Castlery Privacy Policy

Effective Date: January 7, 2022

Last Updated: October 19, 2024

Castlery Inc.(“Castlery,” “we,” “our,” or “us”) is committed to protecting and respecting your privacy.

This Privacy Policy (“Policy”), together with any other documents referred to in it, sets out the basis on which any Personal Data we collect from you, or that you provide to us, when you interact with us on https://www.castlery.com/us/ (the “Site”), purchase our products and services (“Products”), and through other online and offline interactions. Before submitting Personal Data to us, please read this Policy carefully.

SOURCES OF PERSONAL DATA

“Personal Data” is any information relating to an identified or identifiable natural person. We collect Personal Data about you from the following sources:

• Directly from you, such as when you contact us through the Site via web forms or chat, make a purchase, subscribe to our emails, complete a survey, create an account, apply for a job, or attend our events.

• Automatically through tracking technologies, when you use the Site.

• From third parties, such as affiliated companies and subsidiaries, social media companies, or other parties who interact with us.

PERSONAL DATA WE COLLECT

Depending on how you interact with us, we may collect the following Personal Data from you:

• Identifiers, such as your name, address, email address, phone number, and Castlery account username and password.

• Protected class and demographic information, such as military/veteran status, immigration status, age and gender.

• Commercial information, such as your purchase history, billing address, customer support and email correspondence logs, and customer records.

• Internet or other electronic activity information, such as your IP address, device information, device ID, operating system, browser information, cookie ID, browsing history, pages viewed, search history, social media activity, history of your interactions with the Interactive features on our website, and other information regarding your interactions with and use of the Site. For more information about cookies and device data, please see the Cookies and Other Tracking Technologies section below.

• Professional and employment-related information, such as your resume information if you apply for a job with us, or your employer if you are contacting us as a representative of a business.

• Non-precise geolocation data, such as your location derived from your IP address.

• Audio, electronic, visual or other sensory information, such as photos and audio/video recordings you submit in your ratings and reviews of our Products.

• Inferences, drawn from any of the information we collect about you to help us understand your interest in our Products.

• Sensitive Personal Data, such as a copy of your driver’s license or other form of government identification. Please note that we only use your Sensitive Personal Information only for legitimate business purposes, including to (i) perform services or provide goods reasonably expected by an average staff member in your position; (ii) detect security incidents; (iii) resist malicious, deceptive, or illegal actions; (iv) ensure the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) perform or provide internal business services; (vii) verify or maintain the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.

HOW WE USE YOUR PERSONAL DATA

The purposes for which we may use your Personal Data include:

• Administering and improving your experience on our Site

  • We use the following categories of Personal Data for this purpose: Identifiers, Protected class and demographic information, Commercial information, Internet or other electronic activity information, Non-precise geolocation data, Audio, electronic, visual or other sensory information, Inferences.

• Providing you with the Products you requested and customer support

  • We use the following categories of Personal Data for this purpose: Identifiers, Protected class and demographic information, Commercial information, Internet or other electronic activity information, Professional and employment-related information, Non-precise geolocation data, Audio, electronic, visual or other sensory information, Sensitive Personal Data.

• Providing you with alerts, newsletter, education materials or information that you requested or signed up for and promoting and advertising Products that may be of interest to you

  • We use the following categories of Personal Data for this purpose: Identifiers, Protected class and demographic information, Commercial Information, Internet or other electronic activity information, Non-precise geolocation data, Audio, electronic, visual or other sensory information, Inferences.

• Allowing you to participate in interactive features of our Products, such as 3D Images, Web AR, Shop the Look, Sofa Quizzes, and the Room creator tool, when you choose to do so

  • We use the following categories of Personal Data for this purpose: Identifiers, Commercial Information, Internet, or other electronic activity information, Non-precise geolocation data, Audio, electronic, visual or other sensory information, Inferences.

• Improving our products by designing and conducting surveys/questionnaires, conducting statistical analysis, and researching and launching new Products, seminars, events, and forums

  • We use the following categories of Personal Data for this purpose: Identifiers, Protected class and demographic information, Commercial Information, Internet or other electronic activity information, Professional and employment-related information, Non-precise geolocation data, Audio, electronic, visual or other sensory information, Inferences.

