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Effective Date of Current Policy: April 4, 2017
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Personal Information (defined below) we obtain through the Site, your communications with us, or from third parties. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized such that it does not allow a third party to easily identify a specific individual.
THE SITE COLLECTS YOUR INFORMATION
We collect Personal Information when you choose to provide it to us including when you:
• register to use the Site;
• purchase a Burrow Product on the Site;
• use the Site; and
• communicate with us.
We also collect Personal Information by using cookies, pixels, server logs, and other similar technology as you use the Site. Please note that we may use third party service providers to help operate the Site and these third party service providers may collect Personal Information from our Site as well.
Register an Account. The Site gives you the option of creating a user account (an “Account”). If you decide to create an Account, you will provide us with certain Personal Information, such as your user name and password. You are not required to register to use the Site. Purchase a Burrow Product. When you purchase a Burrow product using the Site, you are given the option of logging into an Account or checking out as a guest. In either case, when you purchase a Burrow product, you will provide us with Personal Information, such as your name, email address, and shipping address.
Make a Payment. When you make a payment through the Site, you may need to provide Personal Information to our third party payment processors. Such Personal Information may include sensitive Personal Information, such as your credit card number. Submit Information to the Site. We collect information you submit to the Site. For example, when you post a review of a Burrow product on the Site or refer a friend to Burrow using the Site, the Site will collect the information in your submission to the Site, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Communicate with Us. We may also collect Personal Information from you when you communicate with us. For example, you may send us Personal Information by writing an email to us, subscribing to the Burrow newsletter, or making a reservation for an event hosted by Burrow. If you contact us, we may keep a record of that correspondence.
Take a Survey. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. For example, you may be asked to provide contact information as well as information about your height, weight, gender or date of birth.
Information You Provide About a Third Party. If you choose to use any Burrow referral service to tell a friend about Burrow, we may collect your friend's Personal Information, such as name and email address. We will automatically send your friend a one-time email inviting him or her to purchase a Burrow product. We store your friend’s information in order to send this one-time email and to track the success of our referral program.
Passive Collection. The Site collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We use this data to analyze trends in the aggregate and administer the site. Non-personal information that we passively collect may be combined with other information about you, including Personal Information.
Information Provided by Third Parties. Burrow may collect information about you from third parties or supplement the information we collect from you with additional records received from third parties. Information is collected from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you.
HOW BURROW USES YOUR INFORMATION
We use Personal Information to facilitate and improve our services, and communicate with you.
Internal and Service-Related Usage. We use and retain information, including Personal Information, to improve and facilitate the Site and our services. We may also use such data to help us deliver targeted advertising to consumers that is displayed on both Burrow websites and unaffiliated websites, to analyze interactions with and performance of our Site, to measure the effectiveness of advertising on behalf of our advertising partners, and to identify the audience most likely to respond to an advertisement. We may also use data from third parties (such as data vendors) pursuant to their own privacy policies, and enhance information (including Personal Information) that we have collected with such third-party data. We believe that the use of such information is helpful to providing users with better services. However, if you would like to opt-out of these interest-based advertisements, please follow the opt-out process described below under “Choice.”
Communications. We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.
Marketing. We may use information about you, including Personal Information, to send you information about Burrow’s products and services. Non-Personal Information. We may use anonymized, aggregated or other data that is not Personal Information for any purpose, including marketing. These uses may include but are not limited to analyzing interactions with and performance of the Site, enabling us to improve our Site and services, and sharing such information with our business partners, affiliates, or any other third party. Similarly, we may enhance any such anonymized and aggregated data collected via our Site with other information collected from our business partners.
BURROW MAY DISCLOSE YOUR INFORMATION
We may share your information:
• to comply with legal obligations;
• to protect and defend our rights and property; and
• with your permission.
We do not share your Personal Information with third parties for those third parties' marketing purposes unless you first agree to such sharing (either by opting in or choosing not to opt-out at the time we provide the choice).
We Use Vendors and Service Providers. We may share Personal Information with our vendors and service providers who perform services on our behalf. These third parties are authorized to use your Personal Information only as necessary to provide these services to us.
• Providing customer services including fulfilling orders, delivering packages, and communicating with you about your order
• Payment processing
• Sending, evaluating and improving marketing communications
• Fulfilling subscription services
• Conducting research and analysis
• Measuring and improving the performance of the Site
• Verifying your identity and preventing fraud
• Developing and improving Burrow products and services
• Registering your Account
• Detecting, preventing and remediating fraud or other potentially prohibited or illegal activities
Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
Marketing. If you are in the United States and make a purchase using the Site, information collected from you may be made available to select third parties who offer products or services that may be of interest to you. If you prefer that we not share your information with such third parties, send an email to [email protected] with the word “privacy” in the subject of the email within thirty (30) days of your purchase. Note that if it has been more than thirty (30) days since your purchase, your opt-out may not apply to marketing initiatives that are already underway.
We may also disclose your Personal Information with your permission.
Upon request Burrow will provide you with information about whether we hold any of your Personal Information. If you would like to access, update, correct, or delete any information that you have provided to us through your use of the Site, you may contact us at [email protected] We will respond to your request within a reasonable timeframe. We reserve the right to save transaction data as is necessary to comply with legal obligations or for purposes of standard business operations.
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
To manage our advertising on other sites, we engage third party advertising partners. These third party partners may use technologies such as cookies to gather information about your activities on the Site and other sites in order to provide you advertising based upon your browsing activities and interests. Certain of our third party advertising partners participate in self-regulatory organizations, and those organizations operate websites that give you the ability to opt-out of receiving targeted ads from those partners. You can access these websites, and also learn more about targeted advertising and privacy, at Network Advertising or AboutAds. You can also choose not to be included in Google Analytics here.
To be clear, whether you are opting out by adjusting your browser/device settings or by using a website established by a self-regulatory group, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.
Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third party who has previously been provided with your information in accordance with this policy.
If you would like to opt-out of Burrow sharing your information with third parties (such as data vendors) for non-Burrow related marketing purposes, send an email to [email protected] with the word “privacy” in the subject of the email.
THIRD PARTY SITES AND SOCIAL MEDIA PLATFORMS
The Site may contain links to other websites and other websites may reference or link to our Site. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Site also contains links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
SECURITY OF YOUR INFORMATION
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please email us [email protected] with the word “privacy” in the subject of the email. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Site is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us [email protected] If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.
By using the Site, you will transfer data to the United States.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.
EU-U.S. PRIVACY SHIELD
Burrow Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Burrow Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Under the Privacy Shield Framework, Burrow, Inc. is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. Burrow, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Burrow Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Burrow, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
POST A QUESTION OR SUGGESTION
Burrow, Inc. 33 West 17th Street, 5th Floor, New York, NY 10011 Email: [email protected] and include the word “privacy” in the subject of the email