PRIVACY POLICY

Last updated: June 24, 2024

OVERVIEW

Ellis Brooklyn Inc., (“Ellis Brooklyn,” “we,” “us,” or “our”) takes the privacy of your information seriously. Please read the following privacy policy to better understand what information our website (www.ellisbrooklyn.com) (the “Site”) collects and uses about you and how it handles this information. We will not use or share your information with any person or entity, except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in the Terms of Service located on the Site. The Terms of Service are incorporated herein by this reference.

 

1. INFORMATION COLLECTED BY THE SITE TO CONDUCT TRANSACTIONS

We will collect the information that you provide to us to perform any transaction requested by you, including registering for a Ellis Brooklyn account, subscribing to a mailing list or our newsletter, participating in promotions, purchasing products offered on the Site, responding to questions or comments you may have and for any other purposes with your consent. This information may include information such as, among other items, your name, shipping address, billing information, email address, telephone number, credit card information or other payment information. When you make a purchase or otherwise utilize the Site, we may need to provide your information, including the information indicated above, to certain third-party service providers. Such third-party service providers include Shopify.com (“Shopify”), product manufacturers, shipping companies, parties used in the sending of postal mail or emails, accounting and record keeping functions, advertisements and other web-based services. Your information is disclosed to such third-party service providers only as necessary and solely to complete the transaction for which they have been engaged by us. Such third-party service providers will have access to your information for the limited purpose of completing their intended function, but they may not use it in connection with or for any other purpose.

 

2. OTHER INFORMATION COLLECTED BY THE SITE

The Site automatically collects information as you navigate through the Site.  Information collected automatically may include Internet Protocol addresses, details relating to your use of the Site and information collected through cookies and other tracking technologies.  This information collected is generally statistical data and does not identify you specifically. This information is used by us to improve the Site and to deliver better service to the Site's users.

 

3. USE OF INFORMATION COLLECTED BY THE WEBSITE

The information we collect is used to provide a variety of services and improvements for our customers. The data is used to process your purchases, send you opted-in promotional materials, create and manage your online account, effectively respond to your inquiries and questions, communicate with you about our social networks, events, promotions, request feedback, and provide surveys. We also use the information to notify you about changes to our Site, products and the services we provide to our customers. We may also use the information collected by our Site to provide troubleshooting and improve our services, make recommendations, personalize your Site-experience, comply with legal obligations and fraud prevention and credit risks.  We do not sell or provide your information for third-party direct marketing purposes. We respect our customer's data and relationship.

 

4. MANAGING YOUR INFORMATION

You may, of course, decline to submit personally identifiable information through the Site, in which case we may not be able to provide certain products or services to you. You may update, correct, or delete your account information at any time by logging into your account or by contacting us as provided in the “Contact Us” section below.

 

 5. SECURITY

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption. We follow all PCI-DSS requirements and implement additional generally accepted industry standards. In addition, Shopify reviews its business practices periodically for compliance with policies and procedures governing the security and confidentiality of our information. Nevertheless, no data transmission over the Internet is 100% secure. Accordingly, while we strive to protect your personal information and privacy, we do not warrant or guarantee the security of any information you disclose or transmit to us while using the Site, and we shall not be liable for the theft or inadvertent disclosure of your personal information. We assume no liability for any disclosure of data due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond our reasonable control.

 

 6. OPT-OUT POLICY

We may use your email address to send you notices regarding matters, including the Site (including any notices required by law, in lieu of communication by postal mail). If you do not want to receive these messages, you can opt out by following the instructions included in the email message or by emailing us at info@ellisbrooklyn.com. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.

 

 7. DISCLOSURE

We have the right to disclose statistical or aggregated data (but in no event information which may personally identify you, referred to hereafter as "personal information") in our discretion and without restriction. We may disclose personal information which we have collected (a) as may be expressly permitted by you, (b) to our related companies and service providers to perform a business or technical support function for us, (c) as we deem necessary to enforce the Site's Terms of Service, (d) to comply with any court order, law or legal process, including to respond to any government or regulatory request or otherwise as required by law, and (e) in connection with the sale of Ellis Brooklyn (whether by merger, sale of our assets, sale of stock, or otherwise).

 

 8. SHOPIFY

The Site is hosted on Shopify. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. Shopify stores your data on a secure server behind a firewall.

If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by the Site and its service providers.

For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Policy (https://www.shopify.com/legal/privacy).