• Evaluating and processing your job application and communicating with you about your candidacy

  • We use the following categories of Personal Data for this purpose: Identifiers, Protected Class and demographic information, Professional and employment-related information.

• Complying with our legal and regulatory obligations

  • We use the following categories of Personal Data for this purpose: Identifiers, Protected class and demographic information, Commercial Information, Internet or other electronic activity information, Professional and employment-related information, Non-precise geolocation data, Audio, electronic, visual or other sensory information, Sensitive Personal Data.

• Protecting protect the health and safety of our customers, personnel, and the general public

  • We use the following categories of Personal Data for this purpose: Identifiers, Protected class and demographic information, Commercial information, Internet or other electronic activity information, Professional and employment-related information, Non-precise geolocation data, Audio, electronic, visual or other sensory information, Sensitive Personal Data.

HOW WE DISCLOSE YOUR PERSONAL DATA

We may disclose your Personal Data to the following recipients:

• Affiliates and subsidiaries, including parent entities, corporate affiliates, and other entities that share common ownership.

• Service providers, including companies that we contract with in order to receive services, such as payment processing, delivery, repair, re-commerce service, customer service, product insurance, customer support software service, customer data platform software service.

• Business partners, such as social media companies, advertising networks, analytics partners and providers, and other parties that may use Personal Data to provide you with advertising.

• Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as to comply with our legal obligations, enforce our terms and policies, detect and prevent fraud and security incidents, and communicate with you about our Products and other administrative or transactional matters.

• Other entities in connection with a corporate transaction, such as in connection with a merger, sale, consolidation, transfer of assets, reorganization, or liquidation of our company.

• Other entities with your consent.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Site and third parties that we authorize use cookies and other tracking technologies (such as pixels, web beacons, tags, session replay tools, embedded scripts, and SDKs) to collect Personal Data from you, as described in the “Personal Data We Collect” section above. We use this information to analyze how you use the Site, personalize and improve your experience on our Site, provide you with advertising, and measure and improve the effectiveness of our advertising campaigns.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies.These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e- billing services.

• Analytical/performance cookies.They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

We use Google Analytics to analyze and improve the functionality of our Site. To learn how Google Analytics uses and processes cookies and other tracking technologies, please visit “How Google uses data when you use our partners’ sites or apps.” You can prevent Google's collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout)

Your Choices

Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, your Flash player can be set to reject or delete Flash cookies. Refusing a cookie will generally not interfere with your use of the Sites. However, refusal of a cookie may, in some cases, preclude you from using or negatively impact the display or function of the Sites or certain areas or features of the Sites.

Some of the third parties we work with participate in industry groups that offer mechanisms for opting out of interest-based advertising. To exercise these choices, you can use the Digital Advertising Alliance’s mechanism at http://www.aboutads.info/choices/ and the Network Advertising Initiative’s mechanism at https://optout.networkadvertising.org/. Opting out of interest-based advertising using these tools will not opt you out of all advertising, but rather only interested-based advertising from us or our partners or representatives.

Do Not Track

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a "Do Not Track" ("DNT") or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many digital service operators, including Castlery do not recognize or respond to DNT signals.

MARKETING OPT-OUT

If you would like to opt out of receiving promotional or marketing e-mail from us, you may use the “unsubscribe” mechanism included in each marketing message. If you have an Account, you may opt-out of marketing communications in your User Account settings. However, your option not to receive promotional and marketing e-mail shall not preclude us from corresponding with you, by e-mail or otherwise, regarding your existing relationship with us. Your opt-out request will also not apply to correspondence that has already been initiated.

SECURITY AND RETENTION

We have implemented reasonable safeguards designed to protect your information from loss, misuse, alteration, or destruction. We also take reasonable steps designed to ensure that third parties who work with us agree to protect the Personal Data. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure, and we cannot guarantee the security of your data transmitted to our site. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the Site and Products. Please be careful whenever sending Personal Data to us via e-mail. E-mail is not a secure means of transferring information.

