Wilton Online Privacy Policy

California Privacy Notice

Privacy Shield Policy for Wilton Brands LLC

Residents of the European Union (EU) and European Economic Area (EEA)

Wilton Online Privacy Policy

Updated and effective January 1, 2020.

This privacy policy (“Privacy Policy”) applies when you access, visit, or use any of the websites, mobile applications, features, widgets, or other online services that are owned and operated by Wilton Brands LLC or its affiliates or subsidiaries (“Wilton,” “we”, “us” or “our”) and that include a link to this Privacy Policy (each, a “Site” and collectively, “Sites”) and to information collected offline by Wilton. By accessing, visiting, using, or submitting information to any Site or providing information to us offline, you agree to the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use any Site. Please review our Terms of Use, which also applies to your use of any Site.

Table of Contents

  1. General Audience Site.
  2. Information Collected by Wilton.
  3. Third-Party Analytics Providers, Ad Servers, and Similar Third Parties.
  4. User Content and Submission Features.
  5. Social Media Features.
  6. Use of Information We Collect.
  7. Sharing Information with Third Parties.
  8. Security.
  9. Third-Party Links and Content.
  10. International Transfer of Personal Information.
  11. Corrections/Deletion/Opt-Out.
  12. Inquiries and Complaints.
  13. Closing Your Account; Retention of Information.
  14. Changes to the Privacy Policy.
  15. Contact Information.
  16. Notice to Nevada Residents
  17. Notice to California Residents

1. General Audience Site

The Sites are intended for a general audience and are not intended for use by or targeted to children younger than the age of 16. We do not knowingly collect personal information from children younger than the age of 16. If you are the parent or legal guardian of a child younger than age 16 and believe that we have collected personal information from your child, please contact us using the information in the “Contact Us” section below.

2. Information Collected by Wilton.

A. Information You Directly and Voluntarily Provide: We may collect information from you through various features when you visit one of our Sites or interact with us offline. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual (such as your name, phone number, and email address) to be personal information. We will also treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. Some of the information that we may collect from you, and the features through which we may collect that information, include:

  • Accounts. We collect your name and email address and may also collect other personal information, such as your address and telephone number, when you create an account on a Site (which may include accounts on The Wilton School or Careers portal); we will also require you to create a user name and password for each account. We collect the payment information that you choose to save to an account. We collect the employment and other information that you choose to save to or submit through a Careers portal account.
  • Payment, Shipping, and Delivery. We collect payment information when you pay for an order or a class and collect shipping and delivery information for products that you buy.
  • Contact Us. We collect your name, email address, other contact information and any additional personal information that you provide when you communicate with us through a Site, such as through the “Contact Us” feature.
  • Share by Email. If you use a Site’s “Email a Friend” feature to share by email, we will ask you for the recipient’s personal information (i.e., email address) and will use your email address to identify the “sender.”
  • Newsletters Features. We collect your email address and may collect other personal information you choose to provide if you “opt in” to receive promotional email communications from us.
  • User Content and Submission and Social Media Features. We collect the personal information that you provide when you submit User Content (as described in Section 4) or participate in Submission Features (as described in Section 4) or Social Media Features (as described in Section 5).

We may take your personal information and de-identify it so as to make it non-personally identifiable, either by combining it with information about other individuals and/or by hashing the information (i.e., converting it into an alphanumeric code that does not identify you directly) or otherwise removing characteristics that make the information personally identifiable directly to you. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law. We may also collect other information that is not personal information, such as demographic information (i.e., age and gender) and information regarding use of a Site. (We will treat this information as personal information only where required by applicable law.)

B. Information that We Automatically Collect:

We or our service providers collect certain information whenever you access or interact with a Site (“Usage Information”) using a variety of tracking and other technologies, such as cookies, local storage, web beacons, embedded scripts, and location data services. These tracking technologies may transfer a unique identifier for your device to a browser, place a cookie on your device, temporarily download code to your device, or use other means to track your access or interactions.

To get information about cookies from All About Cookies.org, click here. If you disable cookies, adjust privacy settings on your device, restrict local storage, or otherwise limit these technologies, you may not be able to use some Site features.

