and about users of this site (the “Site”) or offline services, in each case that link to or expressly reference this Privacy Policy (collectively, the “Sites/Services”).

This Privacy Policy sets out the way we use your Personal Information: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled. We advise you to read this Privacy Policy in its entirety, including the jurisdiction-specific provisions in this Privacy Policy, which will apply to users in certain jurisdictions. Additionally, please note that the “Notice at Collection; Categories of Personal Information We Collect and Use” section below, which describes our collection and use of information practices through the Sites/Services, also serves as our Notice at Collection for California residents for purposes of the California Consumer Privacy Act (“CCPA”).

This Privacy Policy is designed to be reasonably accessible to people with disabilities. If you experience any difficulties accessing the information in this Privacy Policy, please email us at privacyofficer@baffin.com.

NOTICE AT COLLECTION; CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND USE

ADVERTISING, MARKETING, AND ANALYTICS ACTIVITIES

RETENTION OF PERSONAL INFORMATION

SOURCES OF PERSONAL INFORMATION

DISCLOSURE OF PERSONAL INFORMATION

INTERNATIONAL TRANSFERS

COOKIES, WEB BEACONS, TAGS AND OTHER SIMILAR TECHNOLOGIES

YOUR RIGHTS AND CHOICES

  1. S. STATE PRIVACY RIGHTS
  2. SHINE THE LIGHT INQUIRIES FOR CALIFORNIA RESIDENTS
  3. COOKIES AND INTEREST-BASED ADVERTISING
  4. UNSOLICITED COMMUNICATIONS

THIRD PARTY LINKS

SECURITY

CHILDREN’S PRIVACY

CHANGES TO THIS PRIVACY POLICY

HOW TO CONTACT US

NOTICE AT COLLECTION; CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND USE

We collect certain types of Personal Information from or about you throughout our interaction with you and from other sources.

“Personal Information” is any information: 

  • that identifies or can be used to identify you or your household;
  • that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your or household;
  • that can be used to authenticate you or provide access to an account;

Personal Information does not include aggregated, de-identified, or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you. We will maintain and use de-identified information in de-identified form and will not attempt to re-identify such information, except to make sure the information is truly de-identified.

Over at least the last 12 months, we have collected, used, and disclosed the categories of Personal Information listed in the table below for the purposes and activities we have listed in the table below. In addition, we sell and share the following categories of Personal Information for cross-context behavioral and targeted advertising: personal identifiers, demographic information, commercial information, device, internet and network activity information, online identifiers, general location information, and inferences drawn from the above categories. If you would like to opt-out of the sale and sharing of these categories of personal information, click Do Not Sell or Share My Personal Information or call at toll free number: [____________].

Categories of Personal Information We Collect

Our Business or Commercial Purposes for the Collection and Use of Personal Information

Personal Identifiers such as your name, postal/mailing address, telephone number, mobile phone number, title, email address, account preferences, and username and password

We use this information to:

·    Fulfill orders, process payments and ship products purchased by you;

·    Onboard you as an account holder;

·    Report and account management;

·    Issue and redeem gift cards;

·    Process exchanges and returns;

·    Respond to enquiries including through our live chat functionality and the provision of stock notification updates;

·    Provide you with information about product recalls and warranty claims;

·    Monitor customer communications for quality and training purposes;

·    Administer contests, sweepstakes and other promotions;

·    Identify Baffin products that may be of interest to you and market these to you (as described in the Advertising, Marketing, and Analytics Activities section below) if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law; and

·    Profile, tailor communications and create personalized experiences.

Demographic Information, including gender and date of birth

We use this information to:

·    Carry out statistical analysis, customer insight, product research, research and reporting;

·    Administer any contests, sweepstakes and other promotions;

·    Improve our Sites/Services, products, and events;

·    Identify Baffin products that may be of interest to you and market these to you (as described in the Advertising, Marketing, and Analytics Activities section) if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law; and

·    Profile, tailor communications and create personalized experiences.