 

 9. THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us, such as hosting our services and data, manage how our services function, host our customer relationship management, improve and automate our marketing techniques, incorporate customer service services and other software platforms, process payments, collect delinquent accounts, fulfill, process and deliver orders, and market and promote our products and services, including email, text messages and social media marketing campaigns. These service providers are authorized to use your personal information, if at all, only necessary to provide the requested services to us. Without limiting the foregoing, Ellis Brooklyn may also share information about visitors, registered accounts and customers with our service providers to ensure the quality of information provided. Without your affirmative consent, Ellis Brooklyn does not share, sell, rent or trade any information with third parties for their promotional purposes.

Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers. Once you leave the Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms of Service.

When you click on links on the Site, they may direct you away from the Site. We are not responsible for the privacy practices of other sites and encourage you to read their Privacy Policies.

 

 10. COOKIES

When you use the Site, we may send one or more “cookies” – a small data file – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Site. A cookie may convey to us anonymous information about how you browse the Site. A persistent cookie remains on your hard drive after you close your browser so that it can be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Below is a list of cookies that we use. We have listed them here so that you can choose your cookie preferences each time that you use the Site and decide whether you want to opt-out of any of our utilized cookies or not.  The cookies that we are currently utilizing are:

 _session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc.).

 _shopify_visit, no data held, Persistent for 30 minutes from the last visit, used by our Site’s provider’s internal stats tracker to record the number of visits

 _shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, counts the number of visits to a store by a single customer.

cart, unique token, persistent for 2 weeks, stores information about the contents of your cart.

 _secure_session_id, unique token, sessional

 storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access.

 

 11. TEXT MARKETING

By subscribing to our text notifications, you agree to receive recurring automated marketing messages at the phone number that you provided to us. Consent is not a condition of purchase. Reply STOP to unsubscribe. HELP for help. Msg & Data rates may apply.

 

 12. OTHER EMPLOYED MARKETING METHODS

By providing to us your affirmative consent (for example, agreeing to our Terms of Service and this Privacy Policy), you will receive marketing materials from us, e.g., email newsletters, sales & other promotions.  At any time, you may contact us as provided in paragraph 25 below or per the directions stated in the received marketing materials, and unsubscribe to our marketing.

 

 13. AGE OF CONSENT

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

 

14. YOUR CALIFORNIA PRIVACY RIGHTS

 If you reside in the State of California, this privacy notice for California residents supplements Our Privacy Policy regarding the collection, use, disclosure, and sale of your personal information and your rights regarding that information.

Under California law, “personal information” is information that identifies, relates to, or could reasonably be linked with you or your household. Personal information generally does not include information that is publicly available.

“Sensitive personal information” is personal information that may include government identifiers (such as one’s social security, driver license, state ID or passport number); an account login, financial account, debit or credit card with any required security code, password or credentials allowing account access; precise geolocation information; contents of mail, email and text messages (unless we are the intended recipient of the communication); genetic data; biometric information processed to identify a consumer; information concerning a California resident’s health, sex life or sex orientation; racial or ethnic origin, religious or philosophical beliefs or union membership.

We adopt this notice to comply with California law, including the California Consumer Privacy Act of 2018 (Cal. Civ. Code 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”)  and the regulations enacted by the Office of the Attorney General of California in connection with the CCPA/CPRA (hereinafter collectively the “CCPA”). The CCPA gives California residents the right to know what personally identifiable information is collected about them, and how it will be used, disclosed, and sold. The CCPA also gives California residents the right to request access to and deletion of their personal information and the right to request that their personal information not be sold, among other rights as more fully explained in this Section of our Privacy Policy.

We collect information from you when you interact with us, including online such as through our Site. The information we collect from you in the preceding twelve (12) months will depend on the nature of our interaction, but may include the following categories that we have collected from California consumers, California resident professionals in the context of a business to business transaction and California resident employees and job applicants.

CCPA Categories of Personal Information and Sensitive Personal Information Collected and Shared; Purposes for Use; Categories of Third Parties with whom shared

CALIFORNIA CONSUMERS: The following table provides details about the personal information and/or sensitive personal information that we collect and handle in connection with California consumers within the preceding twelve (12) months.

Identifiers

Contact information (such as your name, shipping and billing address, email address and telephone number); unique identifiers (such as a device identifier); financial information (such as a credit or debit card number); and online identifiers (such as an internet protocol address and a social media channel ID). Note that financial information (such as a credit or debit card number) is not stored by us as this type of payment is handled through our payment processing service providers.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also collect this information from third parties such as financial institutions, payment processors, and social networks.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to create and administer accounts; to process orders, payments, and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; for physical security, cybersecurity, incident response, and risk reduction purposes; for legal, recordkeeping, and compliance purposes; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services so that we can run our business operations, promote, market, advertise, sell and/or deliver our various products and services, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

Legally protected demographics

Such as your race, ethnicity, or gender identity.

