Privacy policy

DRIFTWARD PRIVACY POLICY

Last updated: January. 20^th, 2021

The Golden State Company, LLC, doing business as “Driftward” (“We”, “Our”, “Us”) respects your privacy rights. This Privacy Policy describes how we collect, use and share the personal data that we gather from you or that you may provide when you access and use our online services and products, including but not limited to our website located at www.driftward.com^{Please click the following links to learn more about our Privacy Policy:}^{1. What Types of Personal Information Do We Collect?
2. How Do We Use Personal Information?
3. How Do We Share Personal Information?
4. Your Privacy Choices
5. California Privacy Rights
6. European Union Privacy Notices
7. Children’s Privacy
8. Safeguarding Your Data
9. International Transfers
10. Data Retention
11. Do Not Track
12. Policy Changes
13. Contact Information}

1. What Types of Personal Information Do We Collect?

The categories of information that you may provide to us or that we may collect include:
• Identifiers such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline;
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Information that you provide by filling in forms on our website, including requesting services or information about our products or that we or one of our partners contact you;
• Records and copies of your correspondence, if you contact us;
• Details of transactions you carry out with us and of the fulfillment of your orders (including financial information when placing an order);
• Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the Site or Services; and
• Geolocation data.

^{Information may be collected in the following ways:

Information You Give Us. You may give us information when you contact us using the “Contact Us” or similar function on our website. You may also provide us information in your correspondence and transactions with us by phone, mail, e-mail or other electronic means, including when you make a purchase on our website.

Information We Automatically Collect. We may collect various information about you using computer technology as you access and use the Site and Services, including browser and device information, and information collected through cookies, pixel tags and other technologies. You may set your browser to not accept cookies, or to warn you when a cookie is being placed on your computer. If you choose not to accept cookies, however, your ability to navigate the Site and/or Services may be hindered.

Third parties, including social media networks, partners or third-party applications or websites linked to on our website, may use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for any information collected through them.

Shopify. Our online store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. When purchasing products and services on our website, your information, including financial information, will be provided to Shopify for the purpose of carrying out those transactions. Any information provided to Shopify will be governed by Shopify’s Terms of Service and Privacy Policy. In addition, Shopify uses cookies, and more information about their use of cookies can be found in the Shopify Cookie Policy.

Social Media. We may use social media features and widgets to interact with and provide information to our customers. Your interactions with these features, and any interactions with us on these social media platforms, are governed by the privacy policy and terms of use of the company providing it. For more information on the technologies used by these social networks, please refer to their specific privacy policies on their websites.

Third Party Links and Websites. From time to time, our website may contain links to and from the websites of other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these other websites.}

2. How Do We Use Personal Information?

We use your personal information as follows:

^{• To provide you with information, products, or services that you request from us or that we think may be of interest to you based on the information that you have provided to us, including to send you emails and other marketing communications;
• To respond to your specific requests or fulfill any other purpose for which you provide it;
• To deliver to you any administrative notices, advice and communications relevant to your use of our products and/or services;
• To analyze usage and improve the products and services offered;
• For market research, project planning, troubleshooting problems;
• For detecting and protecting against error, fraud or other criminal activity; and
• In any other way we may describe when you provide the information and for any other purpose with your consent.}

^{Affiliates, Partners and Service Providers. We may share your information with our affiliates, subsidiaries, partners, and/or third-party service providers as may be required to provide you with the information, products and services that you request or that we think you may be interested in based upon the information that you have provided to us, or for any other legitimate purpose described in Section 2 of this Privacy Policy.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Change of Control. Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your personal information.}

4. Your Privacy Choices

^{Access/Changes: If you wish to have access to information about you in our records, please contact us using the contact information in section 13 below. You may also request that we update information about you, or request correction of any factual errors that you believe may exist regarding this information. We will use commercially reasonable efforts to accommodate such requests. In any event, in no event will we be able to provide you with information about you that is not readily personally identifiable in our records or which would be prohibited by law.}

^{Email Marketing Opt-Out: We may use your information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send. You will still continue to receive
service-related messages concerning products and services you have purchased (unless we have indicated otherwise).}

5. California Privacy Rights

^{If you are a California consumer, you have the following rights:}

^{• The right to know what personal information is being collected about you.
• The right to know whether your personal information is sold or disclosed and to whom.
• The right to say no to the sale of personal information.
• The right to access your personal information.
• The right, in certain circumstances, to delete the information you have provided to us.
• The right to equal service and price, even if you exercise your privacy rights.}

