This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Windsor and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

 

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Category

Examples

Collected

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

L. Sensitive Personal Information

(1) Personal information that reveals: (A) a consumer's social security, driver's license, state identification card, or passport number; 

(B) a consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer's precise geolocation; (D) a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication; (F) a consumer's genetic data. AND (2)(A) The processing of biometric information for the purpose of uniquely identifying a consumer; (B) Personal information collected and analyzed concerning a consumer's health; (C) Personal information collected and analyzed concerning a consumer's sex life or sexual orientation.

NO

 

Personal information does not include:

 

  • Publicly available information from government records.
  • De-identified or aggregated consumer information
  • Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

 

HOW INFORMATION IS COLLECTED

 

We obtain the categories of personal information listed above from the following categories of sources:

 

  • Directly from our customers. For example, from information provided by a customer signing up to our rewards program.
  • Indirectly from our customers. For example, through information we collect from our customers in the course of providing services to them.
  • Directly and indirectly from activity on our website (www.windsorstore.com). For example, from submissions through our website portal or website usage details collected automatically through technologies such as cookies and other data collection tools.
  • From third-parties that interact with us in connection with the services we perform. For example, from UPS or FedEx.
  • From other sources like data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from customers.

 

COOKIES AND SIMILAR TRACKING TECHNOLOGIES

Windsor as well as some of its third party partners (such as advertising and analytics providers) use cookies, web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies to gather information when customers interact with Windsor's website, and email communications. Some tracking technologies help Windsor maintain the security of our websites and consumer accounts, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

 

Windsor also permits third parties to use tracking technologies on its website for analytics and advertising, including to help manage and display advertisements, or to tailor advertisements to customer's interests. The third parties use their technology to provide advertising about products and services tailored to consumer's interests which may appear either on Windsor's website or on other websites.

 

To the extent these tracking technologies are deemed to be a “sale”/ “sharing” under CCPA, consumers can opt-out of these tracking technologies by clicking "Do Not Sell or Share My Personal Information" link at the bottom of our website and selecting your preferences or by (2) Visiting California Consumer Privacy Act (CCPA). Please note, some features of Windsor's website may not be available to you as a result.

 

If you do not have a Windsor account or if you are not logged into your Windsor account, your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to Windsoer. If you would like us to make the connection between your browser and your account when you send the opt out of sale/sharing of your personal information request, and you have not yet opted out of sale or sharing your personal information, we recommend you submitting the "Do Not Sell or Share Personal Information form" at the bottom of our website.

 

Please note that your use of our website may still be tracked by Sephora and/or our service providers. We do not knowingly sell the personal information of consumers under 16 years of age.

 

Categories of personal information disclosed that may be considered “sale”/ “sharing” under California law: Category A: Identifiers, Category B: California Customer Records personal information categories, Category D: Commercial information, Category F: Internet or other similar network activity.

 

Categories of third parties to whom personal information was disclosed that may be considered “sale”/ “sharing” under California law: advertisers and marketing partners, data analytics providers, and social media networks.

 

To our knowledge, we do not engage in the sale or sharing of personal information of consumers under 16 years of age.



USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

 

  • To fulfill or meet the reason for which the information is provided.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • For analytics and personalization. We use personal information to conduct research and analytics, including to improve our services and product offerings; to understand how you interact with our websites, mobile apps, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve our websites, mobile apps, and marketing campaigns; to personalize your experience, to save you time when you visit our websites and mobile apps, and to customize the marketing and advertising that we show you; to understand how you use our mobile Apps; to create a more personalized experience for you when you visit our stores; to provide services, to better understand our customers’ needs, and to provide personalized recommendations about our products and services.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others, including for security and fraud prevention purposes.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

SELLING OR SHARING PERSONAL INFORMATION

 

Windsor does not sell your personal information. In the preceding twelve (12) months, we have not sold any personal information.

 

In addition to the specific situations discussed elsewhere in this privacy policy, we disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

 

We may disclose your personal information for a business purpose to the following categories of third parties: (1) Our affiliates; (2) Service providers; and/or (3) Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

 

In the preceding twelve (12) months, we have shared the following categories of personal information for a business purpose:

 

Category A: Identifiers.

 

Category B: California Customer Records personal information categories.

 

Category D: Commercial information.

 

Category F: Internet or other similar network activity.

 

To our knowledge, we do not engage in the sale or sharing of personal information of consumers under 16 years of age.

 

DATA RETENTION

Windsor will retain your personal data for no longer than is necessary for the purposes stated in this Privacy Policy. Windsor will also retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

 

Windsor will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.



YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

 

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • Whether your information is sold or shared.
  • The retention period or criteria used for retention.

 

Deletion Request Rights

 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

 

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Right to Correct Information

In certain circumstances, you have the right to request correction of any inaccurate Personal Information. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your personal information as directed, taking into account the nature of the personal information and the purposes of maintaining your personal information.

 

Exercising Access, Data Portability, Deletion and Correction Rights

 

To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request to us by either:

 

Calling us at (877) 545-4439

Visiting California Consumer Privacy Act (CCPA)

 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

 

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

 

Response Timing and Format

 

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.



Non-Discrimination

 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

 

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Children under the age of 13 (16 in European Union/United Kingdom)

 

Our website is not intended for or directed for children under 13 (16 in the European Union/United Kingdom), and we do not knowingly collect information from these children. In fact, our website requires you to have reached the age of majority in the jurisdiction in which you live in order to make purchases there. If you are under the age of 13 (16 in the European Union/United Kingdom), please do not use our Services or otherwise provide us with any personal information either directly or by other means. Windsor does not knowingly collect or solicit any information from anyone under the age of 13 (16 in the European Union/United Kingdom) on our Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13 (16 in the European Union/ United Kingdom), we will delete that information as required by applicable law. If you believe that we might have any information from a child under 13 (16 in the European Union/United Kingdom), please contact us using the contact details set out at the end of this Privacy Policy. Visitors older than the age of 13 (16 in the European Union/United Kingdom), but younger than their country’s legal age of majority are permitted to use and/or submit their personal information only with parental supervision. We encourage parents and guardians to spend time online with their minor children and to participate and monitor their interactive activities. Parents, you can learn more about how to protect children's privacy on-line visiting: Protecting your Child's Privacy Online

 

Changes to Our Privacy Notice

 

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

 

Contact Information

 

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

 

Phone: (877) 545-4439

Website: windsorstore.com

Postal Address: 9603 John St., Santa Fe Springs, CA 90670

Attn: CCPA

 

CALIFORNIA SHINE THE LIGHT

Customers who are residents of California may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us at this address:

 

Windsor Inc. 

Attn: Privacy

9603 John St., 

Santa Fe Springs, CA 90670



SUBMIT DATA REQUEST