We may also apply different or additional privacy notices in connection with certain activities, programs and offerings. Our privacy practices are subject to applicable laws in the places in which we operate, which means we engage in the practices described in this Policy in a particular country only as permitted under the laws of such jurisdiction.
If you are a California resident, please see “Additional Disclosures for California Residents”. If you are an United Kingdom or European Union resident, please see “Additional Disclosures for European Residents” below.
- Information We Collect
- Use of Your Personal Data
- How We Share Your Personal Data
- Your Rights and Choices
- Advertising and Analytics Services Provided by Others
- Third Party Links and Social Media Platforms
- Data Transfers
- European Residents
- California Privacy Rights
- Updates to this Policy
- Contacting Us
Information We Collect
Personal data means any information from which you may be identified directly or indirectly. The types of personal data we collect depends on how you interact with us or use our Services.
Information You Provide to Us. We may collect the following categories of personal data from you:
- Contact information, such as your name, email address, mailing address and phone number;
- Account information, such as your email address, password, reward information and benefits;
- Purchase information, such as the types of products or services requested, order details, delivery information, payment details, billing or shipping information and return or exchange information. Please note that we do not store complete credit/debit card information;
- Optional information you may choose to provide, such as your month/day of birth, social media handles, gift card and refer-a-friend recipient information; and
- Any other information you choose to provide, such as product reviews, responses to surveys or quizzes, information to participate in a contest or promotion, marketing preferences, or to receive customer support.
Information We Collect From Other Sources. We may also obtain information from other sources and combine that with information we collect from you, such as from:
- Other users. If you choose to participate in our refer-a-friend program or purchase an e-gift card for someone else, we may collect information about your friend (such as a name and email address) in order to invite your friend to shop with us or send them their e-gift card.
- Third-party social media services. We may collect information such as photos, posts, likes and your engagement with our content on a social media platform.
- Partners. Occasionally, we will partner with third parties on social media and online channels to sponsor giveaways and promotions. Terms and conditions will accompany each giveaway and promotion, and it is the responsibility of all entrants to read the applicable terms and conditions and privacy policies carefully to understand how their information will be collected and processed by us and our third party partners in connection with such giveaways and promotions. If you choose to share your information in order to participate in a giveaway or promotion, your entry information may be shared with such third parties. We may also receive information about you from our corporate partners as part of our corporate gifting program.
- Data providers. We may collect additional information about you from data co-ops, data licensors or card-linked offer partners that provide contact, profile, demographic and other information, such as information about your household, interests, education background and your and your household’s purchasing history. These providers include mailing list providers, advertising networks, media monitoring companies and data co-ops. Some of these providers may combine data collected about visitors to our Services through cookies, pixel tags and similar technologies, with email or mailing addresses they have access to help us serve relevant marketing offers to you via email and direct mail. Information we receive from these sources may supplement information provided by you.
Information We Derive Or Infer. We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.
Information we collect by automated means. We automatically collect certain personal data when you access and use our Services, interact with our communications or shop in our stores. To collect this information, we (and our partners) may use tracking technologies, such as cookies, web beacons and similar technologies. We may also collect information about your online activities over time and across third-party websites. The types of information we collect may include:
- Device and Network Data. We collect certain information about the device you use to access our Services such as, your device’s hardware model, browser type, IP address, operating system version, language settings, unique device identifiers, advertising identifiers, and mobile network data.
- Usage Data. We collect information about your activity on our Services, such as your access times, pages viewed, email opens, the routes by which you access our Services, links clicked and other system activity, your internet service provider (ISP), MAC address, mobile advertising ID, and identifiers associated with browser cookies, web beacons and similar technologies we deploy on our Services. We, and our service providers, may also collect usage data that includes mouse movements and how you scroll through our website, but we do not collect keystroke data.
- Video Data. We collect information through closed circuit TVs for security monitoring or geofencing to identify traffic in our offices or stores.
We may associate this information with your Our Place account if you have one, the device you use to connect to our Services, or email or social media accounts that you use to engage with Our Place. For more information about cookies and how to disable them, please see “Your Right and Choices” below.
Use of Your Personal Data
In general, personal data you submit to us is used either to respond to requests that you make, aid us in serving you better or market our Services. We use your personal data to:
- Provide Products and Services. Provide, maintain and improve our Services, products, data and events.
- Complete Transactions. Complete the transactions you request, perform our contractual obligations, and use your personal data as otherwise anticipated within the context of our ongoing business relationship;
- Manage Accounts. Create and manage your online accounts and profiles and Our Place memberships, including for loyalty programs;
- Service Communications. Send notifications related to your account, purchases, exchanges and returns, technical notices, security alerts and information regarding changes to our policies.