Disclosure	Description
Sources from which collected	We collect this category of information from you when you provide it to us or interact with us online (such as through our Site, as defined above, or our social media). We also collect this information from third parties, such as social networks.
Purpose of collection	We collect this category information to improve, market, and personalize our products and services (including our Site); for physical security and incident response; for legal, recordkeeping, and compliance purposes; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control; to service providers that provide fraud prevention and security services; and to other third parties (such as law enforcement) as required by law.

 

Commercial information

Such as records of the products or services you purchased or considered purchasing.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media).
Purpose of collection	We collect this category of information to better understand and communicate with you; to create and administer accounts; to process orders, payments, and refunds; to provide, improve, market, and personalize our products and services (including our Site); for physical security, cybersecurity, incident response, and risk reduction purposes; for legal, recordkeeping, and compliance purposes; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control; to service providers that provide customer experience management, product fulfillment, marketing, and fraud prevention and security services; and to other third parties (such as law enforcement) as required by law.

 

Internet or other electronic network activity information

Such as your browsing history, search history, and interactions with the Site.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site, or our social media). We also collect this information from third parties such as online advertising networks, online data aggregators, and social networks.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to administer accounts; to process orders, payments, and refunds; to provide, improve, market, and personalize our products and services and third-party products and services (including our Site); for physical security, cybersecurity, incident response, and risk reduction purposes; for legal, recordkeeping, and compliance purposes; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control; to service providers that provide customer experience management, marketing, fraud prevention and security; to third parties who set cookies and tags for third-party marketing and advertising (subject to your right to opt out, as defined below); and to other third parties (such as law enforcement) as required by law.

 

Geolocation information

Your physical location.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media).
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to administer accounts; to provide, improve, market, and personalize our products and services (including our Site); for physical security, cybersecurity, incident response, and risk reduction purposes; for legal, recordkeeping, and compliance purposes; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control; to service providers that provide customer experience management, marketing, fraud prevention and security; and to other third parties (such as law enforcement) as required by law.

 

Sensory information

Audio, electronic, visual, thermal, olfactory, or similar information related to you.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media).
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to provide, improve, and market our products and services (including our Site); for physical security, cybersecurity, incident response, and risk reduction purposes; for legal, recordkeeping, and compliance purposes; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control; to service providers that provide customer experience management and fraud prevention and security; and to other third parties (such as law enforcement) as required by law.

 

Inferences

Inferences drawn from any of the information identified above.

Disclosure	Description
Sources from which collected	We draw inferences about you from the information we collect from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also draw inferences about you from the information we collect from third parties such as financial institutions, payment processors, and social networks.
Purpose of collection	We draw these inferences to better understand, and communicate with you; to provide, improve, market, and personalize our products and services (including our Site); and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) as required by law.

 

CALIFORNIA PROFESSIONALS: The following table provides details about the personal information and/or sensitive personal information that we collect and handle within the preceding twelve (12) months for residents of California who interact with us in a professional/business capacity or in connection with a business to business relationship (instead of a business to consumer relationship). Such residents typically work for some of our suppliers, manufacturers, retail distributors, payment processors and/or other entities that provide general business and/or office support services.

 

Identifiers

Contact information (such as your name, the name of your company and the names of your associates, professional or corporate titles, shipping and billing address, business address, email address, telephone and fax numbers); unique identifiers (such as a device identifier); financial information (such as a credit or debit card number, bank account number); and online identifiers (such as an internet protocol address and a social media channel ID and company ID number). Note that certain financial information (such as a credit or debit card number) is not stored by us as this type of payment is handled through our payment processing service providers.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also collect this information from third parties such as financial institutions, payment processors, social networks, product and services suppliers, product manufacturers, retail distributors and general business and/or office support service providers.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you and your business; to create and administer accounts; to administer and manage events; to make announcements; to help manufacture, design, develop, promote and distribute our products, services and marketing campaigns; to process orders, purchases, payments and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; to conduct research; for business and legal, recordkeeping and compliance purposes; for general business and office management and operational support; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services or to support a business to business relationship that we have established with a supplier, manufacturer, retail distributor or other business that provides us with general business operational and/or office management support, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

Legally protected demographics

Such as your gender identity.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also collect this information from third parties such as financial institutions, payment processors, social networks, product and services suppliers, product manufacturers, retail distributors and general business and/or office support service providers.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you and your business; to create and administer accounts; to administer and manage events; to make announcements; to help manufacture, design, develop, promote and distribute our products, services and marketing campaigns; to process orders, purchases, payments and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; to conduct research; for business and legal, recordkeeping and compliance purposes; for general business and office management and operational support; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services or to support a business to business relationship that we have established with a supplier, manufacturer, retail distributor or other business that provides us with general business operational and/or office management support, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

