1. YOUR PRIVACY IS IMPORTANT TO US
At UrbanLab, we strive to honor the privacy and security of our users, customers and suppliers, as well as their representatives, in relation to all products, services, applications and websites provided by American Lifestyle Company LLC., or any of its affiliates (“UrbanLab”), when acting as a Controller under relevant data protection rules and regulations.
This Privacy Statement describes our privacy practices as required by the General Data Protection Regulation (“GDPR”) (EU) (2016/679) and other applicable data protection laws (collectively “Privacy Laws”). This Privacy Statement applies where UrbanLab is acting as a Data Controller with respect to the Personal Data of our customers, employees, website users, partners and service providers. In other words, this Privacy Statement applies where we determine the purposes and means of the processing of Personal Data.
2. PERSONAL DATA WE COLLECT ABOUT YOU
When you complete a transaction, submit a request, set up an account, apply for a position, visit our Sites, etc., with any UrbanLab’s entity, you may be asked to provide certain information, including, but not limited to, your name, title, company, address, phone number, e-mail address, credit card information, and line of business. You may also be providing us with data regarding your devices including, your IP address, your geolocation, your data usage, your client or supplier account, etc. In limited circumstances, we may collect information related to you, and your family members, such as age, gender and civil status. This information and data may be Personal Data under applicable Privacy Laws.
3. WHY WE PROCESS YOUR PERSONAL DATA, LEGAL BASES FOR PROCESSING AND RETENTION
We will keep your Personal Data while we are providing our products and services to you. Thereafter, we will keep your Personal Data for one of these reasons: (a) to respond to any questions, complaints or claims made by you or on your behalf; (b) to show that we treated you fairly; (c) for the proper administration of our business; and/or (d) to keep records as required by law.
We will not retain your Personal Data for longer than necessary for the purposes for which it was collected as set out in this Privacy Statement. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements, and your expectations and requirements. When it is no longer necessary to retain your Personal Data, we will securely delete it or anonymize it.
4. HOW WE SHARE YOUR PERSONAL DATA
Your Personal Data may be shared with others as described below:
1. We may disclose your Personal Data to any member of our group of companies, affiliates, resellers, suppliers, and service providers, including advertising networks, as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Statement.
2. We may disclose your Personal Data to our insurers and professional advisers as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or other legal proceedings.
3. We may disclose your Personal Data with our payment services providers to complete financial transactions. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4. In addition to the specific disclosures of Personal Data set out in this section, we may disclose your Personal Data: (a) where such disclosure is necessary for compliance with a legal obligation to which we are subject, including a subpoena, court order or search warrant; (b) enforce our Terms of Service, this Privacy Statement, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims regarding violations of third party rights; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of UrbanLab and its employees, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, or in order to protect your vital interests or the vital interests of another natural person.
5. SENSITIVE PERSONAL DATA
Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Sites or otherwise to us, Sensitive Personal Data (e.g., religion, ethnicity, political opinions, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions) unless specifically requested by us or required by law.
6. INTERNATIONAL DATA TRANSFERS
UrbanLab is a global business based in the United States. UrbanLab’s, and our affiliated companies, have offices and facilities in worldwide locations including, the European Union/EEA, Latin America, Asia, Africa, etc. Your Personal Data may be transferred to other UrbanLab’s entities, as well as to third party service providers who may process your Personal Data on our behalf, including e-marketing service providers, hosting providers, etc.
Our customers and the users of our Sites may be located anywhere in the world. The privacy laws in some countries may not provide protections equivalent to those in your country of residence, and your government may or may not deem such privacy protections adequate. We may process your information in, or transfer your information to, the United States, third parties in the United States, or other countries.
For residents of EU/EEA countries, in the event of transfer of your Personal Data to a country which has been deemed to have an inadequate level of protection for Personal Data, we will implement safeguards, including selecting “Privacy Shield” certified processors or putting in place standard contractual clauses, in accordance with the EU requirements.
7. PERSONAL DATA SUBMITTED BY CHILDREN
Some of the content on our Sites may be directed toward children under age 13. However, we do not knowingly collect or solicit personal information from children under age 13 without parental consent, unless permitted by law. If we become aware that we have collected personal information from a child under age 13 without parental consent or unless otherwise permitted by law, we will delete it in accordance with applicable law. If you believe that a child may have provided us with Personal Data without parental consent or otherwise not permitted by law, please contact us as detailed below in the “Contact Us” section.