We use these technologies for many purposes, including to make your use of a Site more convenient and to track total visitors on an aggregate basis. The information we collect may include (but is not limited to):

  • Date and time of your visit to a Site.
  • Areas you visit within a Site.
  • Links that you click on within a Site.
  • Websites or advertisements you visit before or after visiting a Site.
  • Terms you entered into a search engine that lead you to a Site.
  • IP address, mobile device identifier, or other unique identifier (“Device Identifier”) and other Usage Information for the device used to access a Site.
  • Precise location data from your device, if you have opted-in to the collection of that information. (You may be able to disable the collection of precise location data through the settings on the device used to access a Site, but your approximate location may remain available through its IP address or other information that we collect.)
  • Device and connection information, such as browser type and version, operating system, and platform.
  • Whether an email message we sent was opened and whether a link in the email message was clicked.

C. “Do Not Track” Requests. Some browsers can be set to send a “Do Not Track” request that requests that a website not track the visitor’s activity. Currently, our Sites do not stop tracking in response to those requests except as specifically required by law. For information about “do not track” from The Future of Privacy Forum, click here.

D. Information Third Parties Provide: We may receive information about you from third parties and we may supplement that information with the information we collect to respond to your requests, tailor content, offer you products or services that we believe may interest you, and for other purposes.

3. Third-Party Analytics Providers, Ad Servers, and Similar Third Parties. Wilton works with service providers, such as analytics companies, network advertisers, agencies, and others who provide us with information about the Sites, Site users, and our advertisements, and who serve our advertisements elsewhere. We and our service providers collect certain information about your visits to and activity on our Sites and other websites and services and may use this information to target advertising to you and others and to assess the effectiveness of our advertising. We may share (or permit them to collect) certain information, such as Usage Information and deidentified information, with these service providers for similar purposes.

These service providers use their own tracking technologies and may collect or have access to your personal information over time and across websites.

Some of these service providers may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. Both NAI and DAA provide information regarding procedures for opting-out of targeted online advertising from participating companies. For information from NAI about opting out, click here. For information from DAA about opting out click here.

We also use Google Analytics, which uses cookies and other technologies to collect and analyze information about use of the Sites and provide other reports. This service may also collect information regarding your use of other websites, apps, and online resources. For information about opting out from Google, click here, and to download the Google Analytics opt-out browser add-on from Google, click here.

Opting out through these mechanisms does not block all online advertising; you will continue to receive generic advertisements.

4. User Content and Submission Features. A Site may permit you to submit or post photos, audio, video, text, files, social media posts, or other content (“User Content”) through interactive or other features, such as product reviews, discussion forums, blog comments, gallery posts, or promotional activities (“Submission Features”). Your submission of User Content is subject to the Terms of Use for the Site (including the User Content and Acceptable Use terms) which give us the right to use your User Content, online or offline, in connection with our promotional activities. Personal information, such as your name, user name (from a Site or your social media account), or where you reside, may be publicly displayed with your User Content. Others may access it, use it, and share it. We are not responsible for how others use User Content you submit or post. In addition, in connection with certain activities, your personal information may be disclosed publicly, for example, being identified as a winner of a sweepstakes or being awarded a prize.

Some features that allow Site users to submit User Content are operated by third parties and any content submitted through such feature may be provided directly to the third party and subject to that party’s own privacy policy, as disclosed at the time of submission.

5. Social Media Features. A Site may permit you to interact with a third-party platform (such as Facebook, Instagram, or Twitter) and the Site, for example “liking” or “sharing” content from a Site, posting your social media posts to a Site, including a hashtag associated with us in your social media post, or creating an account or registering with a Site using existing login information from a third-party platform (“Social Media Features”). Your use of Social Media Features is subject to the Terms of Use for the Site (including the User Content and Acceptable Use terms) which give us the right to use your interaction, online or offline, in connection with our promotional activities.

If you use Social Media Features, your interaction and personal information may be publicly disclosed on the Sites and on the third-party platform. We and the third-party platform may have access to information about you and your use of the Sites and the third-party site. If others give us access to their profile, page, or other content on a third-party platform, we may also receive information about you if it is accessible through that content.