Commercial information

Such as records of the products or services that you sold or considered selling to us.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media) and you likely work for one of our suppliers or manufacturers or general business support service providers.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you and your business; to create and administer accounts; to administer and manage events; to make announcements; to help manufacture, design, develop, promote and distribute our products, services and marketing campaigns; to process orders, purchases, payments and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; to conduct research; for business and legal, recordkeeping and compliance purposes; for general business and office management and operational support; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services or to support a business to business relationship that we have established with a supplier, manufacturer, retail distributor or other business that provides us with general business operational and/or office management support, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

Internet or other electronic network activity information

Such as your browsing history, search history, and interactions with the Site.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also collect this information from third parties such as financial institutions, payment processors, social networks, product and services suppliers, product manufacturers, retail distributors and general business and/or office support service providers.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you and your business; to create and administer accounts; to administer and manage events; to make announcements; to help manufacture, design, develop, promote and distribute our products, services and marketing campaigns; to process orders, purchases, payments and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; to conduct research; for business and legal, recordkeeping and compliance purposes; for general business and office management and operational support; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services or to support a business to business relationship that we have established with a supplier, manufacturer, retail distributor or other business that provides us with general business operational and/or office management support, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

Geolocation information

Your physical location.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also collect this information from third parties such as financial institutions, payment processors, social networks, product and services suppliers, product manufacturers, retail distributors and general business and/or office support service providers.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you and your business; to create and administer accounts; to administer and manage events; to make announcements; to help manufacture, design, develop, promote and distribute our products, services and marketing campaigns; to process orders, purchases, payments and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; to conduct research; for business and legal, recordkeeping and compliance purposes; for general business and office management and operational support; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services or to support a business to business relationship that we have established with a supplier, manufacturer, retail distributor or other business that provides us with general business operational and/or office management support, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

Sensory information

Audio, electronic, visual, thermal, olfactory, or similar information related to you.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also collect this information from third parties such as financial institutions, payment processors, social networks, product and services suppliers, product manufacturers, retail distributors and general business and/or office support service providers.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you and your business; to create and administer accounts; to administer and manage events; to make announcements; to help manufacture, design, develop, promote and distribute our products, services and marketing campaigns; to process orders, purchases, payments and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; to conduct research; for business and legal, recordkeeping and compliance purposes; for general business and office management and operational support; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services or to support a business to business relationship that we have established with a supplier, manufacturer, retail distributor or other business that provides us with general business operational and/or office management support, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

Inferences

Inferences drawn from any of the information identified above.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media). We also collect this information from third parties such as financial institutions, payment processors, social networks, product and services suppliers, product manufacturers, retail distributors and general business and/or office support service providers.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you and your business; to create and administer accounts; to administer and manage events; to make announcements; to help manufacture, design, develop, promote and distribute our products, services and marketing campaigns; to process orders, purchases, payments and refunds; to provide, improve, market, and personalize our products and services and third-party products and services; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; to conduct research; for business and legal, recordkeeping and compliance purposes; for general business and office management and operational support; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to various third party service providers who provide various business support services or to support a business to business relationship that we have established with a supplier, manufacturer, retail distributor or other business that provides us with general business operational and/or office management support, and to other third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security services.

 

CALIFORNIA EMPLOYEES AND JOB APPLICANTS: The following table provides details about the personal information and/or sensitive personal information that we collect and handle within the preceding twelve (12) months for residents of California who are our employees or who are job applicants.

Identifiers

Contact information (such as your name, the name of your former employers, names of your references, your former professional or corporate titles, your home address, email address, telephone and fax numbers, including the same contact information about your references); unique identifiers (such as your social security number, alien or I-94 number); financial information (such as your bank account); and online identifiers (such as an internet protocol address and a social media channel ID). Note that certain financial information (such as a credit or debit card number) is not stored by us as this types of payment is handled through our payment processing service providers.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media), in writing or in person.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to prepare and maintain employment records and job application records; to help us evaluate your prior employment history; to provide an electronic means for paying you through automatic deposits and to provide you with employment related benefits; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; for business and legal, recordkeeping and compliance purposes; for general business and office management; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security.

 

Legally protected demographics

Such as your race, ethnicity, or gender identity.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media), in writing or in person.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to prepare and maintain employment records and job application records; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; for business and legal, recordkeeping and compliance purposes; for general business and office management; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security.

 

Commercial information

Such as your product, brand and/or skin care preferences or views about our industry

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media), in writing or in person.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to prepare and maintain employment records and job application records; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; for business and legal, recordkeeping and compliance purposes; for general business and office management; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security.