Commercial Information, including the product(s) you have purchased, items you have put in your basket on our website, when and where you made these purchases (e.g., time of day), what you paid for them and how you paid, other information related to your attendance at an event, marketing preferences and information (e.g., previous communication data and transaction history), information you give us when you complete a boot finder quiz, and if you choose to provide such data to us, your shoe size (and foot dimensions), date of birth, gender, apparel size and outerwear size

We use this information to:

·  Fulfill orders, process payments and ship products purchased by you;

·  Onboard you as an account holder;

·  Report and account management;

·  Issue and redeem gift cards;

·  Process exchanges and returns;

·  Identify Baffin products that may be of interest to you and market these to you (as described in the Advertising, Marketing, and Analytics Activities section) if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law;

·  Profile, tailor communications and create personalised experiences;

·  Develop new services, products, and events;

·  Carry out statistical analysis, customer insight, product research, research and reporting;

·  Notify you of product recalls or safety issues;

·  Respond to enquiries including through our live chat functionality and the provision of stock notification updates;

·  Provide you with information about warranty claims;

·  Monitor customer communications for quality and training purposes;

·  Improve our Sites/Services, products, and events;

·  Deal with any complaints;

·  Monitor information transmitted or received through our website or via email to prevent violations of our website terms of use or inappropriate content; and

·  Retain your measurements and profile data for future purchases.

Other Categories of Information You Submit to us, such as when you fill out feedback forms or surveys, submit warranty details, information you provide to us when you make an enquiry, complaint, claim under our warranty program, otherwise communicate with us, whether through our website, via email or over the phone, participate in or respond to consumer survey or request for opinions, concerns, and preferences regarding our products, participate in contests, sweepstakes and other promotions or use other features of our website that may be offered from time to time

We use this information to:

·  Report and account management;

·  Issue and redeem gift cards;

·  Process exchanges and returns;

·  Respond to requests;

·  Identify Baffin products that may be of interest to you and market these to you (as described in the Advertising, Marketing, and Analytics Activities section) if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law;

·  Profile, tailor communications and create personalized experiences;

·  Develop new services, products, and events;

·  Carry out statistical analysis, customer insight, product research, research and reporting;

·  Respond to enquiries including through our live chat functionality and the provision of stock notification updates;

·  Administer any contests, sweepstakes and other promotions;

·  Notify you of product recalls or safety issues;

·  Provide you information about warranty claims;

·  Monitor customer communications for quality and training purposes;

·  Improve our Sites/Services, products, and events;

·  Deal with complaints;

·  Monitor information transmitted or received through our website or via email to prevent violations of our website terms of use or inappropriate content;

·  Manage our events effectively;

·  Keep a record of your attendance at events; and

·  Provide you with relevant information about the event.

Financial Information, including billing address, payment type or method, charge or credit card number, and details of any gift cards being issued or redeemed

We use this information to:

·  Process payments for products purchased by you;

·  Onboard you as an account holder;

·  Report and account management;

·  Issue and redeem gift cards;

·  Process exchanges and returns; and

·  Schedule and carry out your virtual shopping appointment.

Device, Internet and Network Activity Information, Online Identifiers (IP Address, cookie IDs and Device IDs), including what webpages you have visited, whether you’ve opened or clicked on links in electronic communications from us or visited pages on our pages, hardware and browser settings, language preferences, the search engine terms you use, the URLs from which you linked to our Sites/Services, browsing history, search history, and information regarding your interaction with our advertisements

We use this information to:

·  Fulfill orders, process payments and ship products purchased by you;

·  Onboard you as an account holder;

·  Report and account management;

·  Issue and redeem gift cards;

·  Process exchanges and returns;

·  Identify Baffin products that may be of interest to you and market these to you (as described in the Advertising, Marketing, and Analytics Activities section) if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law;

·  Profile, tailor communications and create personalized experiences;

·  Develop new services, products, and events;

·  Carry out statistical analysis, customer insight, product research, research and reporting;

·  Notify you of product recalls or safety issues;

·  Respond to enquiries including through our live chat functionality and the provision of stock notification updates;

·  Provide you with information about warranty claims;

·  Monitor customer communications for quality and training purposes;

·  Improve our Sites/Services, products, and events;Deal with any complaints;

·  Monitor information transmitted or received through our website or via email to prevent violations of our website terms of use or inappropriate content; and

·  Retain your measurements and profile data for future purchases.

General location information, (e.g., zip code and IP address)

We use this information to:

·  Report and account management;

·  Identify Baffin products that may be of interest to you and market these to you (as described in the Advertising, Marketing, and Analytics Activities section) if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law;

·  Profile, tailor communications and create personalized experiences;

·  Develop new services, products, and events;

·  Carry out statistical analysis, customer insight, product research, research and reporting;

·  Improve our Sites/Services, products, and events;

·  Monitor information transmitted or received through our website or via email to prevent violations of our website terms of use or inappropriate content; and

·  Retain your measurements and profile data for future purchases.

