Privacy Policy Old3

I. Introduction

Thank you for choosing Salt & Snow, Inc. (“Company”) for your business. The Company provides e-commerce services (“Services”) to vendors (“Vendors”) through an online marketplace where Vendors may sell their fashion-forward, high-performance, premium sports apparel (“Vendor Products”) and provides customers (“Customers”) with an online marketplace of curated Vendor Products for sale.

This Privacy Policy (“Agreement”) applies to: (1) any and all visitors (“Visitors”) to our website located at www.saltandsnow.com (“Website”); (2) to those who purchase of Vendor Products on our Website (“Customers”); and (3) to Vendors who sell Vendor Products on our Shopify app (“Vendors”). Visitors, Customers, and Vendors and any agents or employees of the same, are herein collectively referred to as “you” in this Agreement.

When you use our Services, Website, or Shopify app, whether as a Visitor, Vendor, or Customer, you are agreeing to our terms, so please carefully read the: (1) Terms of Service, Annexes attached hereto, incorporated herein, and (2) this Privacy Policy, as these documents contain important information regarding your legal rights and obligations.

II. General Data Protection Regulation

This Company is headquartered in the state of New York, USA. The Company operates its Website on the Shopify platform. By using our Products or accessing our Website, you herein agree to Shopify’s Privacy Policy (https://www.shopify.com/legal/privacy) and Terms of Service (https://www.shopify.com/legal/terms). Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper at https://help.shopify.com/en/manual/your-account/privacy/GDPR.

We provide the foregoing disclosure to EU data subjects.

The Company’s and Shopify’s processing of the Personal Information, such as the name, address, email address, or telephone number of an EU data subject (hereinafter, “Personal Information” or “Personal Data”) that is voluntarily supplied by the individual, or supplied by an authorized third party, shall always be in line with the General Data Protection Regulation (“GDPR”), and in accordance with the country-specific data protection regulations applicable to the Company.

By means of this Privacy Policy, our Company would like to inform you of the nature, scope, and purpose of the Personal Information we collect, use and process, as defined herein. Specifically, if you are an EU data subject visiting our Website, you are hereby informed, by means of this section of our Privacy Policy, of the rights to which you are entitled, and the recourse you may seek if you have any questions regarding the collection, use, and processing of Personal Information by the Company.

Your Privacy Rights under the GDPR. The GDPR includes the following rights for you, as an EU data subject, if you provide Personal Information to the Company in connection with accessing the Products or visiting our Website:

The right to be informed about how we store, use, or share your data;
The right to access your data;
The right to rectify your data;
The right to have us erase your data;
The right to prevent us from processing your data;
The right to request copies of your data from us in a commonly-used and machine-readable format, free of charge, for the purposes of transfer to a third party, where technically feasible;
The right to object to use or sharing of your data; and
The right not to be subject to automated decision-making, including profiling

Legitimate Business Interest under the GDPR. Our use of your Personal Information is based on the legitimate business grounds that:

The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to enable access to our Website on your device or charge you for our Products;
The use is necessary for compliance with a legal obligation;
The use is necessary in order to protect your vital interests or those of another person or entity;
We have a legitimate interest in using your information – for example, to provide and update our Website or Vendor Products, to improve our Website or Vendor Products so that we can offer you an even better user experience, to safeguard our Website or Vendor Products, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with Vendor Products, and to personalize your experience; and/or
You have given us your consent.

Data Retention/Erasure. We will retain your Personal Information for as long as needed to provide the applicable Vendor Products, or for a minimum period of four (4) years. If, at any time after agreeing to this Privacy Policy, you: (1) change your mind about receiving information from us; (2) wish to revoke permission for us to retain and use your Personal Information; (3) wish to object to the processing of your Personal Information; or (4) wish for us to erase a copy of your data, please make a request to the Company at hello@saltandsnow.com. If you request erasure of your data, we may retain some of your Personal Information only for legitimate business interests, such as fraud detection, prevention, and enhancing the safety of our Website; and to comply with our legal obligations, specifically our tax, legal reporting, and auditing obligations.

