When you make a purchase in one of our online stores homeandtower.com or thefamilygadget.com or our mobile apps (collectively, “Websites”) or otherwise, create an account, join our Gift Registry, participate in a sweepstakes or contest or any other promotion, post a product review, engage with us on our social media platforms, apply for our credit card, participate in one of our surveys, send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, you provide us with personal information, such as: your name, email address, mailing address, ZIP code, phone number and credit card numbers. This allows us to provide you with our online and in-store retail and design services, process your transactions more efficiently, offer you promotions, contests and other opportunities and, ultimately, give you a higher caliber of customer service (together the “Services”). If you choose not to provide the requested information we may not be able to provide you with the Services, or certain features of the Services may not be functional.
When you visit our Websites, we or our third-party service providers collect information about your use of the Websites: your Internet service provider's address, your location as determined by your Internet Protocol (“IP”) address, the name of the website or advertisement directing you, your user agent, as well as your clicks and activity on our Websites. We use this information to understand how to make our Websites more available and user-friendly to our customers, as well as to provide you with advertising that may be of interest to you.
We use tools called “Google Analytics” and “Adobe Analytics” to collect some information we listed above in the section called, “Usage and Website Activity Information” about your use of the Services. We use the information we get from Google Analytics and Adobe Analytics to improve the services. In order to collect this information, Google Analytics and Adobe Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics and Adobe Analytics may also receive information about you from apps you have downloaded, that partner with Google or Adobe, respectively. We do not combine the information collected through the use of Google Analytics or Adobe Analytics with personally identifiable information.
The Google Analytics and Adobe Analytics products we use collect only anonymized IP addresses for IP’s located in the EU.
We engage with customers on various social media platforms like Facebook, Twitter, Pinterest and Instagram. If you contact us on one of these platforms for customer service or otherwise, we may contact you via direct message. Those communications are governed by this policy as well as the policy of the relevant social media platform.Cookies and Other Tracking Technologies
Web cookies are used in some email messages and on our Websites to help us measure the effectiveness of those emails and for other analytical purposes.
We use the information we collect about you to facilitate your purchases, to communicate with you, to offer better customer service, and to improve our services and customer relations.
To facilitate your purchases: This includes processing your order and payment, shipping the order (including orders initiated through our International Quote Form), providing you with technical support and assistance, and communicating with you about the purchase by email. For example, we will contact you by phone, postal mail, or email to update you of the arrival of the package, to address any issues with the order, or to answer any questions you may have about your order. If you are located in the EU, we will contact you using the contact information you provide (e.g. email, phone, mailing address). The legal basis for this processing of your information is the performance of our contract with you.
To send you promotional communications: If you sign up, we will contact you by email or send you our catalogs to inform you about products, services, and promotions that we think will be of interest to you. You can opt out of email communications at any time by clicking the "unsubscribe" link at the bottom of each email.
To improve our services and customer relations: We use your information for analytics and measurement to understand how our services are used in order to make improvements to our Websites or user interface through understanding how you interact with them, including how you interact with advertising. The analytics and advertising products that we use collect anonymized IP addresses from EU locations. We use information you provide to us through your purchases, feedback, surveys, and suggestions to enable us to provide you with a more personalized shopping experience and also to improve our services and customer relations.
Online Advertising: We contract with companies that offer advertising services to place our banner advertising on other websites. These companies collect information from us about your visits to our Websites and stores, and your interaction with our products and services. They also use this information to tailor banner advertisements for goods and services when you visit certain websites. We may track this information across the different devices you use to access the Websites. These companies are required to keep this data anonymous and not to share any personal information with any other third parties, except as required to provide this service. These companies do not collect EU IP addresses for the purpose of advertising and we do not place banner advertising on other websites for customers identified as being from EU locations.
Sharing among our entities: We share and combine information about you among our brands, such as Home And Tower and The Family Gadget, in order to provide greater security and to provide information about products and services that might interest you. We also share your information with our parent company, subsidiaries, joint ventures, or other companies under common control as necessary for specific purposes in the operation of our business. The legal basis for this processing is our legitimate interest in the security and efficient operation of our services.
We share and combine information about our US-based customers of products and services that may interest them.
Sharing with vendors: In order to serve you better, we may, at times, contract with other companies to help us process information and to provide us with other services. Their assistance can help us fulfill customer orders, manage, store, and enhance customer data, send marketing, run promotions, and provide other services. For instance, when you order a large furniture item, we may send your name, address, email address and phone number to our shipping vendor, allowing you to access their online delivery scheduling system. Our shipping service providers use your information strictly to coordinate and complete your shipment. The legal basis for this sharing of your information is our legitimate interest in providing our services efficiently.
