Your Privacy Rights

This privacy notice was last updated on April 10, 2020.

Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us in the event you have a complaint.

Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Collin Street Bakery, Inc.
Personal information	Any information relating to an identified or identifiable individual

Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Personal Identifiers	Name, address, phone, email, fax.
Order Information.	In addition to Personal Identifiers, we also collect information about your orders and any information you provide us about third-parties to whom you are giving gifts (e.g., their name, address, phone, email, or fax).
Internet or other electronic network activity information.	IP Address, URL, browsing history, search history, and information your interaction with the website, application, or advertisement.
Calls to our call center.	Personal Identifiers and recordings of your calls with our representatives.
Professional or employment-related information	We collect your Personal Identifiers and other information you provide when you submit an employment application to us online or by email.

If you do not provide personal information we ask for, it may delay or prevent us from providing products to you.

How Your Personal Information is Collected. We collect most of this personal information directly from you, for example, when you create an account and submit an order on our website. However, we may also collect information:

When you submit an employment application through Indeed.com or a similar third-party website; and
From cookies and similar online tracking and analytic technology on our website.

Use of Cookies. We use technologies, such as cookies, to customize content and advertising, to provide social media features and to analyze traffic to the site. We also share information about your use of our site with our trusted social media, advertising and analytics partners. You are given the option to consent to the collection and use of your data in this manner prior to it being collected. These options may be modified at https://collinstreet.com/enable-cookies and/or as provided below.
Google Analytics. For more information about how Google uses data when you use our site, visit google.com/policies/privacy/partners. Users may download the Google Analytics Opt-out Browser Add-on at: https://tools.google.com/dlpage/gaoptout.
Facebook Pixel. More information may be located at https://www.facebook.com/‌business/‌‌learn/facebook-ads-pixel. You can adjust your settings at https://www.‌facebook.com/ads/preferences/?entry_product=ad_settings_screen.
More information about JustUno may be located here: https://www.justuno.com/legal/terms-of-service/.
For more information about how YotPo uses data, visit https://www.yotpo.com/yotpo-privacy-guide/.
How and Why We Use Your Personal Information. We use your personal information:

Where you have given consent;
For the performance of our contract with you or to take steps at your request before entering into a contract;
To comply with our legal and regulatory obligations;
For our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
As necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

10. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services and share your personal information with third-party marketing firms.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”).

You have the right to opt out of receiving promotional communications from us at any time by:

Using the “unsubscribe” link in emails or “STOP” number in texts. Full SMS terms can be found here.

We may ask you to confirm or update your preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

11.Who We Share Your Personal Information With. We routinely share personal information with:

Service providers we use to help deliver our products and/or services to you, such as payment service providers, web hosting companies, warehouses and delivery companies;
Other third parties we use to help us run our business, such as marketing agencies or website hosts;
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
Our insurers and brokers;
Our banks;
Third-party marketing firms.
We may share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. may anonymize information, but this may not always be possible.

12. Do Not Track

We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

13. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Personal Identifiers;
Order Information;
Internet or other electronic network activity information

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Personal Identifiers;
Order Information; and,
Internet or other electronic network activity information

14. Where Your Personal Information is Held. Information is held at our offices and those of our service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”) or on computer servers used or maintained by those entities.

15. How Long Your Personal Information Will Be Kept. Unless we delete your information subject to a legitimate request, we reserve the right to keep your personal information indefinitely, including while you have an account with us or while we are providing products and/or services to you. We will also keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

16. EU Data Subject’s Rights Under the GDPR.

If you are a data subject in the European Union, you may have the following rights under the GDPR:

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

17. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

On our website at https://collinstreet.com/contact; or
Call us, toll-free, at (800) 267-4657;

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly (i.e., outside of logging in to your account on our website), you will need to provide us with:

Enough information to identify you (e.g., your full name, address);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

18. Changes to This Privacy Notice. We may change this privacy notice from time to time–when we do, we may inform you via notice on the website or other means of contact such as email.

19. How to Contact Us. You may contact us at help@collinstreet.com.

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