Our Response to Your Requests. If you make any requests regarding your Personal Information, we will not charge you for compliance with the request. The Company will respond and comply within one month. The Company reserves the right to refuse or charge for requests that are manifestly unfounded or excessive. If we refuse your request, we will tell you why we are refusing your request. You have the right to complain to the relevant supervisory authority and to a judicial remedy, but you must do so within one month of our refusal.

Data Controller. With the exception of processing payments, for which Shopify is the Payments Data Controller; the Company is the “data controller,” as defined under the GDPR, or the legal entity which determines the purposes and means of the processing of Personal Information of the customers of the Company and visitors to its Website. The Company is responsible for collecting your consent, managing consent-revoking, enabling right to access, etc. If you wish to revoke consent for us to store, use, or share your Personal Information, you may contact us at hello@saltandsnow.com.

Data Processor. The Company, and Shopify, as the 234host of the Website, is the “data processor," as defined under the GDPR, or the legal entity which processes, as this term is defined here in footnote 1, your Personal Information. The Company maintains records of any processing activities it performs, and is able to show how the Company complies with the data protection principles under the GDPR. It has effective policies and procedures in place. If you have questions regarding the processing of your Personal Data, you may contact us at hello@saltandsnow.com. If you have any questions about how Shopify, our Website host, processes your Personal Data, you may visit their website for EU subjects at https://help.shopify.com/en/manual/your-account/privacy/GDPR.

Data Protection Officer. The Company is not formally required to designate a Data Protection Officer (“DPO”) because it is not: (1) a public authority; (2) an organization that carries out regular and systematic monitoring of individuals on a large scale; or (3) an organization that carries out large scale processing of special categories of data, such as health information or information about criminal convictions. You may contact Ashley Bryan, COO of the Company, regarding data protection compliance and she can answer any questions you may have about your Personal Information. She may be reached at abryan@saltandsnow.com.

Breach. The Company has reasonable internal policies and procedures in place to effectively detect, report, and investigate a data breach. The GDPR defines a Personal Information breach as “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information.” Pursuant to the GDPR, the Company will notify you of a Personal Information breach where the Personal Information breaches are likely to present a risk to data subjects to data protection authorities (“DPAs”) without undue delay, and within 72 hours if feasible, after becoming aware of the breach; and communicate high-risk breaches to affected data subjects without undue delay. In the unfortunate event of breach, the Company shall provide you with: (i) contact details of the DPO or other contact person for the Company, (ii) a description of the nature of the breach, (iii) likely consequences of the breach, (iv) measures the Company has taken or proposes to take to address the breach, and (v) advice on steps data subjects can take to protect themselves.

Note: Data Protection Impact Assessment (DPIA). The Company is not required to undergo a DPIA because the Company’s data processing is not likely to result in a high risk to data subjects, such as in cases where: (1) new technology is being deployed; (2) profiling operations may significantly affect individuals; or (3) processing is on a large scale and involves special categories of data. If you have any questions regarding DPIA compliance by the Company, please contact Ms. Bryan.

Complaints. Without prejudice to any other administrative or judicial remedy, every EU data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement of the data subject considers that the processing of Personal Information relating to him or her infringes this Regulation.

Automatic Decision Making. If you are a resident of the EU, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our Website host and processor, Shopify, uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

Temporary deny list of IP addresses associated with repeated failed transactions. This deny list persists for a small number of hours.
Temporary deny list of credit cards associated with deny listed IP addresses. This deny list persists for a small number of days.

III. Use, Processing, and Sharing of Personal Information

The following information applies to anyone who shares with us his, her, or a third-party’s Personal Information. We may use, process, and/or share your Personal Information (and we have done so in the past 12 months):

To respond to your inquiries and your requests regarding our Website or Vendor Products.
To send you information regarding our services and changes to our terms, conditions, and policies.
To complete your account registration on our Website, process your payments, and communicate with you regarding your purchase of Vendor Products.
To send you marketing communication and newsletters about Vendor Products.
To personalize your experience on our Website.
To inform you and allow you to participate in our Company’s promotions.
To facilitate social sharing functionality.
To collaborate with business affiliates, partners, vendors, or service providers to provide you with Vendor Products.
In connection with our business purposes, as described above, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or services, expanding our business activities, etc.

