Oriental Trading Company, Inc. and Affiliated Companies
Privacy Policy Addendum

If you are a consumer and resident of California, Colorado, Connecticut, Utah or Virginia (in each case, a “consumer”), the information in this Privacy Policy Addendum (this “Privacy Policy Addendum”), along with our general website privacy policy and terms of use applies to you. This Privacy Policy Addendum is written to be easy to read and understand by using ordinary English. Accordingly, certain terms used in this Privacy Policy Addendum may not be the same as terminology used under a specific state privacy law and in such case the terms we use in this Privacy Policy Addendum should be interpreted to correspond with terminology conceptually similar to those used or defined under state privacy laws. The purpose of this Privacy Policy Addendum is to provide consumers with a comprehensive description of our online and off-line practices regarding the collection, use, disclosure and sale of personal information and the rights of consumers regarding their personal information.

Notification of the Right to Opt Out of the Sale of Personal Information

Consumers have the right to opt out of the sale of their personal information and the right to direct a business that sells personal information to stop selling the personal information and refrain from doing so in the future. You may exercise your right to opt out of the sale of your personal information by clicking on the "Do Not Sell My Personal Informationhere using the web form for that purpose or by calling (800) 228-1679.

Notification of Collection of Personal Information

Below is a list of the categories of personal information about consumers which we may collect, the business or commercial purposes for which the personal information will be collected, and the categories of sources from which we collect personal information.

  • Categories of Personal Information Collected. We may have collected and presently collect the following categories of personal information about consumers:
    1. identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, Tax Identification Number, and other similar identifiers;
    2. signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information;
    3. characteristics of protected classifications under state or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, marital status, ancestry, and military and veteran status;
    4. commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, wedding, birthday and other event information;
    5. Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
    6. geolocation data;
    7. audio, electronic, visual, and similar information;
    8. professional or employment-related information;
    9. education information; and
    10. inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Business and Commercial Purposes for the Collection of Personal Information. For purposes of this Privacy Policy Addendum a “business purpose” means the use of personal information for our operational purposes and “commercial purposes” means to advance a person’s commercial or economic interests such as by inducing a person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods or services, or enabling or affecting, directly or indirectly, a commercial transaction. We may have collected and sold and presently collect and sell personal information about consumers for the following business and commercial purposes:
    1. performing Services (as defined below), including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing other services relating to ecommerce and direct marketing;
    2. auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance and auditing related to contractual or financial obligations or standards;
    3. short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
    4. detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
    5. debugging to identify and repair errors that impair existing intended functionality;
    6. undertaking internal research and analysis for marketing, technological and product development;
    7. undertaking activities to verify or maintain the quality or safety of a service or product;
    8. completing a transaction, providing a product or service, performing a contract, detecting and protecting against security incidents and malicious, deceptive, fraudulent or illegal activity or prosecuting those responsible, debugging to identify and repair errors that impair functionality, enabling solely internal uses, and complying with legal obligations, record retention and back-up practices, assisting in litigation or for other lawful purposes; and
    9. advertising or marketing purposes of third parties, or enabling third parties to process, correct, enhance, aggregate, rent or share personal information or to assist us or third parties in any of the foregoing.
  • Categories of Sources of Personal Information. We may have collected and presently collect personal information about consumers from the following categories of sources:
    1. from you, for example, when you provide your name, postal address, telephone/mobile or fax number, email address, credit card information and other data, and when you browse our website, place an order, enter a contest, submit content, request a catalog or make other use of our website, catalog or call center (our “Services”);
    2. your family and friends when they use our Services, such as by sending a product, catalog, or information about our products directly to you;
    3. our affiliates;
    4. social media networks; and
    5. advertising networks, list brokers and managers, list rentals and cooperatives.

