Privacy Policy – BauBax-ROW

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PRIVACY POLICY (Updated 12/30/2019) 

The BAUBAX Company and its affiliates (“BAUBAX”) were created to create the best travel apparel for explorers worldwide, and our sites and applications are created to inform and connect guests with the best that we have to offer on the platforms and devices our guests prefer. When our guests use our sites and applications, we may obtain data from and about guests and their devices. We are dedicated to treating your personal information with care and respect. Our privacy policy is designed to provide transparency into our privacy practices and principles in a format that our guests can navigate, read and understand. Our policy explains: 

  • The scope of this policy 
  • The types of information we collect 
  • How we collect your information 
  • How we use your information 
  • The limited circumstances under which we share your personal information with other entities 
  • Your controls and choices 
  • Our children’s privacy policy and practices 
  • Our data security, integrity, and retention policies and practices 
  • Our global data transfer, storage, and processing practices 
  • How we manage updates to this policy 
  • How to contact us with comments and questions 
  • Definitions of terms in the policy 

ONLINE TRACKING TECHNOLOGIES AND ADVERTISING We and certain service providers operating on our behalf collect information about your activity, or activity on devices associated with you, on our sites and applications using tracking technologies such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons. LEARN MORE 

CHILDREN’S PRIVACY POLICY BauBax is committed to protecting the privacy of children who use our sites and applications. 

TYPES OF INFORMATION WE COLLECT We collect two basic types of information – personal information (as defined in this policy) and anonymous information (as defined in this policy) – and we may use personal and anonymous information to create a third type of information, aggregate information (also defined in this policy). For example, we collect: 

Registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, gender, date of birth, email address, username, and password; 

Transaction information you provide when you request information, contact Guest Services, or purchase a product or service from us, such as your postal address, telephone number, and payment information; 

Information you provide in public forums on our sites and applications, such as your public posts; 

Information sent either one-to-one or within a limited group using our message, chat, post, or similar functionality, where we are permitted by applicable law to collect this information; 

Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices; 

Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information; Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences; and 

Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address. 

HOW WE COLLECT YOUR INFORMATION 

We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to guest surveys, or otherwise interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands. 

We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third- party sites or platforms using one or more devices, whether or not you are logged in or registered. Please visit Online Tracking Technologies and Advertising for further information, including Do Not Track and how to disable cookies and otherwise make choices with respect to such data collection. 

We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms. 

We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it. 

USE OF YOUR INFORMATION BY BAUBAX The member of BAUBAX that is the data controller for your information is responsible for and may use your information for the purposes described in this policy. Other members of BAUBAX may have access to your information where they perform services on behalf of the data controller(s) (as a data processor) and, unless prohibited under applicable law, for use on their own behalf (as a data controller) for the purposes described in this policy. Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to: 

Provide you with the experiences, products, and services you request, view, engage with, or purchase; 

Communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and applications or changes to our policies; Send you offers and promotions for our products and services or third-party products and services; 

Personalize content and experiences; Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications; 

To learn more about how we use your information for personalization and tracking, please visit Online Tracking Technologies and Advertising. 

Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including by using guest survey research and analytics tools; and 

Detect, investigate and prevent activities that may violate our policies or be illegal. 

SHARING YOUR INFORMATION WITH OTHER ENTITIES 

We will not share your personal information with a third party outside BAUBAX except in limited circumstances, including: 

When you allow us to share your personal information with another company, such as: Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services; and 

Directing us to share your personal information with third-party sites or platforms, such as social networking sites. 

Please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices. 

When we cooperate with financial institutions to offer co-branded products or services to you, we will do so only if permitted by applicable law and, in these cases, the financial institutions are prohibited from using your personal information for purposes other than those related to the co-branded products or services; 

When companies perform services on our behalf, like package delivery, marketing and advertising, and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law; and 

When we share your personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law. 

YOUR CONTROLS AND CHOICES We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include: 

Correcting, updating, and deleting your registration account (Logout); Choosing or changing your choices for subscriptions, newsletters, and alerts; Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you; 

Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services; 

Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers (by visiting the Digital Advertising Alliance); 

Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest based ads; 

Requesting removal of your personal information from a public forum on one of our sites or application; and 

Requesting access to the personal information we hold about you and that we amend or delete it. 

You may exercise these controls and choices in various ways, including by visiting Communication Choices (under the Privacy Controls tab), contacting Guest Services, following instructions provided in communications sent to you, or by using your device or other available settings (for example, by re-setting your device’s advertising identifier and/or opting out of interest based ads). You can opt out of interest based ads by visiting the Digital Advertising Alliance or European Interactive Digital Advertising Alliance or using the opt-out mechanism in the “Interest Based Ads” link in the footer of the site you are visiting. Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our 

services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact Guest Services. 