In connection with a business reorganization: We would share your information if we are involved in a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation. The legal basis for this sharing is our legitimate interest in carrying out our business operations.
In order to comply with our legal obligations, protect our rights and those of others: We share your information in order to prevent fraud or abuse to our services, to protect your rights, to comply with our legal obligations, and to protect our rights. The legal basis for this sharing is compliance with the law and our legitimate interest in the prevention of fraud, compliance with legal obligation and the protection of the rights of others.
When relying on legitimate interest as our legal basis we implement appropriate safeguards including as described in information sharing choices, your rights under EU data protection laws and information security
The services do not support Do Not Track at this time. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit donottrack.us.
Marketing: If you do not want us to share your personal information for marketing purposes, please contact us and we will remove your name from lists we share with other companies. When contacting us, please clearly state your request, including your name, mailing address, email address, and phone number. After we process your request, your personal information will no longer be shared for marketing purposes. Opting out of sharing your information for marketing purposes will not prevent your relevant information from being provided to our service providers as needed to provide Services to you, such as shippers when you order products for delivery. Similarly, this will not prevent us from sharing information to the extent it is de-identified or aggregated (in a non-personally identified manner).
Online advertising: To opt out of interest based advertising or to learn more about the use of this information by our Service Providers you can visit the Network Advertising Initiative or the Digital Advertising Alliance. If you choose to opt out, we will place an "opt-out cookie" on your computer. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for some cookies that are important to how our websites and mobile apps work ("essential cookies"). If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return to the links above to re-select your preferences.
Email promotional communications: You can delet your name and your email address from our email contact lists whenever you want. Please note that, to provide you with more control of your experience with us, opting out of one brand does not automatically opt you out of our other brands.
Website Analytics: You can opt out of our Website analysis tool by clicking here.
Cookies generally: If you would like to opt out of accepting cookies altogether, you can generally set your browser to not accept cookies or to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. However, certain features of our Websites or other Services may not work if you delete or disable cookies.
If EU data protection laws apply to our processing of your information, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below.
You can access or delete your information by sending us an email at email@example.com. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.
In the event that we refuse a request under rights of access, we will provide the requesting individual with a reason as to why. Individuals in the EU have the right to complain as outlined in Dispute Resolution Section.
A list of your rights is below:
You can request that we delete your personal information by contacting us at firstname.lastname@example.org. For details about your rights to deletion under California law, please see the below section titled, Notice to California Residents/Your California Privacy Rights.
We retain your information after you request such deletion for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. See below for specific reasons we would retain some data for longer periods of time:
California law requires certain businesses to disclose information regarding the rights of California residents pursuant to the California Consumer Privacy Act (the “CCPA”). The CCPA applies only to California residents. However, because privacy and transparency are top priorities for us, we are making the rights described in this section available to all U.S. customers. We reserve the right to update this policy at any time as to non-California residents. Any terms defined in the CCPA (Cal. Civ. Code 1798.140) have the same meaning when used in this section. If you choose to make a privacy-related request using the processes described in this section, you will be directed to a platform operated by our privacy management partner, OneTrust.
You have the right to request that we disclose what personal information we collect, use, disclose, and sell. You can submit a verifiable request to know either the categories of information or specific pieces of information that we have about you by submitting contacting us at email@example.com. You will be asked to enter your email address, zip code, and phone number. If we have a matching email address on file, we will send a link, which you will have to click to begin the identity verification process. We will then compare your zip code and phone number against our records. If we cannot verify your identity, you will receive an email explaining that your identity could not be verified and directing you to a customer service representative.
You may use an authorized agent to submit a right to know request. To use an authorized agent, you must provide the agent with written authorization. In addition, you may be required to verify your own identity with us. We may deny a request from an agent if the agent does not submit proof that they have been authorized by you on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.
In the preceding 12 months, we have collected the following categories of personal information about California residents from the following sources and for the following purposes. The CCPA requires that we reference specific categories of personal information enumerated in the CCPA. We may collect only certain pieces of personal information described in a given category and may not collect certain other pieces of personal information described in each category.
Categories of Sources of Information
Business or Commercial Purpose for Collection
Categories of Third Parties with Whom We Share
We collect identifier information from customers directly and from data resellers.