 

Internet or other electronic network activity information

Such as your browsing history, search history, and interactions with the Site.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media).
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to prepare and maintain employment records and job applications; to help us evaluate your job performance; to provide you with employment related benefits; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; for business and legal, recordkeeping and compliance purposes; for general business and office management; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security.

 

Geolocation information

Your physical location.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media).
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to prepare and maintain employment records and job applications; to help us evaluate your job performance; to provide you with employment related benefits; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; for business and legal, recordkeeping and compliance purposes; for general business and office management; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security.

 

Sensory information

Audio, electronic, visual, thermal, olfactory, or similar information related to you.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media), in writing or in person.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to prepare and maintain employment records and job applications; to help us evaluate your job performance; to provide you with employment related benefits; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; for business and legal, recordkeeping and compliance purposes; for general business and office management; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security.

 

Inferences

Inferences drawn from any of the information identified above.

Disclosure	Description
Sources from which collected	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Site or our social media), in writing or in person.
Purpose of collection	We collect this category of information to identify, better understand, and communicate with you; to prepare and maintain employment records and job application records; to help us evaluate your prior employment history; to provide an electronic means for paying you through automatic deposits and to provide you with employment related benefits; to promote for physical security, cybersecurity, incident response, and risk reduction purposes; for business and legal, recordkeeping and compliance purposes; for general business and office management; and for other purposes communicated to you at the time of collection.
Categories of Third Parties with whom shared	We disclose this category of information to related or affiliated companies under our control and to third parties (such as law enforcement) in order to comply with our legal obligations or to provide fraud protection and security.

 

Your Rights under the CCPA

The CCPA provides you (as a California resident consumer, professional, employee or job applicant) with specific rights subject to certain limited exceptions:

• The right to know: You have a right under the CCPA to request that we disclose what personal information and sensitive personal information we collect, use, disclose, and sell. The process for exercising this right is described below under Exercising Your Right to Know, Right to Deletion, Right to Access, Right to Correct and Right to Limit.
• The right to deletion: You have a right under the CCPA to request deletion of any personal information about you that we have collected from you. The process for exercising this right is described below under Exercising Your Right to Know, Right to Deletion, Right to Correct and Right to Limit.
• The right to access: You have a right under the CCPA to be given access to and receive a copy of your personal information, including the right to provide your personal information to another organization, i.e. the right of data portability. The process for exercising this right is described below under Exercising Your Right to Know, Right to Deletion, Right to Access, Right to Correct and Right to Limit.
• The right to opt out: You have a right under the CCPA to opt-out of the sale of your personal information. The process for exercising this right is described below under Sale of Information and Your Right to Opt Out.
• The right to non-discrimination: You have a right under the CCPA not to be discriminated against for the exercise of your other rights. This includes the right not to be denied goods or services, not to be charged different rates for goods or services, and not to receive a different level or quality of goods or services from us for your exercise of your privacy rights under the CCPA.
• The right to correct: You have a right under the CCPA to have your personal information corrected should it be materially inaccurate. The process for exercising this right is described below under Exercising Your Right to Know, Right to Deletion, Right to Access, Right to Correct and Right to Limit.
• The right to limit: You have the right under the CCPA to limit the use and disclosure of your sensitive personal information (for example, only to have use of such information limited to providing you with products or services that you have requested). The process for exercising this right is described below under Exercising Your Right to Know, Right to Deletion, Right to Access, Right to Correct and Right to Limit.

As noted above, Right to Know,Right to Deletion, Right to Access, Right to Correct and/or Right to Limit may be subject to one or more limited exceptions, such as: we cannot verify you; we may not be required to provide you access to all of the specific pieces of information we have collected about you due to the sensitive nature of the information or we cannot honor the request to delete or limit information  under certain circumstances. For example, we are not required to delete or limit information that is necessary to complete a requested transaction, to detect security incidents, the request interferes with our legal obligations or legal rights or for certain other internal purposes.

The Sale of Information and the Right to Opt Out (discussed further below) may also be subject to (or not applicable to) certain limited exceptions such as if the selling or sharing of your personal information is made to one of our service providers who is using such information in order to help us provide our products and/or services or such sharing or selling is necessary for us to comply with our legal obligations or to exercise our legal rights.

Exercising your right to know, right to deletion, right to access, right to correct and right to limit

You may exercise your Right to Know and Right to Deletion, including Right to Access, Right to Correct or for sensitive personal information only, the Right to Limit

[https://www.ellisbrooklyn.com/pages/contact-us] or for the Right to Limit your sensitive personal information only, by clicking on “Limit the Use of My Sensitive Personal Information” or the “Limit the Use of My Sensitive Personal Information” link that is displayed on our Site’s homepage. 

