The Website is managed by CROSTY INC. (“CROSTY “), a corporation registered and existing under the laws of Delaware, USA.
1. Our Policy
CROSTY respects your right to be informed regarding the collection of and other operations involving your personal data. While using data that may directly or indirectly identify you personally, a principle of necessity is applied. Therefore, the use of your personal data will be kept to a reasonable minimum and will not exceed the purposes for which your personal data was collected and/or processed.
We will not process your personal data when we can provide you with services through the use of anonymous data (such as marketing research made for improving our services) or by other means which allow CROSTY to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).
2. Use of Personal Data and its purposes
Your personal data are collected and processed by CROSTY for purposes which are strictly connected use of the Website, its services and to purchase products on Website. However, your personal data may also be used for other processing operations within the limits of such purposes.
We may collect, and over the prior 12 months have collected, the following categories of personal information:
- Identifiers, such as name, contact information (e.g., postal, mailing, billing, and/or shipping address, zip code, email address, telephone number), IP address, a unique PayPal identifier, and other similar identifiers;
- Categories of personal information related to the California Customer Records statute (Cal. Civ. Code § 1798.80), such as name, contact information and etc.;
- Commercial information, including information about a consumer’s purchase, such as the items purchased, the price of the items, the payment method used, and whether the product was on sale;
- Audio, electronic and visual information, such as in-store video monitoring and call recordings created in connection with our business activities (e.g., customer service calls for training and quality control purposes);
- Internet or other electronic network activity information, such as browsing history, search history, or information on a consumer’s interaction with our Website;
- Geolocation Data, such as your current location (based on your IP address); and
- Protected classification characteristics under California or federal law, such as age (40 years or older).
We collect information from various sources in three primary ways:
- You give us information: We collect information from you when you submit it to us through our Website, other digital media or in one of our stores.
- We collect information from other sources: We may collect information about you from our vendors and service providers when they interact with you on our behalf.
Your personal data shall be processed for the following purposes:
We use the information we collect internally in our business for many business purposes, such as to: (i) advance our economic and commercial interests by providing the products or services you may order, including processing orders and returns; (ii) analyze trends and conduct research about improving our products and services; (iii) maintain and service customer accounts; (iv) provide support and respond to questions from customers and Website visitors; (v) improve our stores, Website, products and/or services; (vi) audit customer activity in order to learn about and meet our customers’ needs; (vii) contact consumers for research, informational, and marketing purposes, including customizing our product recommendations and promotions to you based upon your information and purchases; (viii) track traffic patterns and Website usage; (ix) enable online ordering by processing and fulfilling your orders and transactions, processing payments, and providing customer service with respect to such orders; (x) correlate information with other commercially available information to identify demographics and preferences to assist us in our marketing efforts; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues; (xiii) ensure and improve the quality and safety of our services; (xiv) verify our customers information, and to protect against and prosecute those responsible for malicious, deceptive, fraudulent, or illegal activity; (xv) investigate and defend against claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xvi) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website or the public; and, (xvii) process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.
Your personal data shall not be disclosed to third parties for purposes which are not permitted by law or without your consent.
CROSTY will process your personal data for direct marketing purposes, including by e-mail, only after receiving your consent. You may withdraw your consent on data procession for direct marketing purposes at any time and in a written form. In such a case, CROSTY will discontinue to process your personal data for direct marketing purposes within 10 (ten) days from such written notification.
3. Non-Disclosure of your Personal Data to CROSTY
Granting your personal data to CROSTY (in particular, your personal details, your e-mail address, your address, your Credit/Debit Card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on Website, supplying other services provided on the Website upon your request, or when your personal information is needed to fulfill obligations required by law or regulations.
The refusal to provide CROSTY with some of your personal data necessary for performing the above purposes may consequently prevent us from processing your order for the purchase of products sold on Website or from supplying other services provided on Website, such as sending the Newsletter or fulfilling obligations required by law and other regulations. Therefore, failing to provide data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on Website or not providing other services.
Disclosure of further personal data to CROSTY other than that required for fulfilling legal or contractual obligations or for providing the services requested, is, on the contrary, optional and does not have any effect on the use of the Website and of its services or on the purchase of products on Website.