California consumers – We will not sell the information of California consumers who are 16 years old or younger without prior authorization. Our sites and services directed toward children will verify a user’s age and offer choices regarding the sale of personal information related to children aged 16 or younger. If a California consumer is under 13 years old, a parent or guardian must consent to the sale of the minor’s personal information. However, if the California consumer is between the ages of 13 and 16 years old, the minor may provide opt-in consent to the sale of their personal information. Our sites directed toward children will ask for age verification and require appropriate consent.
EU Residents– We do not collect or process personal data related to EU Data Subjects under the age of 16 without explicit consent from a parent or guardian. Our sites directed toward children will ask for age verification and require consent as appropriate.
8. COOKIES, WEB BEACONS AND OTHER TRACKING TECHNOLOGIES
Some of our business partners set web beacons and Cookies on our site. In addition, third-party social media buttons may log certain information such as your IP address, browser type and language, access time, and referring website addresses. Further, if you are logged in to those social media sites, they may also link such collected information with your profile information on that site.
If you would like to opt-out of cookies, visit www.aboutcookies.org or www.allaboutcookies.org for further information. These websites also tell you how to set your browser not to accept cookies and how to remove cookies from your browser. However, in a few cases, some of the features on our Sites may not function as a result.
There is no perfect security. We have implemented appropriate and commercially reasonable organizational, technical and administrative safeguards to protect Personal Data. You are responsible for maintaining the secrecy of any credentials that can be used to access any account or service with UrbanLab. If you should suspect any unauthorized activity please report this to us immediately.
10. LINKS TO THIRD PARTY SITES
We may collect your information from third parties sites. This includes when you log in through a third party site such as Facebook, Snapchat, Instagram, LinkedIn, Twitter, etc. We may also disclose information collected from third parties to customize ads and to manage and facilitate messaging on third party sites. Please note that when you unsubscribe from our marketing email there may be a delay in the discontinuation of our ads directed to you on third party sites.
11. DO NOT TRACK
UrbanLab does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, you may be able to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
12. USING MOBILE AND OTHER DEVICES
UrbanLab, our affiliates and third parties that we have engaged, may collect and store unique identifiers matched to your mobile device in order to deliver customized ads or content while you use our Sites, navigate the internet, to deliver location-based services and advertising, or to identify you in a unique manner across devices or browsers. In order to customize these ads or content, we, or third parties, may collect Personal Data, e.g., your email address, or data passively collected from you such as your device identifier, location, or IP address. Most mobile devices allow you to turn off location services.
By adjusting the privacy and security settings on your device, you can manage how your mobile device and mobile browser share information, as well as how your mobile browser handles Cookies and other tracking identifiers. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
13. EMAIL MARKETING COMMUNICATIONS
If you are an existing customer or, if required by applicable law, you have provided consent or have not otherwise directed us not to send you marketing messages, we may send you marketing messages via email and/or mail to keep you updated on our products and services.
You can stop receiving marketing messages from us at any time through the following methods:
- Through your customer account settings/preferences within “My Account”;
- By clicking on the ‘unsubscribe’ link in any email communication we send you
- By contacting us at firstname.lastname@example.org
Once one of these methods is completed, we will honor your request and update your profile to ensure that you don’t receive further marketing messages.
We will process opt-out/unsubscribe requests as quickly as possible, and in most cases, within 10 days. However, UrbanLab is made up of a complex web of many inter-connecting companies and service providers so it may take time for all our systems to reflect these updates. We ask for your understanding that during this period you may still get messages from us while your request is being processed.
Please note that the discontinuation of marketing messages will not stop any service communications such as order updates.
14. TEXT MESSAGING
Our Sites may give you the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you have shared with us. Once you have opted-in, we may send you text messages regarding your account, to investigate or prevent fraud, to alert you in the event of an emergency, etc. We may send you text messages and alerts using autodialed technology. Also, from time to time, we may run certain campaigns that provide you with the ability to send a text message to a specific short code and provide an opt-in to receive future text messages. Your opt-in request provides us with your mobile phone number. If you choose to opt-in, you agree that we may, from time to time, send messages to the mobile device associated with that number about new products, promotions, services, or offers.
You may choose to opt-out from our text messages and alerts at any time by replying “STOP” to the message you received. Once you opt-out, you will not receive any additional text messages via your mobile phone. Please keep in mind that if you opt-out of receiving text messages and alerts we may not be able to contact you with important messages regarding your account or transactions with us. However, if there is an emergency or account question, we will make every attempt to contact you in other ways such as by email or on a landline phone. You do not have to opt-in to text messages and alerts to use our Sites and services. If you opt-in, standard text messaging charges may apply.
15. CHANGES TO OUR PRIVACY STATEMENT
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