We will not use and/or share your Personal Information:

With anyone except for our Company’s authorized service providers, business affiliates, and business partners, such as Shopify, and strictly for business purposes. We will give you an opportunity to opt out of sharing your Personal Information.
To run interest-based advertising campaigns that collect Personal Information such as email addresses, telephone numbers, and credit card numbers.
To use or associate Personal Information with remarketing lists, cookies, data feeds, or other anonymous identifiers.
To use or associate targeting information, such as demographics or location, with any Personal Information collected from the ad or its landing page.
To share any Personal Information with Google or third party companies through our remarketing tag or any product data feeds which might be associated with our ads.
To send Google or third party companies precise location information without obtaining your consent.

However, we reserve the right to disclose Personal Information that we believe, in our sole discretion, to be necessary or appropriate in the following circumstances:

As required by law, such as to comply with a subpoena, or similar legal process.
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
To enforce our Terms and Conditions.
To allow us to pursue available remedies or limit the damages that we may sustain.

IV. Collection of Other Information

Personally Non-Identifiable Information: The Company may run market research projects that seek to identify consumer segments that are interested in and/or use Vendor Products or similar products. As a result, on our Website or through our provision of Vendor Products to you, we may collect personally non-identifiable information about you, including but not limited to your demographic data, age, education level, profession, geographic location or gender, when you choose to use Vendor Products. This information is not, by itself, sufficient to identify or contact you. The Company may store such information, or it may be included in databases owned and maintained by partners, affiliates, agents, or service providers of the Company. The Company may use such information and pool it with other information to track data related to growing the Company’s business, such as the total number of visitors to our Website and purchasers of our products.

Passively Collected Information: The Company may collect information on the user's date and time of page views, or other personally non-identifiable information which may include but is not limited to, for example, IP addresses, browser types, location information associated with your IP address, domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or purchase of the Vendor Products. This information cannot presently be used to specifically identify you.

Aggregated Personal Data: The Company may analyze your Personal Information provided through the Website or in connection with providing the Vendor Products to you, in aggregate form. This aggregate information does not identify you personally. We may share this aggregate data with our partners, affiliates, agents, or service providers for our own business purposes. We may also disclose aggregated statistics to explain use of Vendor Products to current and prospective business partners, potential investors, and to other third parties for other lawful, business-related purposes.

Customer Credit Card Information. The Company uses a third party, Shopify, to process your payments and keep a protected copy of your credit card number. This billing data belongs to you, and by utilizing the Vendor Products, you grant the Company a license to use this data to bill you for Vendor Products purchased. By accessing our Website and/or utilizing/purchasing Vendor Products, you herein agree to Shopify’s Privacy Policy and Terms of Service located at https://www.shopify.com/legal/privacy and https://www.shopify.com/legal/terms, respectively. You also herein agree that you have read our Terms of Service describing the fees and payment processing associated with any purchase of Vendor Products.

V. Website Tracking

We may, either directly or through third party companies and individuals we engage to provide services to us, also:

Track your use of our Website and the use of Vendor Products for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, etc.
Track your use of the Website and enable you to use and access the Vendor Products and pay for your access to the Vendor Products.
Track your behavior on our own Website and market and further advertise Vendor Products to you, on our Website platform and/or on other third party websites. You may opt out of receiving advertisements by visiting the Network Advertising Initiative (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (http://www.aboutads.info/choices/). Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Vendor Products, generally. The advertising will simply not be targeted or specific to your interests.

VI. Tracking Technologies on our Website

The Company may use the foregoing technologies to track your activity on our Website:

Cookies. When you visit our Website or otherwise interact with the Service, we may send one or more “cookies” to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites. Some features on this site will not function if you do not allow cookies. We may link the information we store in cookies to any Personal Information that you submit while visiting our Website.

We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site.

Functional cookies, persistent and session type, store information to enable core site functionality, such as Live Chat and Client ID remembrance.

Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.