In some circumstances and if required, from time to time we will duly inform you if the personal data you are disclosing to CROSTY is compulsory or optional. We will point out to you whether the disclosure of your data is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory or data needed for providing the required services on Website and for the purchase of products on Website. Failing to provide optional personal data will not imply any obligation or disadvantage to our users.
4. Data Collection and Cookies
When you are using Website, some personal data might be collected automatically (through “cookies”), for example, when we automatically collect users’ IP addresses and other information regarding the users’ data traffic or the users’ preferences in the choice of services provided on this web site and of the products purchased through the provided services. This information and data are collected directly and automatically by the Website as part of its operational functions. This information and data are then processed in a collective and anonymous way for commercial purposes in order to optimize the services provided on Website for the needs and preferences of the Website’s users.
In other circumstances, CROSTY will directly collect personal data and information from its users when they register online with Website or when they send purchase orders of products sold on the web site in order to finalize e-commerce transactions. CROSTY process such data only for the purposes and within the limits of what is stated herein in this policy.
We use the following categories of cookies on our website:
- Strictly necessary cookies: these cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies will also inform us about your behaviour on our website, if we can do business with you and protect CROSTY and its customers from fraudulent activities.
- Performance cookies: These cookies collect anonymous information on how you use our website (eg. we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site) and highlight areas we can improve such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. They are also used to help measure the effectiveness of an advertising campaign. You may opt-in to these cookies using your browser settings.
- Functionality cookies: These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt in to these cookies using your browser settings.
- Targeting cookies or advertising cookies: These cookies collect information about your browsing habits and limited aggregated demographic information in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
You can withdraw your consent to these cookies at any time through the following options:
- Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
- Other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu.
- Any other type of cookies, you can clean the cookies through your browser settings.
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
5. Security Measures
It is strictly advisable that your computer be provided with software devices that protect network data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
6. Right to access Personal Data and further rights
CROSTY will process your personal data only after receiving your consent, freely expressed, in order to send you advertising material and direct marketing or other commercial communications, including by e-mail, which do not fall within customer requested services provided by Website. Each time your consent is required, we will inform you in advance and we will give you the option to either provide or refuse your consent for the use of your personal data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.
However, CROSTY may process your personal data also without your consent in certain circumstances provided by law, such as when such processing is necessary for performing a legal obligation to which CROSTY is subject or when such processing is necessary for performing obligations undertaken in contracts with the users (such as, for example, if you purchased products on Website or if you asked to use specific services through our web site).
In any case, we guarantee that you may exercise, at any time and without having to state the reason, your right not to receive future communications connected to particular services upon request.
You are entitled to obtain, at any time, confirmation from CROSTY as to whether or not data relating to you is being processed.
Moreover, you are entitled to receive from CROSTY information on the source of your personal data; the purposes and way of processing your personal data; the logic involved in any electronic data processing; details of the data controller and of the data processors; the names of the entities and categories of entities to whom your personal data may be disclosed or who may access your personal data, for example, as a data controller or a party so appointed.
You are entitled to object, in whole or in part:
- for legitimate reasons, to the processing of your personal data, even if it is related to the purposes for which it was collected;
- to the processing of your personal data for advertising or direct marketing purposes or in order to carry out marketing research or commercial communications.
You may freely exercise your rights at any time, provided that you do so in compliance with applicable laws, by sending your request to CROSTY at the following e-mail address: firstname.lastname@example.org. We will reply to you as necessary.
7. YOUR CHOICES ABOUT THE INFORMATION WE COLLECT
UPDATING YOUR PERSONAL INFORMATION
We prefer to keep your personal information accurate and up-to-date. If you would like to change your contact information, please login to your account.
We collect various types of personal information about you during the course of your relationship with us as a customer.
We collect and process your personal information for our business purposes, which include the following:
- Providing you with information tailored to your requests, responding to inquiries, and delivering services and products;
- Operating, maintaining and improving the quality of the Services and such content, products and/or services as we may make available through the Services;
- Communicating with you by email and/or notification, in each case with your consent if such consent is required in accordance with applicable laws or software platforms, about products, services, order status, and other topics;
- For marketing purposes, including sending you messages about us, our partners, and the products and services we offer, which may from time to time include contests, rewards, events and special offers for products and services;
- Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
- Endeavoring to protect our and our partner’s rights, property, or safety, and the rights, property, and safety of our users and other third parties; and
- For other purposes, as permitted or required by law.