The purposes of collecting this kind of information include order management and fulfillment, customer service, marketing, customer acquisition, and loss prevention.
We share identifier information with order fulfillment partners, such as supply chain and delivery companies, and marketing CRM vendors, data analytics providers, social networks, and fraud detection services. We also share with our affiliate brands and with an industry data consortium.
Categories of personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80.
We collect information described in subdivision (e) of Cal. Civ. Code Section 1798.80 from California residents directly and from data resellers.
The purposes of collecting this kind of information include order management and fulfillment, customer service, marketing, customer acquisition, and loss prevention.
We share identifier information with order fulfillment partners, such as supply chain and delivery companies, and marketing CRM vendors, data analytics providers, social networks, and fraud detection services. We also share with our affiliate brands and with an industry data consortium. We share financial information with order processing partners and, in the case of credit card applications, our credit card service provider, Synchrony.
Audio, electronic, visual, thermal, olfactory, or similar information
We collect audio and video recordings from customers directly. We do not store recordings in a way that connects them to particular customer.
We collect audio recordings when customers call our customer service hotline for quality assurance purposes. We collect video recordings in stores for security and loss prevention purposes.
We utilize service providers to make and store audio and visual recordings.
We collect commercial information from customers directly via their transactions.
The purposes of collecting commercial information include to fulfill orders, and for customer service, marketing, and demand planning.
We share commercial information with order fulfillment partners and our affiliate brands.
Internet or other electronic network activity information
We collect customers’ interactions with our Websites from customers directly and certain service providers.
The purposes of collecting internet activity include marketing and customer service. We also use this information to improve our Websites and the customer experience.
We share internet activity with ecommerce data analytics providers.
Characteristics of protected classifications under California or federal law
We collect demographic information from customers directly and from data resellers.
The purposes of collecting this information include marketing analysis.
We share demographic information with affiliate brands and with data analytics providers.
We have sold or disclosed some personal information about California residents to service providers or other third parties for a business or commercial purpose in the preceding 12 months.
The categories of personal information that we have disclosed about California residents for a business purpose in the preceding 12 months are: identifiers, categories of personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80, audio, electronic, visual, thermal, olfactory, or similar information, commercial information, and internet or other electronic network activity information.
The categories of personal information that we have sold about California residents in the preceding 12 months, as the term “sale” is defined in the CCPA, are: identifiers, categories of personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80, commercial information, and characteristics of protected classifications under California or federal law.
We do not knowingly maintain or sell the personal information of minors under 16 years of age without affirmative authorization.
If we receive an access request pertaining to household information, we may request further verification, as permitted by law, and may provide information in an aggregated format.
You have the right to request the deletion of your personal information that we collect or maintain. You can submit a request to delete by contacting us at firstname.lastname@example.org You will be asked to enter your email address, zip code, and phone number. You will be asked to confirm that you do, in fact, wish to proceed with deletion, considering that fulfillment of this request will mean that Home And Tower and you will no longer have access to order history, gift registries, or any related services at Home And Tower Life and The Family Gadget . Once you confirm, if we have a matching email address on file, we will send a link, which you will have to click to begin the identity verification process. We will then compare your zip code and phone number against our records. If we cannot verify your identity, you will receive an email explaining that your identity could not be verified and directing you to a customer service representative.
You may use an authorized agent to submit a deletion request. To use an authorized agent, you must provide the agent with written authorization. In addition, you may be required to verify your own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.
If we reject the request to delete, you will receive an email detailing the reasoning for denying the request. We may deny a delete request if your information is necessary to:
Complete a transaction, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you;
Perform a contract with you;
Comply with federal, state, or local laws, including tax exempt transaction and sales tax audit obligations, defend legal claims, including pending chargeback disputes, or other legal obligations;
Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality; or
Use internally in a lawful manner that is compatible with the context in which you provided the information.
You have a right to opt-out of the sale of your personal information. While we do not sell customer data in exchange for monetary compensation, we do share information in certain circumstances for valuable consideration. For example, Home And Tower Life LLC and The Family Gadget LLC sometimes share customer information with each other for marketing purposes. We also sometimes share with a third party that serves as an industry data consortium.
To exercise your right to opt out of sale, please contact us at email@example.com.
If we have a good-faith, reasonable, and documented belief that a request to opt-out of sale is fraudulent, we may deny the request. In this instance, we will inform the requesting party that we will not comply with the request and will provide an explanation for why we believe the request is fraudulent.