To process your request, we must be able to verify your identity. In order to do so, you must provide the information we request as part of the verification process, such as your contact information and an additional non-sensitive personal information identifier based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity and your relationship with us.

You can designate an authorized agent to make a CCPA rights request to us on your behalf. When you use an authorized agent to submit a CCPA rights request, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

When you make a legitimate CCPA rights request, we will communicate that request to our appropriate service providers who are acting on our behalf so that they will similarly honor your request.

Sale of information and Your Right to Opt Out

The CCPA requires us to inform you whether we currently use your personal information (or used your personal information during the past twelve (12) months) in a way that would be considered a "sale" (as defined under the CCPA). We engage (and have engaged for the past twelve (12) months) in activity, including the use of third-party cookies and tags, that could be considered the "sale" (as defined in the CCPA) of (a) online identifiers and (b) internet or other electronic network activity information (each as defined in the table above) to marketing companies that support our online marketing efforts as well as to third parties that may have a secondary use of this information. Under such circumstances, we solicit your online consent before doing so.

You may exercise your Right to Opt Out (of the sale of personal information) by clicking on the “Do Not Sell My Personal Information” link here, the “Do Not Sell My Personal Information” link displayed on the homepage of our Site or by following the instructions contained on our Contact Us Form. You may access our Contact Us Form by clicking here.

Disclosure of information

The CCPA requires us to inform you whether we disclose your personal information to other parties. We do disclose your information in certain circumstances to service providers and other third parties, as described above, and we have disclosed this information as permitted in the preceding twelve (12) months.

Personal information and/or sensitive personal information collected from California resident consumers, California resident employees, California residents who work for our contractors and California resident job applicants

• Ellis Brooklyn Customers: If you are an Ellis Brooklyn consumer or customer who is also a California resident and would like to know detailed information about the specific personal information and/or sensitive personal information that Ellis Brooklyn collects from you or about you as an customer or consumer and the purposes for which the personal information and/or sensitive personal information will be used and how we handle such information, please click here [https://www.ellisbrooklyn.com/pages/contact-us].

• Ellis Brooklyn Service Providers/Contractors: If you are a manufacturer or supplier for Ellis Brooklyn, a retail distributor or other service provider or contractor of Ellis Brooklyn or work for one of these types of organizations that provides or purchases products and/or performs services for Ellis Brooklyn and you are a California resident and would like to know detailed information about the specific personal information and/or sensitive personal information that Ellis Brooklyn collects from you or about you as a service provider or contractor and the purposes for which the personal information and/or sensitive personal information will be used and how we handle such information, please click here [https://www.ellisbrooklyn.com/pages/contact-us]

 California’s “Shine the Light” law

If you are a California resident and an Ellis Brooklyn customer, you have the right to request information from us once per calendar year regarding the customer information that we may share with third parties for the direct marketing purposes of that third party, provided that we share customer information for such purposes. To request this information, please send an email to info@ellisbrooklyn.com with ‘Request for California Privacy Information’ in the subject line and in the body of your message. We will provide the requested information to you via an email response. 

California’s “Eraser Button” law

If you are a California resident under 18 years old and a registered user of the Site, you can request that we remove content or information that you have posted to our website or other online services. Fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please email us at info@ellisbrooklyn.com.

Responding to “Do Not Track Requests”

Under California law, there exist certain requirements governing an operator of a website or online service that collects personally identifiable information about consumers in California.  California law requires such operators to disclose how the operator responds to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities over time and across third-party web sites or online services, if the operator engages in that collection. At this time, other than as outlined in paragraphs 16 & 17 below and elsewhere in this Privacy Policy, we do not track our customers' personal information over time and across third-party websites and, therefore, we are not able to respond to “do not track” requests. California law also requires such operators to disclose whether third parties may collect personal information about their users' online activities over time and across different sites when the users use the operator's website or service. Third parties that have content or services on the Site (such as a social feature, analytics service, or an advertising network partner) may obtain information about your browsing or usage habits but this information does not include personal information. With the exception contained in paragraphs 16 & 17 below and elsewhere in this Privacy Policy, we do not knowingly permit such third parties to collect any personal information from the Site, for direct marketing purposes or otherwise, unless you directly provide it to us, and we provide it to them with your consent.

 

15. WEB BEACONS

Web beacons (sometimes called “tracking pixels,” “transparent GIFs,” “clear GIFs,” “pixel figs,” or “Pixel tags”) are tiny, invisible images that are embedded on web pages and emails and are stored on your hard drive. They help us count the number of users who visit our websites or open our emails. Tracking pixels help us figure out if certain advertisements/marketing campaigns, product features, notifications, and products or services are effective and if they can be improved. You can modify your browser settings to control web beacons.  Using web beacons enables us to measure the effectiveness of our ads for statistical and market research purposes. The data collected in this way is anonymous to us, and we do not see the personal data of individual users.