The information we collect in connection with Social Media Features is subject to this Privacy Policy; the information the third-party platform collects is subject to the third party’s privacy practices (including whether the third party shares information with us, the types of information shared, and your choices about what is visible to others on the third-party platform).

6. Use of Information We Collect. We use information we collect:

  • To enable you to use a Site or other services we offer, such as maintaining your account information, fulfilling your orders, accepting your payments, shipping and delivering your orders and email messages, and processing information you provide to us, including verifying that your email address is active and valid.
  • To communicate with you and send you information--by email, mail, telephone, text message, or other means--about us and our Sites, products, services, and activities. For information on how to opt-out of promotional communications from us, see Section 11.
  • To contact you about administrative matters, such as changes to our Privacy Policy, Terms of Use, or other policies.
  • To tailor the content and advertising we display to you or others, on a Site or elsewhere, and to analyze trends and statistics.
  • To create advertising models through lookalike modelling or other research methodologies.
  • To provide customer service, such as responding to your questions, complaints, or comments and getting your feedback.
  • For internal business purposes, such as improving our Sites, products, and services and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies.
  • To consider an employment application you submit through the Careers portal, including as described in Section 7.E.
  • For other reasons that we disclose when you provide your information, with your consent, and as described in this Privacy Policy.

7. Sharing Information with Third Parties. We may share non-personal information with third parties. We may also share personal information: (i) as disclosed when you provided it, (ii) with your consent, (iii) as described elsewhere in this Privacy Policy, and (iv) in the circumstances described below – all as permitted by applicable law:

A. Service Providers: We use third parties to provide services to us or on our behalf, such as operating and supporting a Site, maintaining accounts, operating the Wilton School portal, Careers portal, and Blog portal, fulfilling orders, processing payments, shipping and delivery, sending newsletters and email messages, analyzing data, or performing marketing or consulting services. We give these service providers access to your personal information (or allow them to collect information from or about you) so that they can provide the services.

B. When You Agree to Receive Information from Third Parties or Request That We Share Your Information: We do not share personal information with any third party for the third party’s own direct marketing purposes unless we first provide you with the opportunity to agree (by opting-in or electing not to opt-out). If you opt-in or if you do not opt-out at the time choice is provided, your personal information will be disclosed to that third party and will be subject to the third party’s privacy practices

C. Law Enforcement and Protection of Users: To the extent permitted by law, we will disclose your personal information to government authorities or third parties pursuant to a subpoena or other legal request or process. We may also use or disclose your personal information as permitted by law to enforce or protect the rights or property of us, our customers, or business partners. Information that we disclose in this way may become available to others.

D. Business Transfers and Transitions. We may, in evaluating or engaging in a sale of assets, bankruptcy, merger, or other transaction, transfer or assign your personal information, which you agree that we may do without your further consent. We may also share your personal information with any parent company of ours for business and operational purposes.

E. Employment Applications. If you submit an employment application through the Careers portal on a Site and voluntarily “self-identify” in certain ways (e.g., veteran status or gender), we may use your personal information to fulfill legal reporting requirements or to defend against employment-related claims.

8. Security. We take commercially reasonable steps to secure information. For example, the checkout process uses SSL (Secure Socket Layer) technology to help protect the transaction. No computer system is fully secure, however, and there are inherent risks associated with online transactions. You use a Site and submit information to us at your own risk.

9. Third-Party Links and Content. A Site may contain links to other web sites that Wilton does not control, and advertising and other content hosted and served by third parties. Wilton is not responsible for the privacy practices of any third party.

10. International Transfer of Personal Information. Wilton is a United States company. If you are outside the U.S. and choose to provide personal information to us, we may transfer personal information for processing to the U.S. and other jurisdictions (including Germany, where our parent company is located). These jurisdictions may not have the same data protection laws as the country where you are located. When we transfer your personal information to the U.S. or other jurisdictions, we will protect it as described in this Privacy Policy. By visiting a Site or providing information, you agree to the transfer, processing, and storage of your information in the U.S. and elsewhere.