Advertising cookies may be set through our Website by our advertising partners. Data may be collected by these companies that enable the companies to serve up advertisements on other sites that are relevant to your interests.

Our Website is hosted on Shopify. We may use Google Analytics, Shopify Analytics, Zoho Analytics, and/or other similar analytics services, which uses cookies and other similar technologies to collect and analyze information about the use of the Vendor Products and/or Website, and report on activities and trends. This Website may also collect information regarding the use of other websites, apps and online resources. To that end, we provide the following links for your information:

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
You can learn more about Shopify’s privacy practices at https://www.shopify.com/legal/privacy/customers. You may learn more about Shopify generally in its Terms of Service located at https://www.shopify.com/legal/terms.
You may learn more about Zoho Analytics’ privacy practices at https://www.zoho.com/privacy.html. You may learn more about Zoho generally in its Terms of Service located at https://www.zoho.com/terms.html.

You herein agree that if you use our Website or Services, that you agree to the Privacy Policies and Terms of Service of Google Analytics, Shopify Analytics, and Zoho Analytics.

The cookies necessary for the functionality of our Website, as hosted on Shopify’s platform, include:

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
cart	Used in connection with shopping cart.
cart_sig	Used in connection with checkout.
cart_ts	Used in connection with checkout.
checkout_token	Used in connection with checkout.
secret	Used in connection with checkout.
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

Reporting and analytics cookies on our Website include:

Name	Function
_tracking_consent	Tracking preferences.
_landing_page	Track landing pages
_orig_referrer	Track landing pages
_s	Shopify analytics.
_shopify_fs	Shopify analytics.
_shopify_s	Shopify analytics.
_shopify_sa_p	Shopify analytics relating to marketing & referrals.
_shopify_sa_t	Shopify analytics relating to marketing & referrals.
_shopify_y	Shopify analytics.
_y	Shopify analytics.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.

If you reject cookies, you may still use our site, but some features on the site may not function properly.

Web Beacons. Web beacons are electronic files that signal when a webpage, advertisement, video, other content, an email or newsletter has been viewed. They are usually invisible to you. We may use web beacons alone or in conjunction with cookies to compile information about our Service. Web beacons may be used to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by web beacons to your Personal Information to gauge the effectiveness of certain communications and our marketing campaigns.

Log Files. A Log File is a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software. Log file information is automatically reported by your browser or mobile application each time you access the Website or use Vendor Products. Along with cookies and web beacons, log files help provide additional functionality to the Website and help us analyze Website and Vendor Products usage more accurately. We and our third party tracking-utility partners may use log files on our Website to gather automatically gather and store information including, but not limited to, internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for business purposes.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plugins, system fonts and other data, for purposes of identification.

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

VII. Children

The Children’s Online Privacy Protection Act of 1998 (COPPA) and its accompanying FTC regulation protects the privacy of American children aged 13 and under, who are using the Internet. The GDPR sets the age at which an EU child can give their own consent in order to process their Personal Data at 16 years of age.

The Website is not intended for anyone under 16, and we do not knowingly collect information from anyone under the age of 16. If we learn that we have received any type of information from a child under the age of 16, we will take commercially reasonable efforts to promptly delete such information. If you are younger than age 18, you may use the Website only with the permission and involvement of your parent or guardian. Please contact us at hello@saltandsnow.com if you believe we have collected information from a child without parental consent.

VIII. Links to Other Websites

This Privacy Policy does not address, and we are not responsible for the privacy, information or other practices of any third parties. This Privacy Policy applies only to this Website and the Company’s Vendor Products. It does not apply to any third-party sites, and the inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.

We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Instagram, Twitter, or any other app developers, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with your use of the Website or Vendor Products.

IX. Security

We maintain reasonable and appropriate, although not infallible, security precautions. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts. You should note that in using the Website, and/or our related Vendor Products, your information will travel through third-party infrastructures which are not under our control. Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to hello@saltandsnow.com.

X. Data Retention

We will retain your Personal Information for four (4) years, or as long as needed to provide the applicable Vendor Products to you. Our data retention period may change in the future if a longer retention period is required or permitted by law.