Our digital marketing and advertising campaigns are fluent and change over time. We are currently using various web beacons, including those from:

• Facebook (Instagram) 
• Pinterest
• TikTok
• Google
• YouTube
• Microsoft/Bing
• Yotpo
• Retention.com (For Retention.com, you may opt out of receiving this advertising by visiting https://app.retention.com/optout. This information can also be found here: https://retention.com/support/update-privacy-policy/)

 

 16. FACEBOOK CONVERSIONS API

We use Facebook’s Conversions API (sometimes called “server-side API”). Data is shared using your web browser and from Shopify’s servers, and is sent directly to Facebook’s servers. Data sent from server to server cannot be blocked by browser-based ad blockers. Your personal information will be used to match users on Facebook’s network. The information collected using this setting includes your name, location, email address, and phone number, as well as your browsing behavior on our online store.  Ellis Brooklyn uses this information for its legitimate interests to measure customer actions, improve the accuracy of information sent for targeting, measurement, and optimization, and for more control over data sharing.  You agree that Ellis Brooklyn can collect this data through the Facebook Conversions API platform for these purposes.

The data described under this section is also stored and processed by Facebook.  Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy, located at https://www.facebook.com/about/privacy.  You can allow Facebook and its partners to place ads on and off Facebook.  Facebook may use cookies, web beacons, and other storage technologies to collect or receive information from this website and your browsing activities elsewhere on the internet.

The legal basis for this use is Article 6, paragraph 1, sentence 1, letter f of the GDPR.  You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address:  https://www.facebook.com/settings?tab=ads.

Facebook is certified under the Privacy Shield Agreement (https://www.facebook.com/about/privacyshield) and thus guarantees compliance with European data protection legislation.

 

You may object to the use of cookies for measuring range and advertising purposes via the Network Advertising Initiative’s deactivation page (https://optout.networkadvertising.org) and additionally via the U.S. website (https://www.aboutads.info/choices) or the European website (https://www.youronlinechoices.com/uk/your-ad-choices).  Note, however, that the Facebook Conversions API does not use cookies, and so you must opt out directly with Facebook at https://www.facebook.com/settings?tab=ads.

 

 17. INFORMATION FROM THIRD-PARTY SERVICES

We allow you to create an account and log in to use this website through the following third-party services:  Facebook, Google, LinkedIn, and Amazon. 

If you decide to register through or otherwise grant us access to a third-party service, we may collect personal data that is already associated with your third-party service, such as your name, your email address, your activities, or your contact list associated with that account. 

You may also have the option of sharing additional information with us through your third-party services account.  If you choose to provide such information and personal data, during registration or otherwise, you are giving us permission to use, share, and store it in a manner consistent with this privacy policy. 

Instructions on changing the personal data these third-party services share with us are located as follows:

Facebook: https://www.facebook.com/help/1224342157705160

Google: https://support.google.com/accounts/answer/112802?co=GENIE.Platform%3DAndroid&hl=en

LinkedIn: https://www.linkedin.com/help/linkedin/answer/1207/third-party-applications-data-use?lang=en#:~:text=Click%20Settings%20%26%20Privacy%20from%20the,it%20from%20your%20LinkedIn%20account.

Amazon: https://www.amazon.com/gp/help/customer/display.html?nodeId=GSNRZP4F7NYG36N6

However, we may retain information you provided prior to terminating access.  If you want us to delete this information, please contact us at info@ellisbrooklyn.com.

 

 18. THE RIGHTS OF OUR CUSTOMERS WHEREVER YOU MAY BE LIVE

Our customers, including those individuals subject to specific state, federal and European Union (EU) and United Kingdom (UK) data protection laws, have data subject rights in relation to the personal data we hold on to them (described in detail below). This may, in and of itself, be subject to the following:

Please contact us to exercise your rights via paragraph 25 of this Privacy Policy to:

(i)           Access Your data

If prompted, we will confirm whether or not we are processing your personal data and if so, we will provide you with a copy of, or access to a copy of, that personal data along with any other pertinent details.

(ii)         Restricting the processing of personal data

You may ask us to restrict or stop processing your personal data in certain circumstances, for example, if you contest the accuracy of the data or object to us processing it. We will notify you before we lift any restriction on processing. If we share your personal data with others as provided in this Privacy Policy, we will notify them of the restriction wherever possible. If prompted, and if it is possible and lawful to do so, we will also notify you with whom we have shared or will share your personal data so you can contact them directly.