11. Corrections/Deletion/Opt-Out. You may update, correct, or delete the personal information you have provided by contacting us at privacy@wilton.com. We will take commercially reasonable steps to make changes in our active databases but will keep the original information consistent with our business practices (e.g., recordkeeping, backup, and document retention). To opt out of promotional email communications from us, email us at privacy@wilton.com or click on the unsubscribe link in a promotional email you receive from us.

12. Inquiries and Complaints. You may request information about how, where, and why we collect and use your personal information, including how we share your personal information with third parties, by contacting us at privacy@wilton.com. You may file a complaint with us in connection with the collection, use, or processing of your personal information under this Privacy Policy by contacting us at privacy@wilton.com. We will take reasonable steps to remedy any issues relating to our obligations relating to your personal information.

If you are a California resident, please see our “Notice to California Residents” section below regarding additional rights you have.

13. Closing Your Account; Retention of Information. To instruct us to close your account, email us at privacy@wilton.com. We will retain information from closed accounts as necessary to comply with legal requirements and our business practices, resolve disputes, enforce our Terms of Use, and take other actions permitted by law.

14. Changes to the Privacy Policy. To the extent permitted by applicable law, we may change this Privacy Policy from time to time. We will notify you of material changes by posting the changed or modified Privacy Policy on each of our Sites. We may also notify you in other ways, such as through contact information you have provided. The revised Privacy Policy will take effect when posted unless a later date is specified. To the fullest extent permitted by applicable law, you agree that by accessing, visiting, or using any of the Sites or submitting information to any of the Sites or in-store after the effective date (or taking any other action as specified in the revised Privacy Policy), you agree to the revised Privacy Policy. However, we will provide notice and obtain your consent (opt-in or opt-out) if required by law. Note that you may need to consent to our new policy in order to continue to use the Sites.

15. Contact Information. If you have any questions or concerns about this Privacy Policy, please email us at privacy@wilton.com.

16. Notice to Nevada Residents

Pursuant to Nevada law, you have the right to opt-out of the sale of certain covered personally identifiable information we have collected about you through our websites and online services, as those terms are defined under applicable Nevada law. If you are a Nevada resident and would like to opt-out of the sale of your covered information, please submit your request to privacy@wilton.com. Your request must include your full name, street address, city, state, and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via such email address as needed regarding this request. If you previously provided a phone number to us, including it in your Nevada Opt-Out request email will assist us in identifying you and processing your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. We will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.

17. Notice to California Residents

A. California Privacy Notice

This California Privacy Notice is effective as of January 1, 2020.

This notice supplements Wilton’s Privacy Policy and applies only to California residents. This California Privacy Notice sets forth the disclosures and rights for California consumers regarding their personal information, as required by the California Consumer Privacy Act (“CCPA”). Terms used in this California Privacy Notice have the same meanings given in the CCPA and the regulations of the Attorney General implementing the CCPA, unless otherwise defined.

Information We Collect

Wilton collects 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”).

The following are the categories of Personal Information that we have collected from our users over the last 12 months (and examples of the types of information those include), the categories of sources from which that information was collected, the business or commercial purpose(s) for which the information was collected, the categories of third parties with whom we disclose the information for a business purpose, and the categories of third parties to whom each type of Personal Information is sold (if any).

The Personal Information we collect about you will depend upon how you use our Sites or otherwise interact with us. Accordingly, we may not collect all of the below information about you.

We may also collect and/or use additional types of information after providing notice to you before collection and obtaining your consent (to the extent such notice and consent is required by the CCPA).

Category of Personal Information Collected Categories of Sources from Which the Information was Collected Business or Commercial Purpose(s) for Which Business or Commercial Purpose(s) for Which Information is Collected Categories of Third Parties to Whom This Type of Personal Information is Disclosed for a Business Purpose Categories of Third Parties to Whom This Type of Personal Information is Sold
IdentifiersThis category includes information such as name, contact information, and online or device identifiers.

We may collect this type of information from:

  • Consumer (i.e., you),
  • Cookies and tracking technologies,
  • Third-party service providers,
  • Third-party social media companies,
  • Third-party business partners and data resellers.

