Privacy Policy
Last Updated: 09/06/2022
Scope
Top Knobs USA, Inc., together with other subsidiaries and brands of Dimora Brands, Inc. (collectively, “Dimora,” “we,” “our,” or “us”), respects the privacy of your information. This Privacy Policy (“Policy”) is designed to assist you in understanding how Dimora collects, uses and safeguards the information you provide to us in using our websites (“Sites”) and the services provided through our Sites (collectively, “Services”).This Policy covers the following topics:
- Types of Information We Collect
- How We Collect Your Information
- How We Use Your Information
- How We Share Your Information
- "Do Not Track" Signals
- Children Under 13
- Cookies & Other Tracking Technologies
- Third Party Processors
- Choices About Marketing Communications
- Notice to Nevada Residents
- Notice to California Residents
- Security
- Links
- Accessibility
- How to Contact Us
- Changes in Policy
Types of Information We Collect
Dimora collects Personally Identifiable Information from you through your use of the Sites and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. Here are some examples of the information we may collect:
- Contact Information. For example, we may collect your name, email address, telephone number, mailing address, and social media handle.
- Business Contact Information. For example, your company’s name, address, and telephone number.
- Account Login Information. If you are registered for one of our online accounts or portals, in addition to contact information.
- Payment Information. For example, credit card number and billing address for business accounts or to receive product samples.
- Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
- Device Information. For example, we may collect the type of device you use to access our Sites. We may also collect your device identifier, IP address, mobile network information, or mobile operating system.
- Location Information. We may collect location information on a city-regional basis.
- Other Information. If you use our Sites, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.
How We Collect Your Information
Dimora collects your Personally Identifiable Information in different ways. Below are some examples of how we may collect your information.
- Directly From You.For example, when you submit a request or question to us, subscribe to a newsletter, register to become a dealer or for a customer portal (e.g., dealer portal), or utilize our free sample program.
- PassivelyFor example, when you visit and navigate our Sites on any device, we may also collect information about your use of the Sites over time and across different devices.
- From Third PartiesWe may receive information about you from other sources. For example, this may include receiving information from our business partners, including analytics vendors, and from advertising networks.
In some cases, we may receive certain Personally Identifiable Information from you about a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Policy.
How We Use Your Information
Examples of how we may use your Personally Identifiable Information include:
- Process Your Account Registration. This could include your application to become a dealer or your request to register for a customer portal.
- Process and Fulfill Your Order. This may include our free sample program and certain of our Sites that offer online ordering.
- Process Product Warranties. This may include registering your product for a warranty or processing your warranty claim.
- For Contests/Sweepstakes. We will use your information submitted to a sweepstakes, contest, survey, or other promotion to contact you regarding the promotion, to market to you, and for any purposes disclosed to you at the time of entry.
- For Recruitment. When you apply for a job, we may use your information for the purpose of employment consideration, background checks and employment eligibility, and as otherwise set forth in any separate privacy statement or other notice made available to in connection with your application.
- To Contact You. This could include sending you our newsletters or blogs to which you subscribe and contacting you regarding our products and services that we feel may be of interest to you. This may also include contacting you regarding webinars, events, or trainings for which you register.
- To Improve Our Business. We may use your information to make our Sites and Services better and otherwise efficiently maintain our companies.
- To Respond to Your Requests or Questions. This may include responding to your feedback or inquiry.
- For Security Purposes. This could include protecting our companies and other consumers who use our products and services. It may also include protecting our Sites.
- To Defend Our Legal Rights and the Rights of Others.
- As Otherwise Permitted or Required by Law or As We May Notify You.
“Do Not Track” Signals
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our Sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
Children Under 13
Our Sites are not intended for children under the age of 13. We do not knowingly collect, use, or disclose personal information from children under 13.
Third Party Processors
To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, certain of our Sites use third-party payment processors and marketing service providers.
Choices About Marketing Communications
To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us by contacting us as provided below under “How to Contact Us”.
Notice to Nevada Residents
Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to privacy@dimorabrands.com.
Notice to California Residents
The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it. The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.” The CCPA contains an exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to personal information collected in a business-to-business context. That is information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such entity.
Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information that we have collected about you;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
Collection of Personal Information
We currently collect and, in the 12 months prior to the Last Updated date of this Policy, have collected the following categories of Personal Information:
- Identifiers (name, postal address, online identifier, IP address, email address, account name)/li>
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number)
- Telephone number
- Credit and debit card number (to receive product samples)
- Internet or other electronic network activity information (browsing history; search history; and information regarding a consumer’s interaction with the Sites, application or advertisement)
- Geolocation data
- Commercial information (records of products or services purchased, obtained or considered)
- Professional or employment-related information (e.g., company name and role)
- Audio and visual information (e.g., webinars and contest photo submissions)
- Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences
The Personal Information is collected from California residents directly and from advertising networks, internet service providers, data analytics providers, and operating systems and platforms. Not all categories of Personal Information are collected from each source. In addition to the purposes stated above in the section “How We Use Your Information”, we currently collect and have collected and sold the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, and providing advertising, marketing, and analytic services
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of our services or products, and to improve, upgrade, or enhance same
- Commercial purposes, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Disclosure or Sale of Personal Information
The following table identifies the categories of Personal Information that we disclosed for a business purpose to service providers or sold to third parties in the 12 months preceding the Last Updated date of this Policy and, for each category, the category of service providers or third parties to whom the Personal Information was disclosed or sold. Note, the only potential “sales” to third parties pertain to certain of the Sites’ use of third-party advertising cookies, as discussed more fully below under, “Right to Opt-Out of Sale of Personal Informaion”. We do not knowingly collect or sell the Personal Information of minors under 16 years of age.
Category of Personal Information | Category of Service Providers | Category of Third Parties |
---|---|---|
name, postal address, company name and role, email address, account name, telephone number | Fulfillment providers, marketing agencies, legal and accounting service providers | Advertising networks, Credit networks, Financial networks |
online identifier, IP address, device identifier, cookies, beacons, pixel tags, mobile ad identifiers | Data analytics providers | Advertising networks |
browsing history, search history, and information regarding a consumer’s interaction with the Sites, application or advertisement; records of products or services purchased, obtained or considered; geolocation data | Data analytics providers, marketing agencies | Advertising networks |
Credit and debit card number | Payment processors | Financial networks |
Audio and visual information (e.g., webinars and contest photo submissions) | Fullfillment providers | Technology platforms |
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferencesW | Advertising networks | Advertising networks |
Right to Request Deletion of Personal Information
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
How to Submit a Request to Know or Delete
You may submit a request to know or delete by calling us toll free at 1-800-499-9095 or by emailing us at privacy@dimorabrands.com.
Our Process for Verifying a Request to Know or Delete
If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt-Out of Sale of Personal Information
If you are a California resident, you have the right to direct businesses to stop selling your Personal Information.
The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.
Certain of the Sites’ use of certain third-party cookies may constitute “sales” under the CCPA. To exercise your right to opt-out of this “sale” of Personal Information, please view the “How You Can Opt-Out of Cookies” section above. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt-out.
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”
Authorized Agents
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Shine the Light Law
We do not disclose personal information obtained through our Sites to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
Security
The Internet is not 100% secure. We cannot promise that your use of our Sites will be completely safe. We encourage you to use caution when using the Internet. We use commercially reasonable means to safeguard the Personally Identifiable Information under our control from loss, misuse, destruction, or unauthorized access but cannot guarantee absolute security.