We maintain your Personal Data as reasonably required to provide our Site and Products, run our business, and comply with our legal obligations. In determining when your Personal Data is retained or disposed, we may consider the nature and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and applicable legal requirements.

INFORMATION FOR INTERNATIONAL VISITORS

If you visit the Sites or provide us your Personal Data from outside the United States, your information will be transferred to, stored, and processed in the United States, Singapore, Australia and other countries where Castlery or its vendors operate in accordance with this Policy and applicable laws. Please note that data protection and consumer protection laws of such other countries may differ from the data protection or consumer protection laws in your country. By using the Site or providing us with your Personal Data, you understand that your Personal Data will be collected from and processed in the United States, Australia, Singapore, and other countries where Castlery or its vendors operate, and acknowledge that your information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions. Where applicable, we have implemented appropriate cross border data transfer mechanisms when transferring your Personal Data to a country outside of your home jurisdiction. To request for deletion of your Personal Data, please contact us by completing our web form.

CHILDREN’S PRIVACY

We do not knowingly collect any Personal Data from children under 13 without prior verifiable parental consent. If we learn that a child under the age of 13 has submitted Personal Data without parental consent, we will take all reasonable measures to delete the information as soon as possible and to not use such information for any purpose, except where necessary to protect the safety of the child or others as required or allowed by law. If you believe a child under 13 has provided us with Personal Data, please contact us using the information in the “Contact Us” section below.

EXTERNAL LINKS

Our Site may contain references or links to third-party websites and services. Except as described above regarding service providers, we do not control what information third parties track or collect. Any access to and use of such third-party websites and services is not governed by this Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.

CHANGES TO OUR PRIVACY POLICY

We may occasionally update this Policy to reflect changes in our practices. When we post modifications to this Policy, we will revise the "Last Updated” date at the top of this web page. If the changes are material, we will endeavor to notify you in advance of such changes taking place. If you object to any modification, your sole recourse is to notify us that you do not agree and to stop using the Site and providing us with your Personal Data. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT US

For questions about this Policy, you can contact us at:

[1950 W. Corporate Way PMB95972 Anaheim CA 92801 & privacy@castlery.com]

SUPPLEMENTAL INFORMATION FOR RESIDENTS OF CALIFORNIA, COLORADO, AND OTHER U.S. STATES

Your Rights

Residents of certain US states may have certain rights regarding Personal Data, including:

• Right to Know. You may have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why. You may also request the specific pieces of Personal Data we have collected about you.

• Right to Delete.You may have the right to request that we delete Personal Data that we have collected from you. To request for deletion of your Personal Data, please contact us by completing our web form.

• Right to Correct.You may have the right to request that we correct inaccurate Personal Data that we maintain about you.

• Right to Opt Out of Sales/Sharing/Targeted Advertising. You may have the right to opt out of (i) the sale or sharing of your Personal Data and (ii) targeted advertising.

You can Opt Out of Sales/Sharing/Targeted Advertising by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our website, checking the “Do Not Sell or Share My Personal Information” box and clicking “Save My Preferences” to disable Targeting Cookie. You may exercise the any of other above rights available to you by completing our web form or calling us at +1 855-685-3995. We will not discriminate against you for exercising your privacy rights.

Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, such as a signed declaration that you are who you say you are, and will inform you if we need such information.

Authorized Agents: Authorized agents may exercise rights on behalf of you by emailing us at privacy@castlery.com, or calling us at +1 855-685-3995 and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of you by providing signed permission from you. We may also require you to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.

Appeal: If we deny your rights request, you may have the right to appeal. To submit an appeal, contact us at privacy@castlery.com. We will inform you in writing our response to your appeal.

California Shine the Light

California Civil Code Section 1798.83 also permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Data to third parties for those third parties’ direct marketing purposes. To make such a request, please reach out to us at +1 855-685-3995 or privacy@castlery.com. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the phone number or the email specified. Note that we do not currently share Personal Data with third parties for those third parties’ direct marketing purposes.

Disclosures of Personal Data

Below please find a chart detailing the categories of Personal Data we collected and with whom it was sold, shared, or disclosed for a business or commercial purpose in the past 12 months. Note that we do not knowingly sell or share any Personal Data of minors under the age of 16.