This information is collected:

  • To enable you to use a Site or other services we offer;
  • To communicate with you and send you information about us and our Sites, products, services, and activities, as well as administrative matters;
  • To tailor the content and advertising we display to you or others (on a Site or elsewhere), to analyze trends and statistics, and to create advertising models;
  • To provide customer service;
  • For internal business purposes, such as improving our Sites, products, and services, and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies; and,
  • To consider an employment application you submit.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property.
  • Third-party advertising companies may have access to this data, including to better serve you more relevant advertisements, and this may be considered a sale under CCPA under certain circumstances.
Any categories of personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80 This category includes name, address, and phone number, information about your employment or education, and other categories of information classified as “personal” under this California law.

We may collect this type of information from:

  • Consumer (i.e., you),
  • Third-party service providers,
  • Third-party social media companies, and
  • Third-party business partners and data resellers.

This information is collected:

  • To enable you to use a Site or other services we offer;
  • To communicate with you and send you information about us and our Sites, products, services, and activities, as well as administrative matters;
  • To tailor the content and advertising we display to you or others (on a Site or elsewhere), to analyze trends and statistics, and to create advertising models;
  • To provide customer service;
  • For internal business purposes, such as improving our Sites, products, and services, and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies; and
  • To consider an employment application you submit.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property.
Characteristics of protected classifications under California or federal law This category includes information such as age, sex (including gender), and marital status.

We may collect this type of information from:

  • Consumer (i.e., you), and
  • Third-party business partners and data resellers

This information is collected:

  • To enable you to use a Site or other services we offer;
  • To tailor the content and advertising we display to you or others (on a Site or elsewhere), to analyze trends and statistics, and to create advertising models; and
  • For internal business purposes, such as improving our Sites, products, and services, and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property.
Commercial information This category includes, for example, information about your transactions with us, reviews you have written, your contacts with our customer service, and your participation in sweepstakes or contests we have offered.

We may collect this type of information from:

  • Consumer (i.e., you),
  • Third-party service providers,
  • Third-party business partners.

This information is collected:

  • To enable you to use a Site or other services we offer;
  • To tailor the content and advertising we display to you or others (on a Site or elsewhere), to analyze trends and statistics, and to create advertising models;
  • To provide customer service; and
  • For internal business purposes, such as improving our Sites, products, and services, and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies.

We may disclose this type of information to;

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property.
Third-party advertising companies may have access to this data, including to better serve you more relevant advertisements, and this may be considered a sale under CCPA under certain circumstances.
Internet or other electronic network activity information This category includes information such as information about the hardware and software you use to visit a Site, areas of a Site you visit, and login information (such as when you last logged into your Wilton account).

We may collect this type of information from:

  • Cookies and tracking technologies; and
  • Third-party service Providers,

This information is collected:

  • To enable you to use a Site or other services we offer;
  • To tailor the content and advertising we display to you or others (on a Site or elsewhere), to analyze trends and statistics, and to create advertising models;
  • To provide customer service; and
  • For internal business purposes, such as improving our Sites, products, and services, and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property.
Third-party advertising companies may have access to this data, including to better serve you more relevant advertisements, and this may be considered a sale under CCPA under certain circumstances.
Audio, electronic, visual, thermal, olfactory, or similar information This category includes, for example, images or videos you upload (which, depending on what they capture, could be considered Personal Information under CCPA)

We may collect this type of information from:

  • Customer (i.e., you); and
  • Third-party social media companies.

This information is collected:

  • to allow you participate in the Channels, or features or activities we offer; and
  • for our marketing and similar business purposes.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property.
Professional or employment-related information We may collect this type of information from you.

This information is collected:

  • To consider an employment application you submit.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99) We may collect this type of information from you.

This information is collected:

  • To consider an employment application you submit.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property
Inferences drawn from any of the information identified above to create a profile about a consumer These inferences may relate to your perceived interests, preferences, characteristics, or behavior. We may draw these inferences ourselves or acquire them from third-party data resellers or other business partners.

This information is collected:

  • To tailor the content and advertising we display to you or others (on a Site or elsewhere), to analyze trends and statistics, and to create advertising models; and
  • For internal business purposes, such as improving our Sites, products, and services, and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies.