- Respond to You. Respond to your requests and any other communications from you, including to provide customer service.
- Advertising and Marketing. Send advertising or marketing communications about Services, offers, products, promotions, rewards and events offered by Our Place and others, and provide news and information that we believe may be of interest to you, all as permitted by applicable law;
- Offers and Events. Offer, conduct and administer loyalty programs, events, classes, contests, prize draws, sweepstakes and other promotions;
- Research and Development. Conduct research and development, including surveys and other market research;
- Facilitate Engagement. Facilitate and measure your engagement with the Services and social media engagement with our brand, including to enable you to post comments and reviews and post on social media;
- Personalize Your Experience. Monitor, analyze and audit your engagement with our brand and your interactions with our Services and online ads to better understand your interests and behaviors and customize your experience, including the ads you see when you use the Services or third-party platforms based on your preferences, interests, purchase history and browsing behavior;
- Safety and Security. Detect, investigate, respond to and protect against malicious, deceptive or illegal or objectionable activity, including fraudulent transactions, error, negligence, and breach of contract, security incidents, and harm to the rights, property, health or safety of Our Place and our users, customers, employees or others;
- Troubleshooting. Debug, identify and repair efforts that impair existing or intended functionality of our Services;
- Corporate Transactions. We may process personal data in the context of corporate acquisitions, mergers or other corporate transactions, including in the process of diligence activities related to such transactions;
- Your Consent. We may process your personal data in accordance with your consent or instructions;
- Comply with Legal Obligations. We will process personal data to comply with our legal or regulatory obligations, including tax obligations and those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions; and
- Reasonable Other Purposes. As permitted by applicable law, we may process personal data to carry out certain short-term activities and other reasonable purposes related to the products or Services you purchase from us or your ongoing relationship with us. Where required by applicable law, we will provide a notice of such data processing prior to using your personal data for such purposes.
How We Share Your Personal Data
- Within Our Place. We may disclose certain of your personal data to Our Place’s current and future parents, subsidiaries and affiliates under common ownership or control with Our Place and its respective personnel (such as our customer service team) who need to know the information for the purposes described above.
- Business Partners. We may share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint promotions or marketing activities.
- Professional Advisors. We may share information about you with our professional advisors, including our accountants, auditors, lawyers, insurers and bankers in connection with the kinds of corporate transactions described below or in connection with the management of all or part of our business or operations.
- Data Providers. We may use data providers such as Oracle, Epsilon and Wiland, with whom we share limited information about our customers in the United States and Canada (“Data Providers”) including customer names, addresses and transaction history, so that these Data Providers can help us identify individuals in the United States and Canada most likely to be interested in our direct marketing communications. Our Data Provider’s use of this information is subject to their own privacy policies, which generally allow them to share the information they collect with other customers. You can learn more about how our Data Providers collect, use and share personal data and your choices for limiting how they use and share your personal data, by visiting the following web pages: Oracle, Epsilon and Wiland. If you prefer that we not share your personal data with our Data Providers, you can notify us at any time by using the contact details below.
- Advertising Companies. We work with third party advertising companies (such as advertising networks) to serve advertisements on our behalf or to understand how our ads are working and analyze their performance and online interaction with them, which helps us improve our targeted ad campaigns. For additional information, see the "Advertising and Analytics Services Provided by Others" section.
- Other Third Parties. In certain limited circumstances, we share and/or are obligated to share your personal data with other third parties, where we have a good faith belief that such sharing is necessary, including (a) to comply with our obligations, enforce our policies and contracts, or establish or defend a claim; (b) to respond to your requests; (c) cooperate with law enforcement investigations or a legal process; (d) to detect and respond to actual or suspected loss or harm and to protect your, our or others’ rights, property, health or safety; (e) if we believe that access, preservation, or disclosure is otherwise necessary or advisable; and/or (f) with your consent and at your direction.
- Other Users. Any content you post on our website, such as when you provide a product review or post other user content, may be publicly posted on our website and other websites. Other users may be able to see your name or other information about you that you post. Please be careful when posting information publicly to not share unnecessary personal data.
- Business Transactions. In connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing, or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings), your information may be shared, sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, Our Place will endeavor to direct the transferee to use personal data in a manner that is consistent with the Policy in effect at the time such personal data was collected.
- Aggregated, Anonymized or De-Identified Data. In certain instances, where permissible under applicable law, we may also share aggregated, anonymized or de-identified information that cannot reasonably be used to identify you with third parties at our discretion.
Your Rights and Choices
Opting Out of Marketing Communications.