Sharing of Personal Information
We share personal information with the following categories of third parties:
Service providers – we disclose personal information to our service providers to allow them to provide services to us and assist in carrying out your requests, such as Rakuten Advertising.
Our partners – we disclose personal information to our partners in aggregate, demographic form in connection with our marketing and business development efforts; and
Third parties – we disclose personal information to third parties when you ask us to do so; when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or of our users and others.
1. Right to Know
California Civil Code Section 1798.83, known as the “Shine the Light’ law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third partis for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email below and are free of charge. If you are a resident of California, the CCPA grants you the following specific rights regarding your personal information. In order to exercise your rights, you must submit a consumer request, which must then be verified. Generally, in order to verify your requests, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may include your name, email address, phone number, shipping address, or the date of your last purchase from us. We will deliver a response to you within 45 days of receiving the verifiable consumer request.
We do not disclose personal information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
If you are a resident of one of the States, State Privacy Laws provide you with the following rights with respect to your Personal Information, as that term is defined in the State Privacy Laws:
- The categories of personal information collected about you; The categories of sources from which we collected your personal information;
- The categories of personal information that we have sold or disclosed about you for a business purpose;
- The categories of third parties to whom hour personal information was disclosed for a business purpose;
- Our business or commercial purpose for collecting or selling your personal information; and The specific pieces of personal information we have collected about you.
Verifiable consumer requests to know may be submitted through following method: email@example.com entitled “CCPA Request.”
2. Data Portability
you have right to request a copy of personal information we hold about you.
3. Right to Request Deletion
You have the right to request that we delete any personal information that we have collected from you. However, we are not required to comply with a request to delete, if it is necessary for us to retain the personal information in order to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with legal obligations.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Verifiable consumer requests to delete may be submitted through following method: firstname.lastname@example.org entitled “CCPA Request.”
4. Right to Opt-in to Financial Incentives
CROSTY does not currently utilize a loyalty or financial incentive program of any sorts.
5. Right to Opt-Out from Financial Incentives
You have the right to Opt-out from financial incentives at any time. However, CROSTY does not currently utilize a loyalty or financial incentive program of any sorts.
6. Right to Non-Discrimination
You have right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
- Deny you goods and services;
- Provide you a different level of quality of goods or services;
- Charge you different prices or rated for goods or services, including through granting discounts of other benefits, or imposing penalties;
- Provide you a different level of quality of goods or services;
- Suggest that you may receive a different price or rate for goods or services or different level of quality of goods or services.
7. Opt-Out and Opt-In Rights Regarding the “Sale” of Your Personal Information
8. Do not sell or share my info (CPRA)
CROSTY does not sell (as “sell” is traditionally defined) your personal information. That is, we do not provide your name, phone number, address, email address or other information that personally identifies you to third parties in exchange for money.
But, under California law, some transfers of personal information are considered “sales” even if no money changes hands and no payments are made, and California residents have the right to tell us not to “sell” their personal information.
At CROSTY, the only “sales” (as defined by California law) we make relate to sharing information about your activity on our Website through cookies with our advertising partners to help us provide ads that are more relevant to you.
When you opt out through this Website, an “opt-out” cookie is stored in your web browser indicating that you do not want to receive targeted advertisements. If you delete cookies generally or use a different device or browser, you will need to opt out again. We also place cookies to help us with your orders placed on our Website. If you would like to place an order without using cookies, please contact Customer Service.
9. Authorized Agent
Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require you to verify your identity directly with us and directly confirm that you have provided the authorized agent permission to submit the request. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.
10.Modifications and Updated to this California Privasy Rights
We reserve the right, at any time, to modify, alter, and/or update this California Privacy Rights, and any such modifications, alterations or updates will be effective upon our posting of the revised California Privacy Rights. Your continued use of the Services following our posting of any revised California Privacy Rights will constitute your acknowledgement of the amended California Privacy Rights.
11.RESPONSE TO DO NOT TRACK SIGNALS
California law requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about your online activities over time. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to the browser DNT signals when you use our services and products or interact with our Website.
Last Updated: 18th March, 2023