We may disclose this type of information to:

  • Our parent company;
  • Service providers (like those described in Sections 3 and 7 of our Privacy Policy); and
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s rights or property
Third-party advertising companies may have access to this data, including to better serve you more relevant advertisements, and this may be considered a sale under CCPA under certain circumstances.

Exercising Your Rights

You have the right to request that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the specific pieces of Personal Information we have collected about you in the prior 12 months (“Right to Know”) and you have the right to ask us to delete the Personal Information we collect about you (“,b>Right to Delete”), subject to exceptions set forth in the CCPA. California residents also have the right to opt-out from the sale of their Personal Information. These rights are subject to some limitations, such as when we are retaining data to comply with our own legal obligations. You will not be required to create an account with us in order to submit a request. More information on each of these rights is below.

You may authorize an agent to submit a CCPA request on your behalf. We may require proof that an agent is duly authorized to act for you. Please keep in mind that if we do not receive adequate proof that the agent is authorized to act on your behalf, we may deny the request.

Response Timing

When you request access to the Personal Information we have collected or deletion of your Personal Information, we will typically provide the requested information within 45 days, and we will notify you within that time period if we need additional time to process your request.

Right to Know

1. Making A Request

To request the specific pieces of Personal Information we have collected about you in the prior 12 months, California residents can call us toll-free at 1-800-794-5866 or email us at privacy@wilton.com.

We will provide the requested information free of charge up to two (2) times in a 12-month period, but please note that where we receive unfounded, excessive, or repetitive requests, we may elect to decline the request. Note also that we will not retain information we do not ordinarily retain in the course of our regular business practices.

2. Verifying Requests to Access

Please note that we will take steps to verify your identity in order to fulfill your request, which may include requiring you to provide additional information for verification purposes and to submit a signed declaration under penalty of perjury.

If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to provide the requested information.

Right to Delete

The CCPA also provides a right to request that we delete Personal Information we have collected about you and for us to direct service providers to do the same, with certain exceptions as set forth in the CCPA.

When processing a request to delete, we may erase some information and we may de-identify some information. (When we de-identify information, we implement technical safeguards and business processes that prohibit re-identification, implement business processes to prevent inadvertent release of de-identified information, and will make no attempt to re-identify the information.)

1. Making A Request

If you are a California resident and would like to request that we delete your Personal Information, please call us toll-free at 1-800-794-5866 or email us at privacy@wilton.com.

2. Verifying Requests to Delete

To ensure that we do not delete your Personal Information in response to a fraudulent request, we will follow up after you submit your request in order to confirm that you want your information to be deleted. We may also require you to submit additional information for verification purposes.

If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not delete the information.

Right to Opt-Out of the Sale of Personal Information

The CCPA provides a right to California residents to request to opt-out of the sale of Personal Information. As indicated above, we may allow third-party advertising companies to collect data from visitors to our Sites, including to better serve you more relevant advertisements. Wilton does not sell your personal information for monetary compensation, but its online advertising practices (and certain analytics or similar activities) may potentially be considered “sales” pursuant to the CCPA under certain circumstances.

You can limit this type of tracking through industry opt-outs http://networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices/) and by limiting ad tracking on your mobile device. You may also be able to limit the access these third parties have to information about you when you use our Site by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies.

If you use different computers or browsers, you may need to indicate your opt-out choices across those computers and browsers.

Users under 16

Right to Opt-In to the Sale for Personal Information for Users under 16

As stated above, Wilton does not knowingly collect or sell Personal Information of minors under 16 years of age. Without limiting the foregoing, any user who is under 16 years of age is not permitted to opt in to the sale of their Personal Information.

Right to Non-discrimination for the Exercise of a Consumer’s Privacy Rights

California consumers have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising your CCPA rights.