- Promotional Emails. You may unsubscribe from our promotional emails at any time by using the unsubscribe button at the bottom of the email. If you opt out of receiving such communications, note that we may continue to send you non-promotional emails (such as order confirmation emails or emails about changes to our legal terms).
- Text Messages. You may unsubscribe at any time by replying “STOP” to any mobile message sent from us.
- Direct Mail. If you would like to opt-out of receiving communications via postal mail, please email email@example.com.
Do Not Track. Like many other websites, our website does not currently respond to Do Not Track (DNT) signals, but you can learn more about, and opt-out of, targeted advertising by adjusting your cookie settings, as described above.
Advertising and Analytics Services Provided by Others
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting and other providers to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
We may also work with third parties to serve ads to you as part of a customized campaign on third-party platforms (such as Facebook or Google). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
Our Services are intended for general audiences and are not directed at children. If we become aware that we have collected data without legally valid parental consent from children under an age where such consent is required, we will take reasonable steps to delete it as soon as possible.
Third Party Links and Social Media Platforms
We may provide links to third-party websites, services, plug-ins and applications, such as Facebook and Google, that are not operated or controlled by us. When you click on a link to any other website or location, you will leave our site and go to another site. This Policy does not apply to such third-party sites or services, and we cannot take responsibility for the content, privacy policies, or practices of third-party sites or services. We encourage you to review the privacy policies of any third-party sites or services before providing any information to or through them. The links to third party websites or locations are for your convenience only and do not signify our endorsement of such third parties or their products, contents or websites.
The Services may offer social sharing features and other integrated tools (such as the Facebook "Like" or "Share" button or the Twitter “Tweet” button) which let you share actions you take on our Services with other media. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Our Place is based in the United States. If you are accessing the Services from outside the U.S., please be aware that your information will be processed in the U.S. as well as potentially be transferred to recipients in other countries, including but not limited to the United States and United Kingdom. Some of the counties to which data may be disclosed may be countries where data protection laws may be less stringent than the laws in your country. Where we transfer personal data from the European Union, United Kingdom or Switzerland to the United States, we do so in reliance on an approved data transfer mechanism, such as the Standard Contractual Clauses adopted by the European Commission. By using our Services and providing any information, you are consenting to the transfer and processing of your information in accordance with this Policy.
The security of your personal data is important to us. While we maintain a variety of physical, technical and administrative security measures to protect your personal data, we cannot guarantee that the Internet is 100% secure; any transmission is at your own risk. You are responsible for keeping your account password confidential. By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. If we learn of a security breach impacting you, we may attempt to notify you electronically by posting a notice on the Services or sending an email to you.
Any payment transactions are handled by Shopify, PayPal, Apple Pay, Google Pay, Klarna or another payment provider and their 3rd parties, depending on your region. All direct payment gateways are required by law to adhere to the security standard set by the Payment Card Industry Data Security Standard (PCI-DSS). For information on how Shopify handles your personal data, please visit: https://www.shopify.com/legal/privacy.
We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose such as to conduct audits, enforce our agreements, comply with applicable laws, establish legal defenses, pursue legitimate business purposes and resolve disputes. When we no longer need to use your personal data, it is removed from our systems and records or anonymized so that you can no longer be identified from it in accordance with applicable law.
Legal Basis for Processing: If you are a European Resident, we process your personal data when:
- We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products you have ordered).
- We have a legitimate interest in processing your personal data. For example, we may process your personal data for performing marketing activities, to conduct data analytics and to provide, secure, and improve our Services.
- We need to do so to comply with a legal obligation to which we are subject.
- We need to do so to protect your vital interests or those of others.
- We have your consent to do so (e.g., promotional emails), which you may withdraw at any time.
Data Subject Requests: If you are a European Resident, you are entitled to (i) access personal data we hold about you, (ii) ask that your personal data be corrected, updated, or erased, (iii) object to, or request that we restrict, certain processing, (iv) transfer personal data about you to another entity where technically feasible or (v) withdraw your consent to our processing of your personal data if we relied on consent as the legal basis for processing, in each case subject to certain exceptions. If you would like to exercise any of these rights, you may email firstname.lastname@example.org. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access or making any changes to your personal data and will process your request in accordance with applicable law. If you have an Our Place account, you may also review, update, and delete certain personal data by logging into your account.
Questions or Complaints: You may contact us as described in the “Contact Us” section below. If you have a concern about how we process personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you live. For contact details of your relevant local Data Protection Authority, please see here or, if you are a resident of Switzerland, see here.
California Privacy Rights
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal data. If you are a California resident, this section applies to you.