XI. Do Not Track

Your browser setting may allow you to automatically transmit a "Do Not Track" signal to websites you visit. The Company’s Website does not respond to "Do Not Track" signals or other mechanisms from a visitor's browser. If, in the future, we create a program or protocol to respond to such web browser "Do Not Track" signals, we will inform you of the details of that protocol in this Privacy Policy. To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.

XII. Advertising/Google Ads

On this Website, the Company has integrated Google Ads. Google Ads is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google Ads allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displays when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google Ads is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Ads is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached a Google Ads ad on our website generated sales, that is, executed or canceled a sale of goods.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through Google Ads ads to ascertain the success or failure of each Google Ads ad and to optimize our Google Ads ads in the future. Neither our company nor other Google Ads advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, Personal Information, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. Personal Information is stored by Google in the United States of America. Google may pass these Personal Information collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google Ads may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.com/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

XIII. Analytics

As mentioned above under the Cookies section of this Privacy Policy, we and our third party tracking-utility partners use technology on our Website to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes. Specifically, we analyze trends, administer the site, track users’ movements around the Website, and gather demographic information about our user base as a in the aggregate. We and our third party tracking-utility partners use log files on our Website to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes. Specifically, we analyze trends, administer the site, track users’ movements around the Website, and gather demographic information about our user base as a in the aggregate.

On this Website, the Company has integrated both Shopify Analytics, as the Website is hosted on Shopify and Google Analytics, which is a separate web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of Google Analytics is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, United States. The operator of Shopify Analytics is Shopify, Inc., 151 O’Connor Street, Ground floor, Ottawa, ON K2P 2L8, Canada.

The purpose of both analytics software systems is to analyze the traffic on our website. Analytics software uses the collected data and information, inter alia, to evaluate the use of our Website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

By continuing to use our Website and/or Vendor Products, you agree to the applicable data protection provisions of Google under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html, as well as the terms regarding Google Analytics at https://www.google.com/analytics/.

By continuing to use our Website and/or Vendor Products, you agree to Shopify’s privacy practices at https://www.shopify.com/legal/privacy, and the terms regarding Shopify Analytics in particular at https://help.shopify.com/en/manual/reports-and-analytics/shopify-reports.

XIV. Public Forum on our Website

Our Website offers publicly accessible message boards, blogs, and community forums to which you may contribute. You may submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, "User Content"), such as on profiles, blogs and message boards. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed), and may or may not attribute it to you.

Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that the Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. Our promises regarding handling of your Personal Information under this Privacy Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Website. We are not responsible for the accuracy, use, or misuse of any User Content that you disclose or receive from third parties through the Website.

To request removal of your Personal Information from our blog or community forum, contact us at hello@saltandsnow.com. In some cases, we may not be able to remove your Personal Information, especially if it was already re-posted by another user. If this is the case, we will let you know if we are unable to do so and why in response to your request.

XV. Your California Privacy Rights

California “Shine the Light” Law

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. This code section applies to businesses with 20 or more full or part-time employees. At this time, the Company does not need to comply with this law, but does so voluntarily in an effort to assure you that we value your privacy.

You may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to hello@saltandsnow.com.

California Consumer Privacy Act

Organizations who are subject to the California Consumer Privacy Act (CCPA) must provide a clear and conspicuous link titled “Do Not Sell My Personal Information” on their homepage and in their privacy policy in order to meet the requirements of the new CA privacy law effective as of January 1, 2020. The law applies to businesses with over $25 million in revenue, those handling information from 50,000 consumers, or deriving 50%+ annual revenue from selling consumer personal information. At this time, the Company does not need to comply with this law, but does so voluntarily in an effort to assure you that we value your privacy.

You may opt out of the Company’s sale of your personal information at any time by emailing us at hello@saltandsnow.com. Under the CCPA, “personal information” is defined to include information that identifies or relates to a particular consumer or household including, but not limited to, name, postal address, email address, IP address, social security number, personal property records, purchasing histories, biometric information, internet activity such as browsing or search history, geolocation data, employment information, education information and inferences drawn from this information, in so far as it is not publicly available information. The Company’s “sale” of personal information is broadly defined by the law to include selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. In other words, most business to business transfers of personal information will fall within the definition of a sale.