B. Other California Rights / Your California Privacy Rights

i. As stated above in this Privacy Policy, Wilton does not share personal information with third parties for their direct marketing purposes (as defined by California Civil Code Section 1798.83) unless we give you choice (to opt in or opt-out) before sharing with those third parties.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request by email to privacy@wilton.com. You must put the statement “Your California Privacy Rights” in the subject field of your email. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

ii. California Residents Under the Age of 18 Only. If you have created an account with a Site, you may request that we remove content or information that you have publicly posted by sending an email message to privacy@wilton.com that includes: your mailing address and a detailed description of the content or information. At our option, we may either remove your personal information (and not other User Content) or remove all of the content and information. Note that if you have submitted your post to a third party (such as a product review), you may need to request removal from that third party.

Privacy Shield Policy for Wilton Brands LLC

Wilton Brands LLC and its Affiliates defined below (collectively, “Wilton,” “we,” “our,” and “us”) comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the United States Department of Commerce regarding the collection, use, and retention of Personal Data (defined below) from member states of the European Union (“EU”), European Economic Area (“EEA”), and Switzerland. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles, which we summarize below in this Policy. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and view our certification (which is in the process of being published on the Department of Commerce website), please visit https://www.privacyshield.gov/.

Definitions

For purposes of this Privacy Shield Policy:

Affiliates” means: Wilton Brands International LLC, Wilton Global Sourcing LLC, and Wilton Industries, Inc.

Data Subject” means an individual to whom any Personal Data covered by this Privacy Shield Policy refers.

Personal Data” and “personal information” mean any information relating to an identified or identifiable person residing in the EEA or Switzerland.

Sensitive Personal Data” means Personal Data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

Controller” means a person or organization that, alone or jointly with others, determines the purposes and means of processing Personal Data.

Scope and Responsibilities

This Privacy Shield Policy applies to Personal Data transferred from within the EEA and Switzerland to our operations in the U.S. in reliance on the respective Privacy Shield framework and does not apply to Personal Data otherwise transferred under Standard Contractual Clauses or an approved derogation under the EU General Data Protection Regulation.Our employees who have access in the U.S. to Personal Data covered by this Privacy Shield Policy are responsible for handling Personal Data in a manner consistent with this Privacy Shield Policy. Employees responsible for engaging third parties to handle Personal Data covered by this Privacy Shield Policy are responsible for obtaining appropriate contractual or other assurances that the Personal Data will be handled in a manner consistent with the Privacy Shield Principles.

Our adherence to this Privacy Shield Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations.

Privacy Shield Principles

We commit to process all Personal Data received in the U.S. subject to the EU-U.S. or Switzerland-U.S. Privacy Shield Frameworks in conformance with the following principles:

1. Notice

Our Privacy Shield certification will be published at https://www.privacyshield.gov/. Our general privacy policy is found at https://www.wilton.com/privacy-policy/, explaining the types of Personal Data we collect and for what purposes, the categories of third parties with which we share data and for what purposes, the rights of Data Subjects to access and correct their Personal Data and exercise choices over its use and disclosure, and how to contact us with questions or complaints. That privacy policy also covers Personal Data submitted by applicants who apply for employment positions through our wilton.com website.

Our employee privacy policy is distributed to our employees, independent contractors, and temporary workers. It describes the types of Personal Data we routinely collect and for what purposes, the categories of third parties with which we share data and for what purposes, the rights of Data Subjects to access and correct their Personal Data and exercise choices over its use and disclosure, and how to contact us with questions or complaints. The same kinds of information are provided in privacy notices furnished in specific contexts, such as applications for employment and optional benefits or training programs.

2. Choice

Apart from fulfilling our legal obligations and engaging agents to perform tasks on our behalf, we will inform you if we share Personal Data with a third party or use it for a new purpose materially different from the purpose for which we originally collected it or that you have already authorized or subsequently authorize. We will give you a choice of opting out of that sharing or new use. However, if the sharing or new use involves Sensitive Personal Data, we will not proceed unless you explicitly consent or “opt in.”

3. Accountability for Onward Transfer

If we transfer Personal Data covered by this Privacy Shield Policy to a third party acting as a Controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only under a contract with the third party providing that it will: (a) process the Personal Data for limited and specified purposes consistent with the consent provided by the Data Subject, (b) provide the same level of protection required by Privacy Shield Principles and notify us if it determines that it can no longer meet this obligation; and (c) if it determines that it can no longer meet this obligation, cease processing the Personal Data or take other reasonable and appropriate steps to remediate.