^{Requests for Information and Deletion. California consumers have the right to request, up to twice in a 12-month period, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months.}

^{(1) The categories of personal information it has collected about that consumer.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting or selling personal information.
(4) The categories of third parties with whom the business shares personal information.
(5) The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
(6) The categories of personal information that the business disclosed about the consumer for a business purpose.
(7) The specific pieces of personal information it has collected about that consumer.}

^{To make such a request for information, or to request that we delete your personal information, please email us at info@driftward.com.}

^{Do Not Sell My Personal Information. California consumers have the right to opt out of the sale of the consumer’s personal information. To make such a request, please email us info@driftward.com or visit this webpage titled “Do Not Sell My Personal Information”.}

^{Request Verification. Please note all consumer requests described above in this Section 5 are subject to verification and there may be circumstances where we do not honor your request, as required or permitted under the law. We may verify any request by asking for additional information, including identifying information to verify the identity of the person making the request. You are entitled to make any such request through an authorized agent. If an authorized agent is making the request, such requests are subject to the same verification process mentioned above and we may also ask for additional proof of authorization.}

^{Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes in certain instances. To make such a request, please contact us at info@driftward.com.}

6. European Union Privacy Notices

Privacy Rights. If you are located in the European Union, you may have the following rights:
• A right to lodge a complaint with the supervisory authority where we process your information in a way that does not comply with the laws and regulations.
• A right of access to information undergoing processing. We may charge a reasonable administrative fee if further copies of your information are requested.
• A right to rectify inaccuracies in information we collect and hold about you.
• A right to require your information to be provided to you or to another company in a commonly used electronic form. • A right to object to specific types of processing such as direct marketing, processing based on legitimate interest, or processing for research or statistical purposes.
• A right to have your information ‘erased.’
• A right to temporarily restrict processing of information, for example if you believe the information is inaccurate or being used illegally.
• A right to withdraw your consent for future processing.

If you want to exercise or request more information about one or more of the above rights, you can contact us using the contact information listed in Section 13.

Legal Bases for Processing Your Information. We collect and use information about you pursuant to applicable law, contractual obligations, and with transparency and fairness. The legal basis for processing depends on the products or services you use and how you use them. We rely on the following lawful grounds:

^{Consent. Where appropriate or legally required, we collect and use your information subject to your consent.
Performance of contract. We collect and use information about you to enter into a contract with you or to perform a contract that you have with us.
Legitimate interests. We collect and use information about you for our legitimate interests, for example to deliver the products and services that you request, to market the products and services that you request or that we think you may be interested in, and to optimize your experience with our products and services.
Compliance with laws. We may also collect and use information about you: (i) as required by law, such as to comply with a subpoena or similar legal process, (ii) when we believe in good faith that disclosure is necessary to protect our rights or property, protect your health and safety or the health and safety of others, investigate fraud, or respond to a government request, or (iii) if we are involved in a merger, acquisition, or sale of all or a portion of its assets.}

^{We do not use personal information about you in any automated decision making or profiling that would have a legal or similarly significant effect on you without obtaining your consent.}

7. Children’s Privacy

Our Site and Services are not directed at individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information, please contact us using the contact information in section 13 below. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.

8. Safeguarding Your Data

To guard your personal information, we will maintain reasonable and appropriate physical, electronic and procedural safeguards that comply with applicable legal standards.

9. International Transfers

We are located in the United States (“US”). If you choose to provide us with your information, we may transfer your personal information cross-border. For example, we may transfer your information to affiliates, subsidiaries, partners, or other third parties located outside of or within your home country for the purposes described in this Privacy Policy. If you are located in the European Union (“EU”) or other regions with laws governing data collection and use that may differ from the laws of the US, please note that you are transferring your information to the US, which does not have the same data protection laws as the EU.

With knowledge of these risks, by providing your personal information you understand: (i) your personal information will be used in accordance with this Privacy Policy; and (ii) your personal information will be transferred to the US and other jurisdictions, in accordance with applicable law.

11. Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

12. Policy Changes

We may change our Privacy Policy at any time. The date the Privacy Policy was last revised is identified at the top of the page. You are encouraged to periodically visit this Privacy Policy to check for any changes. In any event, your further use of our Site and Services, or your providing of information to us, after a change to our Privacy Policy will be subject to the updated policy.