The Company has provided visitors to our Website with a link to an Internet Web page on our Website enabling visitors to opt out of the “sale” of their “personal information.” Our Website also contains a recognizable and uniform opt-out logo or button to promote consumer awareness of the option to opt-out. Please feel free to access both for more information and to effectively opt out.

Additionally, If you are a California resident age 16 or older, as of January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal information.

RIGHT TO KNOW REQUEST - Under the CCPA, you may have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

Categories of and specific pieces of personal information we have collected about you.
Categories of sources from which we collect personal information.
Purposes for collecting, using, or selling personal information.
Categories of third parties with which we share personal information.
Categories of personal information disclosed about you for a business purpose.
If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

RIGHT TO DELETE REQUEST - You may also have a right to request that we delete personal information, subject to certain exceptions. They can be invoked if it is necessary for the Company to maintain the personal information pursuant to the exception.

Transactional: Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
Security: Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Errors: Debug to identify and repair errors that impair existing intended functionality.
Free Speech: Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
CalECPA Compliance: Comply with the California Electronic Communications Privacy Act
Research in the Public Interest: Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
Expected Internal Uses: To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
Legal Compliance: Comply with a legal obligation.
Other Internal Uses: Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Absent an exception, under the CCPA, we have 45 days to comply with your request.

DISCLOSURES OF PERSONAL INFORMATION FOR BUSINESS PURPOSE - In the preceding 12 months, we may have disclosed certain personal information to the categories of recipients listed in Section III of this Privacy Policy for one or more business purposes. If you are a California resident 16 years of age or older and would like to make a verifiable request for information about the personal information we have collected about you or a request for deletion of such personal information, please submit your request in writing to hello@saltandsnow.com.

XVI. Referrals

If you choose to use our referral service to tell a friend about our Services by email, we will ask for your friend’s email address, and send your friend a one-time email inviting them to visit our Website and inform them of our Services. We will only store your friend’s email address for the sole purpose of sending this one-time message and tracking the success of the referral program. Your friend may contact us at hello@saltandsnow.com to request that we remove this information from our database at any time.

If you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

XVII. Testimonials, Ratings and Reviews

If you submit testimonials, ratings, or reviews of the Vendor Products directly on our Website, any Personal Information you include will be displayed on the Website. We may also partner with third-party service providers to collect and display ratings and review content on our Website. If you provide our third-party service providers with your Personal Information in the process of submitting your rating and review, the content and Personal Information collected by a third party will be posted on our Website, absent your express instruction not to do so. If you want your testimonial, rating, or review removed from our Website at any time, please contact us at hello@saltandsnow.com.

XVIII. Changes

This Privacy Policy may be updated from time to time for any reason, at our sole discretion. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Website, and emailing you a copy of the revised Privacy Policy or a link to it. You are advised to consult our Website regularly for any changes.

XIX. Incorporation into Terms of Service

By using or accessing the Website or purchasing the Vendor Products, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set forth in this Privacy Policy and as amended by us. This Privacy Policy is incorporated into, and considered a part of, the Company’s Terms of Service.

XX. Opt-Out Policy

If, at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at hello@saltandsnow.com.

XX1. Contact Us

If you have any questions or concerns relating to our use of your Personal Information, please email hello@saltandsnow.com or reach us via first class registered U.S. mail, overnight courier, to: Salt & Snow, Inc., 652 Lexington Avenue, New York, NY 10021.

YOU HEREBY ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THE FOREGOING PRIVACY POLICY, AND THE COMPANY'S TERMS OF SERVICE AND ATTACHED ANNEXES, AND AGREE THAT USE OF THE SERVICES OR PURCHASE OF ANY VENDOR PRODUCTS ON THE WEBSITE IS AN ACKNOWLEDGMENT OF YOUR AGREEMENT TO BE BOUND BY THE FOREGOING AND ANY SEPARATE EXECUTED AGREEMENT BETWEEN YOU AND THE COMPANY.