CHILDREN'S PRIVACY We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our sites and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including: 

Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information; 

In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children; 

Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and 

Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted. For additional information about our practices in the United States and Latin America regarding children’s personal information, please read our Children’s Privacy Policy. 

DATA SECURITY, INTEGRITY, AND RETENTION The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. 

DATA TRANSFERS, STORAGE, AND PROCESSING GLOBALLY We operate globally and may transfer your personal information to individual companies of BAUBAX or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements of standard contractual clauses when transferring personal information from Australia. 

CHANGES TO THIS PRIVACY POLICY From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting 

notice of such changes on our sites and applications, or by other means, consistent with applicable law. 

COMMENTS AND QUESTIONS If you have a comment or question about this privacy policy, please contact us. 

CALIFORNIA RESIDENTS’ RIGHTS Notice to California Residents: If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of BAUBAX to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. The California Consumer Privacy Act, California Civil Code 1798.100, et seq., requires transparency regarding data practices and permits you to request, among other things, access to and deletion of your personal information, and requires that we provide you control over certain data transfers deemed under the law to be a “sale.” Visit our Your California Privacy Rights page for more information. 

DEFINITIONS IP ADDRESS An IP address is associated with the access point through which you enter the Internet, and is typically controlled by your Internet Service Provider (ISP), your company, or your university. We may use IP addresses to collect information regarding the frequency with which our guests visit various parts of our sites and applications, and we may combine IP addresses with personal information. 

MEMBER Member means a subsidiary or affiliated entity that is part of BAUBAX. 

PARENTS Parents means a parent or legal guardian. 

PERSONAL INFORMATION Personal information means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information. 

PUBLIC FORUMS Our sites and applications may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages, and other forums that do not have a restricted audience. If you provide personal information when you use any of these features, that personal information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party. 

AGGREGATE INFORMATION Aggregate information means information about groups or categories of guests, which does not identify and cannot reasonably be used to identify an individual guest. 

ANONYMOUS INFORMATION Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest. 

APPLICATION 

Application means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile, or other platforms and environments, including those operated by third parties, which permits us to interact directly with our guests. 

CHILDREN Children means individuals who we have identified are not of legal age to consent to the collection and processing of their personal information. In the United States and Latin America, the term “children” refers to individuals under 13 years of age. 

  1. ONLINE TRACKING TECHNOLOGIES AND ADVERTISING We and certain service providers operating on our behalf collect information about your activity, or activity on devices associated with you, on our sites and applications using tracking technologies such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons. Definitions for some of the tracking technologies listed, as well as information about your choices with respect to them, are available below. This tracking data may be used for many purposes including, for example, to: 

Provide useful features to simplify your experience when you return to our sites and applications (for example, remembering your shipping information for future purchases); 

Deliver relevant content and advertising based on your preferences, usage patterns and location; Monitor, evaluate, and optimize the use and operation of our sites and applications; and 

Analyze traffic on our sites and on the sites of third parties. We may collect information whether or not you are logged in or registered, and may associate this tracking data with your registration account (if you have one), in which case we will treat it as personal information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online. Advertisers and third parties also may collect information about your activity on our sites and applications, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our sites and applications and on third-party sites and applications. 

You may choose not to receive targeted advertising from many ad networks and partners, data exchanges, and marketing analytics and other digital advertising and marketing service providers. You may also be able to choose to control targeted advertising on other websites and platforms that you visit. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices (for example, by re-setting your mobile device’s advertising identifier and/or opting out of interest based ads). We adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. 2. ONLINE TRACKING TECHNOLOGIES Examples of online tracking technologies include: 

Cookies. Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your computer warn you each time a cookie is being placed on your device, or you can choose to block all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your guest experience more efficient, and some of our services will not function properly. 

Flash cookies. We may use local shared objects, sometimes known as Flash cookies, to store your preferences or display content based upon what you view on our site to personalize your visit. Our advertisers and third-party service providers also may use Flash cookies to 

collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and manner in which data is stored. Cookie management tools provided by your browser will not remove Flash cookies. Learn how to manage privacy and storage settings for Flash cookies. If you disable Flash cookies, you won’t have access to many features that make your guest experience more efficient, and some of our services will not function properly. 

Web beacons. Web beacons are small pieces of data that are embedded in images on the pages of sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use web beacons to bring together information we collect about you. 3. DO NOT TRACK Web browsers can transmit Do Not Track signals that indicate that a user does not wish to have activity tracked. Currently, no universally accepted standard exists for how to interpret such signals, although work to create consensus is ongoing. Accordingly, we adhere to the standards set out in our privacy policy. You can manage your choices regarding targeted advertising as described in Section 1 above and in Your Controls and Choices. Learn about Do Not Track. 

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