When we transfer Personal Data to a third party acting as our agent rather than as a Controller, we will: (a) permit the agent to process the Personal Data only for limited and specified purposes; (b) require the agent to provide the same level of privacy protection required by the Privacy Shield Principles; (c) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data in a manner consistent with our obligations under Privacy Shield Principles; and (d) require the agent to notify us if it determines that it can no longer meet its obligation to provide the same level of protection required by the Privacy Shield Principles. On notice from an agent that it has made such a determination, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

We remain liable under the Privacy Shield Principles if an agent processes Personal Data covered by this Privacy Shield Policy in a manner inconsistent with Privacy Shield Principles, except where we can establish that we are not responsible for the event giving rise to the damage.

4. Security

We take reasonable and appropriate measures to protect Personal Data covered by this Privacy Shield Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation

We limit the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of processing, as described in our general or specific privacy notices. We do not process Personal Data in a way that is incompatible with the purposes for which it was collected or that were subsequently authorized by the Data Subject.

We take reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. We take reasonable and appropriate measures to comply with the requirement under Privacy Shield Principles to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes our obligations to comply with legal requirements and professional accounting and audit standards, and for longer periods in the event of legal or insurance claims or regulatory proceedings. We adhere to the Privacy Shield Principles for as long as we retain such Personal Data.

6. Access

Data Subjects whose Personal Data is covered by this Privacy Shield Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to: privacy@wilton.com

7. Disclosure to Law Enforcement

We may disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

8. Recourse, Enforcement, and Liability

Our participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Data. If you have questions or complaints regarding this Privacy Shield Policy or our practices, you should first contact us at: privacy@wilton.com.

We have further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks to an independent dispute resolution provider located in the United States. If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS Inc. (“JAMS”) https://www.jamsadr.com/eu-us-privacy-shield. for more information or to file a complaint. The services of JAMS are provided at no cost to you.

We have further committed to cooperate with the panel established by the EU data protection authorities or the Swiss Federal Data Protection Authority, as applicable, and comply with their advice regarding human resources data transferred under this Policy in the context of the employment relationship.

Under certain conditions detailed in the Privacy Shield Annex I, Data Subjects also may be able to invoke binding arbitration before the Privacy Shield Panel created by the U.S. Department of Commerce and the European Commission.

We will periodically review and verify compliance with the Privacy Shield Principles and remedy any issues arising out of failure to comply with the Privacy Shield Principles.

Residents of the European Union (EU) and European Economic Area (EEA)

We comply with the European Union General Data Protection Regulation (“GDPR”) and other relevant data protection laws. For GDPR purposes, Wilton Brands LLC is a data “controller,” and you may contact us here:

Wilton Brands LLC
535 East Diehl Road, Suite 300
Naperville, Illinois 60563
United States of America
c/o Data Protection Officer

1. Corrections/Deletion/Opt-Out. You can access personal information about you and update or correct it. In some cases, you can also ask us to erase it, restrict or stop processing it, or provide your personal data to you in a “portable” form, if feasible. You may withdraw consent (“opt-out”) if you have previously consented to a particular use of your personal information, such as receiving emails or text messages, by contacting us at privacy@wilton.com or clicking on the unsubscribe link in a promotional email you receive from us.

2. Inquiries and Complaints. If you reside in the EEA, you have the right to make a complaint to your national data protection supervisory authority.

3. Children. Each Site is intended for a general audience and not for use by or targeted to children younger than the age of 16. We do not knowingly collect personal information from children younger than the age of 16 and if we learn that we have, we will delete that information from our active databases.

5. Closing Your Account; Retention of Information. We keep personal information as long as needed for the purposes for which it was collected and additionally for as long as we are required to keep it to comply with legal requirements and our business practices (including our document retention policy), resolve disputes, enforce our Terms of Use, and take other actions permitted by law.

Except as noted on specific webpages, we retain your personal information while you have an account with us and while you are using our app or continuing to visit any of the Sites.

When we ask you for personal data, we will tell you if it is optional. Otherwise, we ask because it is necessary in order for us to provide requested information, complete a requested transaction, or access some Site features.