Updated and effective May 22, 2018.
TABLE OF CONTENTS
- Information Collected by Wilton.
- Third Party Analytics Providers, Ad Servers, and Similar Third Parties.
- User Content and Submission Features.
- Social Media Features.
- Use of Information We Collect.
- Sharing Information with Third Parties.
- Third-Party Links and Content.
- International Transfer of Personal Information.
- Inquiries and Complaints.
- Closing Your Account; Retention of Information.
- California Residents Under the Age of 18 Only.
- Contact Information.
1. Information Collected by Wilton.
A. Information You Directly and Voluntarily Provide: We may ask you to provide “Personal Information” (i.e., information that identifies you as a specific, identifiable individual) when you visit one of our Sites through various features, including:
- 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 3) or participate in Submission Features (as described in Section 3) or Social Media Features (as described in Section 4).
We do not use the Personal Information that you provide as described above for any other marketing purposes. However, we may convert Personal Information into information that no longer identifies you as a specific, identifiable individual and is no longer Personal Information, for example, by converting your email address into an alphanumeric code that does not identify you directly (“Hashed Information”). We and our service providers use Hashed Information to track your activity on the Sites and elsewhere, to target advertising, and for other marketing purposes.
Each Site is intended for a general audience and not for use by or targeted to children younger than the age of 13. We do not knowingly collect Personal Information from children younger than the age of 13 and if we learn that we have, we will delete that information from our active databases.
Providing information is optional, but if you do not provide us with certain information, including Personal Information, you may not be able to use some Site features.
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 (including Flash cookies from the Adobe Flash plug-in), 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 Flash and Adobe’s privacy choices from Adobe, click here. 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. For information about “do not track” from The Future of Privacy Forum, click here.
2. 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 certain information, such as Usage Information and Hashed 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, and for information about DAA’s AppChoices application, click here.
Opting out through these mechanisms does not block all online advertising; you will continue to receive generic advertisements.
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.
5. Use of Information We Collect. We use information we collect, including Personal Information, Usage Information, and Hashed Information:
- To enable you to use a Site, 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 through a Site, 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 10.
- 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 6.E.
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 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 and will not do so unless we first provide you with the opportunity to agree by opting-in. If you opt-in, 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.
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.
7. Security. We take commercially reasonable steps to secure information (including Personal 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.
8. 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. Corrections/Deletion/Opt-Out. You may update, correct, or delete the Personal Information you have provided by contacting us at email@example.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 firstname.lastname@example.org or click on the unsubscribe link in a promotional email you receive from us.
13. 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 email@example.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.
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 firstname.lastname@example.org 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.
- We operate the Sites in the United States. By visiting a Site or providing your personal information, you consent to the collection, transfer, and processing of your personal data in the United States and other jurisdictions. We also comply with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks regarding the collection, use, and retention of personal information relating to individuals residing in the EEA or Switzerland and are in the process of self-certifying.
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.