California Consumer Privacy Act (“CCPA”)
In the preceding 12 months, we have collected the following categories of personal information (as defined in the CCPA) from and about you: identifiers; commercial information; demographic information (note that some demographic information may be considered characteristics of protected classifications under state or federal law); internet or electronic network activity; geolocation data; audio, electronic, visual, or similar information; inferences; and other categories of personal information that relates to or is reasonably capable of being associated with you. For examples of the precise data points we collect, please see “Information we Collect” above. We collect personal information for the business or commercial purposes described in the “How We Use Your Information” section above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients:
Category of Personal Data
Categories of Recipients
Identifiers and Contact Information (e.g. name, email address)
Advertising networks, marketing partners, data analytics providers, market research platform, payment processors, fulfilment partners, customer support partners, Internet service providers, operating systems and platforms, Data Providers, events and promotions partners, other users, fraud prevention partners, cloud service providers, technical maintenance and system security providers
Commercial Information (e.g. purchase info, payment details)
Data analytics providers, advertising networks, marketing partners, Data Providers, market research platform, payment processors, fulfilment partners, customer support partners, and fraud prevention partners, cloud service provider
Characteristics of Protected Classifications under state or federal law, such as age
Advertising networks, marketing partners, market research platform, customer feedback platforms
Internet or other electronic network activity
Advertising networks, marketing partners, data analytics providers, Internet service providers, operating systems and platforms, customer support partners, cloud service providers, fraud prevention partners, technical maintenance and system security providers
Geolocation data (e.g. IP address, shipping address)
Advertising networks, marketing partners, data analytics providers, Data Providers, Internet service providers, operating systems and platforms
Audio, electronic, visual, or similar information
Customer support partners, market research platform, security partners
Advertising networks, internet service providers, data analytics providers, customer support partners, fraud prevention partners, cloud service providers
Sale of Personal Data. California law requires that we provide transparency about the personal information we "sell," which for the purposes of the CCPA broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. Our Place does not sell your personal information to other companies for money; however, we do allow our advertising partners to collect certain information to show you ads that are targeted to your interests and share information with Data Providers (as described above), which may be considered a “sale” in California. In the preceding 12 months, we have allowed our advertising partners and Data Providers to collect identifiers, commercial information, and Internet or other electronic network activity information for targeted advertising and direct mail purposes. Please review the “How We Share Information” section for more details about the parties we have shared information with. You have the right to opt out of having your personal information used for targeted advertising at any time by clicking the “Do Not Sell My Personal Information” link in the website footer or by emailing email@example.com. We do not knowingly sell personal information about consumers under the age of 16.
Your Rights. In addition to the right to opt out of sales explained above, subject to certain limitations, California consumers have the right to (1) request to know more about the specific pieces and categories of personal information we collect, use, sell and disclose, (2) request deletion of their personal information, and (3) not be discriminated against for exercising their rights. You may make a request to know more about or delete your personal information by submitting by emailing firstname.lastname@example.org or submitting this form. After submitting a request, you will be required to verify your identity. Please note that we may retain certain information as required or permitted by applicable law. If you request to delete your personal information, certain of our products and services may no longer be available to you, including membership to our Dirty Dishes Club.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
Notice of Financial Incentives. We offer various financial incentives. For example, we may provide discounts, special offers, free gifts or other benefits to customers who sign up to receive our marketing communications, join a customer rewards program, or enter a contest, sweepstakes or other similar promotional campaigns (collectively, the “Programs”). When you participate in a Program, we collect personal information from you, such as identifiers like your name and email address. You can opt into a Program by following the sign-up instructions, and you have the ability to opt-out at any time by contacting us. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. In offering the Programs, we consider the value of the free or discounted products or service or other benefits we offer as well as our expenses in offering the Program and ensure that the benefits we offer to consumers are reasonably related to the value of collecting consumers’ personal information to us, such as by being able to reach them with marketing communications or better understand their preferences.
Shine the Light. California law permits residents of California to request certain details about how their personal information is shared with third parties for those third parties’ direct marketing purposes or to opt out of such sharing. If you are a California resident and would like to make such a request, please contact us at email@example.com. Our Place may share personal information with third parties for their own marketing purposes as described herein or as you may consent.
Updates to this Policy
We reserve the right to change this Policy from time to time. If we make changes, we will notify you by posting an updated policy on our sites and will indicate when the Policy was last revised.
If we make material changes to this Policy impacting you, we will provide you with additional notice (such as adding a statement to our websites’ homepage or sending you a notification). Continuing use of our Services following notice of such changes will indicate your acknowledgement of, and agreement to, such changes. You should periodically review our current Policy to stay informed of our practices.
Last Updated: May 24, 2022