(iii)       Objections

You may:

• ask us to stop processing your personal data at any time, and we will do so unless we demonstrate compelling legitimate grounds for processing;
• object to our processing of your data for the purposes of direct marketing at any time by unsubscribing to receive our marketing materials (see the opt-out directions in the footer of our marketing materials); and
• refuse to receive service notifications via email. This can be adjusted in your Shopify .
• Otherwise, you may contact us in accordance in paragraph 25 below.

(iv)       Withdrawal of consent

If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time via paragraph 25 below or the directions stated in our marketing materials. This will not affect the lawfulness with which we process your data before receiving notice of your wish to withdraw your consent. We emphasize that we do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent, we will make this clear to you at that time.

(v)         Viewing and correcting data

You have the right to have inaccurate personal data rectified or completed if it is incomplete. In order to do so, you can view, manage and/or update your personal data in your .  If you have questions in regards to this process, please contact us via paragraph 25 below.

If we share your personal data with others, we will notify them of any corrections made whenever possible. If prompted, and where possible and lawful to do so, we will also notify you with whom we have shared your personal data so you can contact them directly if need be.

(vi)       Deleting data

You have the right to refuse to use our Services and may ask us to delete or remove your personal data in certain circumstances. If we share your data with others, we will notify them of the edits wherever possible. If prompted, and wherever possible and lawful to do so, we will also notify you with whom we have shared your personal data so you can contact them directly if need be.

(vii)     Data retention

We will keep your personal data (1) until you decide to delete your account (upon request), or (2) as required by law or as necessary for legitimate business purposes (i.e., for tax, legal, accounting, fraud, or abuse prevention, and/or other purposes). This data can be stored even after an account is deleted.

Upon expiration of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you. In this case, such data is no longer considered personal.

If you consent to receive marketing communications, we will keep your data until you unsubscribe, which is possible via the ‘unsubscribe’ button at the end of our marketing emails. Additional methods to unsubscribe may be added in the future.

(viii)   Data portability

You have the right to obtain your personal data from us, which that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used, and machine-readable format. You may reuse it elsewhere if you so wish.

(ix)       Lodge a complaint with the data protection authority

If you have concerns about our privacy practices, including the way we handle or have your personal data, and if you are EU or UK citizen, you can report it to any competent data protection authority of an European Union member state that is authorized to hear such concerns (you may find European Union Data Protection Authorities’ contact information here) or to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. If you wish to exercise any of these rights, please contact us. Note that we may need to ask you for further information to verify your identity before we can respond to any request.

 

 19. INTERNATIONAL DATA TRANSFER

We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from laws of the United States and state law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the United States and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

 

 20. REVIEWS AND TESTIMONIALS

We may select and post customer testimonials about our products and services, which may contain personal information such as your name and/or the city, state, or country in which you live. We will obtain your consent before we post any testimonial with your name. When you submit a review, you give us permission to post that review. If you post this content, it will be available to other users. Your posting may also become public, and we cannot prevent that information from being used in a manner that may violate our privacy policy or the law. If you would like us to remove or delete your name, testimonial, or review from our web pages, please contact us. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of our web pages for a period of time.

 

 21. CHANGES TO THIS PRIVACY POLICY

We may change our Privacy Policy from time to time at our discretion and will post any such changes on the Site. At the time of any change, we will change the date of the Privacy Policy at the top of this Privacy Policy. If we make what we deem to be a material change to our Privacy Policy, we will post a notice on the homepage of the Site for a reasonable period of time after such modification has been made. We encourage you to check our Privacy Policy periodically for any changes. Your continued use of the Site following the posting of changes to our Privacy Policy will mean you accept those changes, and they will be binding on you.

 

 22. A IMPACT OF SALE OR MERGER

It is possible that we and/or any of our assets may be acquired by a third-party. In such a transaction, as the owner of your information, we may disclose or sell the information as an asset of Ellis Brooklyn in conjunction with the sale of Ellis Brooklyn or the sale of a portion of our assets to a third-party. While we will endeavor to require the successor company to maintain this Privacy Policy, we cannot guarantee that this Privacy Policy will remain in effect.

 

 23. YOUR CONSENT

Use of the Site signifies your consent to this Privacy Policy, including the collection and use of information by Ellis Brooklyn, as described herein, and also signifies your agreement to the Terms of Service. Continued access and use of the Site without acceptance of the terms of this Privacy Policy relieves Ellis Brooklyn from responsibility to you.

 

 24. QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, make changes to your account, register a complaint, or simply want more information, please contact our Privacy Compliance Officer at the following:

 

Ellis Brooklyn

4 Star Point, Suite 201

Stamford, CT 06902

Email: Info@ellisbrooklyn.com