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Privacy Policy

Barolin & Spencer, Inc. Privacy Statement

Effective January 1, 2025

Introduction

This Privacy Statement (“Statement”) describes our practices in connection with personal data that we collect through: 

  • barolin-spencer.com and any other website operated by us from which you are accessing this statement (“Websites”); 
  • The software applications made available by us for use on or through computers and mobile devices (“Apps”);
  • Our social media pages that we control from which you are accessing this Statement (“Social Media Sites”); and 
  • HTML-formatted email messages that we send to you that link to this Statement. 

In this statement, Websites, Apps, and Social Media Sites are collectively called the “Services”.

By providing personal data to us, you agree to this Statement. 

Types of Personal Data We May Collect

When you interact with Barolin & Spencer, Inc. through our Services, we may collect various personal data, such as: 

  • Your first and last name;
  • Your postal address;
  • Your email address; 
  • Your company name;
  • Your country;
  • Your telephone number; 
  • Your Barolin & Spencer, Inc. username and password;
  • Your IP address;
  • Your usage of and activities on our Services; 
  • Your interests;
  • Any biographical info you choose to share and other information related to your online behavior.

We may need to collect and process these types of personal data to provide the requested Services to you or because we are legally required to do so. If you do not provide the information we request, we may not be able to provide you with the requested Services.

If you submit any personal data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so. You permit us to use the data per this Statement.

How We May Collect Personal Data 

We and our service providers may collect personal data in a variety of ways, including:

  • Through the Services: We may collect personal data through the Services, e.g., when you sign up for a newsletter, sign up for marketing activities, contact our support centers, or create an account.
  • From Other Sources: We may receive your personal data from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), and from other third parties. In addition, if you elect to connect your social media account to your Website account, certain personal data from your social media account will be shared with us, which may include personal data that are part of your profile or your friends’ profiles. 

For Which Purposes We Use Your Personal Data

We use your personal data for the following purposes:

  • To respond to your inquiries, complete your transactions, and fulfill your requests, such as sending you newsletters;
  • To send administrative information to you, for example, information regarding the Services, product tests, surveys, and changes to our terms, conditions, and policies;
  • To send you marketing communications that we believe may be of interest to you;
  • To personalize your experience on the Services by presenting products and offers tailored to you;
  • To allow you to participate in sweepstakes, contests, and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain other information about how we use and disclose your personal data. We suggest that you read any such rules carefully; 
  • To facilitate social sharing functionality; and
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities. 

Sharing Your Personal Data with Others

We may share your personal data with: 

  • Barolin & Spencer, Inc. affiliates for the purposes described in this Statement. Barolin & Spencer, Inc. is the party responsible for managing the jointly used personal data.
  • To our third-party service providers who provide services such as website hosting, data analysis, information technology, related infrastructure provision, customer service, email delivery, auditing, and other services.
  • To third parties, to permit them to send you marketing communications consistent with your choices. 
  • To third-party sponsors of sweepstakes, contests, and similar promotions.
  • To identify you to anyone to whom you send messages through the Services.
  • By you, on message boards, chats, profile pages, blogs, and other services to which you can post information and materials (including, without limitation, our Social Media Sites). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when disclosing any information on the Services.
  • To your friends associated with your social media account, to other website users, and your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account. By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your personal data shared with other users or with your social media account provider, please do not connect your social media account with your Services account and do not participate in social sharing on the Services.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  • We also may use and disclose your personal data as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (d) to enforce our terms and conditions; and (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

Other Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as: 

  • Browser and device information
  • App usage data
  • Demographic information and other information provided by you that does not reveal your specific identity, 
  • Information that has been aggregated in a manner that it no longer reveals your specific identity

If we are required to treat Other Information as personal data under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal data as detailed in this Policy.

Collection of Other Information 

We and our service providers may collect other information in a variety of ways, including: 

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly. 
  • IP Address: Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address. 

Uses and Disclosures of Other Information 

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Your Rights

If you would like to review, correct, update, suppress or delete the personal data that you have provided to us, you can contact us via [email protected].

In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal data. For your protection, we may only implement requests concerning the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began before requesting a change or deletion (e.g., when you ordered a reward, you may not be able to change or delete the personal data provided until after the delivery of the reward). There may also be residual information remaining in our databases and other records, which will not be removed. 

Your Choices

We want to know you better so that we can serve you better while at the same time respecting your choices about how we use your personal data.

If you do not want us to send you personalized offers or information, you can let us know by ticking the appropriate box on the registration form or reply card or by exercising the "opt-out" option in emails you receive.

If you would prefer that we not share your personal data on a going-forward basis with our affiliates and unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by contacting us at [email protected].

Where local law requires it, we will ask you to "opt in" or affirmatively consent to the processing of your personal data. For example, where local law so requires, we will only send you newsletters if you have subscribed to them. Similarly, where local law so requires, we will ask you to "opt-in" before using sophisticated profiling techniques.

We will try to comply with your choice as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, which you cannot opt out of.

Social Media

When you participate in various social media forums, like Facebook, X, Pinterest, Instagram, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share personal data in your social media profile(s).

Barolin & Spencer, Inc. is bound by the privacy practices or policies of these third parties, so we encourage you to read the applicable privacy notices, terms of use and related information about how your data is used in these social media environments.

Also, depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the web pages), certain personal data may be shared with Barolin & Spencer, Inc. about your online activities and social media profiles, e.g. interests, marital status, gender, user name, photos, comments and content you have posted/shared, etc.

How We Protect Your Personal Data

We recognize a responsibility to protect the personal data you entrust to Barolin & Spencer, Inc. from loss, misuse, or unauthorized access, and we take this responsibility seriously. Barolin & Spencer, Inc. uses a variety of security technologies and organizational procedures to protect your personal data. For example, we have implemented access controls, used firewalls and secure servers, and we encrypt certain types of data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please notify us immediately at [email protected].

Special Information for Parents

The Services are not directed to minors under the age of sixteen, and we request that they not provide personal data through the Services.

Data Transfers

The Services are controlled and operated by us from the United States of America and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States of America. 

Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of your personal data to countries outside of your country of residence that may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal data.

Retention Period

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Statement unless a longer retention period is required or permitted by law. 

Sensitive Data

We ask that you not send us or disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

Changes to This Privacy Notice

The Services that Barolin & Spencer, Inc. provides are always evolving and may change from time to time without prior notice to you. For this reason, we reserve the right to change or add to this Statement accordingly.

We will post a prominent notice on our Websites to notify you of any significant changes to this Statement, and we will indicate at the top of the notice when it was most recently updated. We encourage you to check back often to review the latest version.

The new Statement will be effective upon posting. If you do not agree to the revised notice, you should alter your preferences or consider stopping using our Websites. By continuing to access or make use of our Services after the changes become effective, you agree to be bound by the revised Statement. 

How to Contact Us

If you have any questions about this Statement or our collection, use, or disclosure of your personal data, contact Barolin & Spencer, Inc. at [email protected].