 Lists of Personal Information Sold or Disclosed

  1. List of Personal Information Sold. We may have sold the following categories of personal information about consumers to the following categories of third parties:

Categories of Personal Information Sold

Categories of Third Parties to Whom Sold (applicable to each category of personal information)

identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers;

commercial information, including records products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, wedding, birthday and other event information; and

Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.

our affiliates;

vendors who provide services on our behalf, including, but not limited to, list brokers, list managers, marketplace facilitators, consumer reporting agencies;

our marketing, research and analytics partners; and

third-party marketers (who may combine your personal information with their own records, and records available from other sources), for their own direct marketing purposes, and the direct marketing purposes of other third-party marketers.

We do not sell the personal information of minors under 16 years of age without affirmative authorization.

  1. List of Personal Information Disclosed for Business or Commercial Purposes. We may have disclosed for business or commercial purposes the following categories of personal information about consumers to the following categories of third parties:

Categories of Personal Information Disclosed for Business or Commercial Purposes

Categories of Third Parties to Whom Disclosed (applicable to each category of personal information)

identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers;

signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information;

characteristics of protected classifications under state or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, marital status, ancestry, and military and veteran status;

commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, wedding, birthday and other event information;

Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;

geolocation data;

audio, electronic, visual, and similar information;

professional or employment-related information;

education information; and

inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

our affiliates;

processors, service providers, contractors and vendors who provide services on our behalf, including, but not limited to, list brokers, list managers, printers, drop shippers, parcel delivery services, marketplace facilitators, payment processors, collections processors, human resources service providers, staffing agencies, consumer reporting agencies, insurance carriers and brokers, consultants and professional advisers;

our joint marketing partners; and

third-party marketers (who may combine your personal information with their own records, and records available from other sources), for their own direct marketing purposes, and the direct marketing purposes of other third-party marketers.

CONSUMER RIGHTS

How to Exercise Consumer Rights

You may request (a) to know what personal information we collect and the purposes for such collection and processing, (b) that we delete the personal information collected about you, (c) to obtain a copy of the personal information you provided to us to the extent feasible, or (d) to opt out of the sale of personal information or targeted advertising. You may submit such requests by clicking on the request link here and using the Web form for that purpose or by calling (800) 228-1679. We may request verification of consumer requests as described in this Privacy Policy Addendum.

We will respond to consumer requests within 45 days of receipt of the request when submitted in accordance with the methods described in this Privacy Policy Addendum. The response period may be extended once by 45 additional days if necessary, taking into account the complexity and number of requests, but in that case we will inform you of any such extension within the initial 45 day response period, together with the reason for the extension. If we decline to take action on a request, we will inform you of the reasons for declining to take action and instructions on how to appeal the decision. 

You may appeal a decision we make to decline to take action on a request by clicking on the request link here and using the Web form for that purpose or by calling (800) 228-1679. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny the appeal, we will also provide you with an online mechanism or other method through which you may contact your Attorney General to submit a complaint.

Right to Know About Personal Information Collected, Disclosed or Sold

Consumers have the right to request that a business disclose whether it collects or uses personal information and what personal information it collects, uses, discloses and sells. You may submit a request to know (i) the specific pieces information we collect about you, (ii) the categories of personal information we collected about you, (iii) the categories of sources from which we collected the personal information, (iv) the business or commercial purposes for which we collected or sold the personal information, (v) the categories of third parties with whom we sold or disclosed personal information, and (vi)

the categories of personal information about you that we sold or disclosed for a business or commercial purpose by clicking on the request link here and using the web form for that purpose or by calling (800) 228-1679.

For security purposes we will verify your identity prior to providing any personal information about you or the personal information we collected, disclosed, or sold using a variety of methods including, but not limited to, by sending you an email to confirm your request and asking you for additional information such as your last order amount, customer number or other identifying information appropriate for verification.

Right to Request Deletion of Personal Information

Consumers have the right to request (not more than twice in any 12-month period) that their personal information collected or maintained by a business be deleted. You may submit a request for us to delete personal information we have collected or maintain about you by clicking on the request link here and using the web form for that purpose or by calling (800) 228-1679.

For security purposes we will confirm your request and verify your identity prior to deleting any personal information about you using a variety of methods including, but not limited to, by sending you an email to confirm your request and asking you for additional information such as your last order amount, customer number or other identifying information appropriate for verification.