 

·   

Inferences drawn from Personal Identifiers, Demographic Information, Device, Internet, and Network Activity, General Location, and Commercial Information to create a profile about you reflecting your preferences, characteristics, and behavior

We use this information to:

·  Identify Baffin products that may be of interest to you and market these to you (as described in the Advertising, Marketing, and Analytics Activities section) if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law;

·  Profile, tailor communications and create personalized experiences;

·  Develop new services, products, and events;

·  Carry out statistical analysis, customer insight, product research, research and reporting; and

·  Improve our Sites/Services, products, and events.

Employment-Related Information, including your employment and education history, resume, cover letter, transcript, writing samples, and references as necessary to consider you for job openings

We use this information to:

·  Review and consider the information that you submit in connection with your application for employment with Baffin; and

·  Respond to your application for current or future career opportunities.

In addition to the above, Personal Information may also be processed if it is necessary:

  • on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claim;
  • to address or prevent a policy or terms violation;
  • to defend or enforce our rights
  • to enforce our agreements;
  • to protect against unauthorized access to our systems or other inappropriate use of our Sites/Services; and
  • to provide you with a service or experience at your request.

We will not delete Personal Information if relevant to an investigation or dispute. It will continue to be stored until those issues are fully resolved.

We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our products to you based on fraud detection and creditworthiness checks. This will be informed by verification of Personal Information (including by vendors engaged by us). Depending on the outcome of these checks, a decision will be reached automatically as to whether we are able to provide products to you.

Where we need to collect your Personal Information under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide our products to you).

ADVERTISING, MARKETING, AND ANALYTICS ACTIVITIES

We use vendors, such as agencies, advertisers, ad networks, and other technology providers, to serve advertisements on our behalf across the internet. These vendors may collect information about your visits to our website, and your interactions with our products and services. Such vendors may place and access their own cookies, tags, web beacons or similar technologies on your computer or device used to access the website to serve you ads or other content personalized to your interests (“Interest-based Advertising”). In addition to the information about your visits to our website, these vendors may also use the information about your visits to other websites to target advertisements for products and services available from Baffin.

We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Sites/Services or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Sites/Services, and the ad partner matching common factors between our data and their data. For instance, we may incorporate the Facebook pixel on our Sites/Services and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

In certain contexts, these vendors may act as our service providers and in other contexts may independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

As described in more detail below, you may reject the use of cookies when accessing our website and you may be able to set your browser to reject cookies later. In that case, you may still receive online advertising, but it may be less personalized.

RETENTION OF PERSONAL INFORMATION

We will keep Personal Information for as long as it is reasonably necessary considering the purposes for which Personal Information has been collected. It will depend on factors such as whether you have any outstanding purchases or an account with us or have interacted with recent offers. For further information on how long we will keep Personal Information, please contact our privacy officer at privacyofficer@baffin.com.

SOURCES OF PERSONAL INFORMATION

We collect Personal Information in the following ways:

  • Directly From You (either offline or through the Sites/Services). For example, when you:
    • Register for a Baffin account;
    • Make reservations for a Baffin event;
    • Sign up to receive promotional communications;
    • Submit a request to or contact our customer service team, including through our live chat functionality;
    • Apply for a job through our Sites/Services;
    • Enter a promotion or sweepstakes
    • Order online.
  • Automatically through Cookies and Similar Technologies. For example, when you:
    • Visit and navigate our Sites/Services on any device
    • Use our live chat functionality
    • Click on sponsored links or third-party advertisements

We may also use cookies and similar technologies owned and operated by other entities to collect Personal Information about you over time and across different websites, apps, and devices. For more information about our use of cookies and other similar technologies, please refer to the section called “Cookies, Web Beacons, Tags and Other Similar Technologies” below.

  • From Service Providers and Contractors. For example, we work with service providers and contractors who collect Personal Information on our behalf in order to:
    • Run and manage our Sites/Services
    • Offer and improve products and services
    • Provide IT development and support
    • Host and carry out marketing and business studies and marketing campaigns
    • Verify your information
    • Authenticate payments and process orders and payments
    • Provide fulfillment services
    • Provide delivery services
    • Provide customer service
  • From Other Entities.We may receive Personal Information about you from other sources. For example, this may include receiving Personal Information from:
    • Our business and website partners