However, notwithstanding a verifiable request for deletion, we may retain certain personal information necessary for us to complete a transaction, provide a product or service, perform a contract, detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity or prosecute those responsible, debug to identify and repair errors that impair functionality, enable solely internal uses, and to comply with legal obligations, record retention and back-up practices, or for other lawful purposes.

Right to Correct Inaccuracies of Personal Information

Consumers have the right to request that we correct inaccuracies in their personal information, taking into account the nature of the personal information and the purposes of processing the personal information. You may submit a request for us to correct inaccuracies in the personal information we maintain about you by clicking on the request link here and using the web form for that purpose or by calling (800) 228-1679.

For security purposes we will confirm your request and verify your identity prior to changing any personal information about you using a variety of methods including, but not limited to, by sending you an email to confirm your request and asking you for additional information such as your last order amount, customer number or other identifying information appropriate for verification.

However, notwithstanding a verifiable request to correct inaccuracies, we may retain certain personal information in a form necessary for us to complete a transaction, provide a product or service, perform a contract, detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity or prosecute those responsible, debug to identify and repair errors that impair functionality, enable solely internal uses, or for other lawful purposes or we may simply delete the personal information.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

Businesses cannot discriminate against consumers if they exercise any of the rights provided in the CCPA. This means that businesses cannot deny goods or services to that consumer, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, provide a different level or quality of goods or services to the consumer, or suggest that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services. However, a business is permitted to charge a consumer a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to the business by the individual’s data.

We will not deny, charge different prices for, or provide a different level or quality of goods or services if you choose to exercise these rights or live in . 

Right to Opt Out of Targeted Advertising

"Targeted advertising" means displaying advertisements to a consumer where the advertisement is selected based on personal information obtained from that consumer's activities over time and across nonaffiliated websites to predict such consumer's preferences or interests. Targeted advertising does not include (a) advertisements based on activities within our or our affiliates’ websites, (b) advertisements based on the context of a consumer's current search query or visit to our websites, (c) advertisements directed to a consumer in response to the consumer's request for information or feedback, or (d) processing personal information solely for analysis of advertising performance.

Consumers have the right to opt out of targeted advertising and may do so by clicking on the targeted advertising opt out link here and using the web form for that purpose or by calling (800) 228-1679.

Right to Opt Out of Processing of Sensitive Personal Information

We may process sensitive personal information such as information revealing a consumer’s racial or ethnic origin, religious beliefs, sexual orientation or philosophical beliefs. We will not process sensitive data concerning a consumer without obtaining the consumer's consent.

Financial Incentives

We may provide consumers a financial incentive to obtain free shipping, discounts off the price of an order and other incentives for signing up to receive marketing emails and/or text messages. In doing so we collect email addresses and telephone numbers, respectively. Consumers may opt out at any time at no cost or penalty. We provide those incentives in order to be able to send offers by email and/or text message and the value of the consumer’s data is reasonably related to the incentives. The cost of sending an email or text message is nominal.

Retention of Personal Information

We retain personal information we collect about you as long as reasonably necessary for the purposes for which it was collected. For example, we will use personal information to complete transactions, collect accounts payable, conduct marketing and modeling or for historical analysis of business and industry trends. We may retain personal information for longer periods of time for legal, tax, accounting, or security purposes.

Authorized Agents

You may use an authorized agent to submit a request to know, delete, or opt-out on your behalf, subject to verification of the authenticity of the request.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission, (2) that you verify your identity directly with us, and (3) you directly confirm to us that you provided the authorized agent permission to submit the request. These requirements do not apply if you have provided the authorized agent with a lawful power of attorney.

If you use an authorized agent to submit a request to opt-out of the sale of personal information, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

Other Consumer Privacy Rights

You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. See the “How To Contact Us” section for information regarding how to make such a request.

How to Contact Us

To submit a request, or to contact us with questions or concerns about this Privacy Policy Addendum you may contact us using the request link here and using the web form for that purpose or by calling (800) 228-1679. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. 

Privacy Policy Addendum Update

This Privacy Policy Addendum was last updated effective as of January 1, 2023.