You may use an authorized agent to submit a request to opt-out on your behalf. You must provide the agent with written authorization to do so. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
You have a right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including, but not limited to, by:
(1) Denying goods or services to you;
(2) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
(3) Providing a different level or quality of goods or services to you;
(4) Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may charge you 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 us by your data. In addition, we may offer financial incentives, including payments to you as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information. We may also offer a different price, rate, level, or quality of goods or services to you if that price or difference is directly related to the value provided to us by your data. We will notify you of such financial incentives. We will enter you into a financial incentive program only if you give us prior opt in consent which clearly describes the material terms of the financial incentive program, and which may be revoked by you at any time. We will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
In some instances, we may offer a discount or an opportunity to win something of value in exchange for the collection of your personal information. For example, we may offer a discount promotional code or coupon if you provide us with your cell phone number, email address or mailing address for marketing communications; an opportunity to win a prize if you provide your email address as part of a sweepstakes entry; and rewards dollars to customers who use our private label credit cards. The details of each program are contained in the program offering.
Under the CCPA, these offerings may be considered financial incentives, and they are reasonably related to the value of the information you provide. The precise value of the data will vary depending on certain factors, including the internal resources required to collect and maintain information. The category of personal information implicated by financial incentives are identifiers, and more specifically, contact information. In the case of our private label credit cards, we also collect financial information, such as your income, in order to process your application, but we do not use that information for marketing purposes. Details regarding the credit card application process are available here.
You can withdraw from financial incentives at any time by opting out of marketing communications, replying “STOP” to text messages, cancelling your credit card account, and/or directing us to delete your personal information, as described in this policy. If a discount code or sweepstakes prize has already been obtained, you will have no obligation to return or destroy the discount code or prize upon opting out. If you cancel your credit card account, you will no longer have access to accrued reward dollars. Other credit card terms and restrictions apply.
If you have questions or concerns about our privacy policies and practices, please contact us at firstname.lastname@example.org
Under Nevada privacy law, Nevada residents have a right to submit a verified request directing certain operators of Internet websites and online services not to sell their personal information, as “sell” is defined in Nevada law. We do not sell personal information of Nevada residents. If you have any questions regarding our data privacy practices, please contact email@example.com
We adhere to a strict privacy code regarding children and do not knowingly collect or accept personal information from any child under the age of 16. If it is brought to our attention that we have unknowingly received personal information from a child under 16, we will immediately remove all of that child’s personal and identifiable information from our records. In addition, we will not disclose this information to any other companies. California users under the age of 18 may request the removal of their content or information publicly posted on the Website by e-mailing us at the appropriate brand’s customer service email address identified below.
Please be aware that whenever you share information on a publicly available area of our Websites, such as in a product review, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.
We take our customers’ personal information seriously and take steps to protect our customers' personal information against loss, misuse, alteration and unauthorized access. We use encryption technology whenever receiving and transferring your payment information on our Websites.
You are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer. You are responsible for all activities that occur under your account or password. As a result, it is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a computer that others may have access to.
We are committed to resolve complaints about your privacy and our collection or use of your personal information. Please direct your inquiries or complaints to firstname.lastname@example.org
Notwithstanding the below, if you reside in the EU, in the event your concerns in connection with how we process your information are not addressed you can file a complaint with the data protection supervisory authority in the country of your residence.
If you demonstrate that the costs of arbitration will be prohibitive as compared to the costs of litigation, we will pay as much of the administrative costs and arbitrator's fees required for the arbitration as the arbitrator deems necessary to prevent the cost of the arbitration from being prohibitive. In the final award, the arbitrator may apportion the costs of arbitration and the compensation of the arbitrator among the parties in such amounts as the arbitrator deems appropriate.
Neither you nor we may act as a class representative or private attorney general, nor participate as a member of a class of claimants, with respect to any Claim. Claims may not be arbitrated on a class or representative basis. The arbitrator can decide only your and/or our individual Claims. The arbitrator may not consolidate or join the claims of other persons or parties who may be similarly situated.
THIS SECTION LIMITS CERTAIN RIGHTS, INCLUDING THE RIGHT TO MAINTAIN A COURT ACTION, THE RIGHT TO A JURY TRIAL, THE RIGHT TO PARTICIPATE IN ANY FORM OF CLASS OR REPRESENTATIVE CLAIM, THE RIGHT TO ENGAGE IN DISCOVERY EXCEPT AS PROVIDED IN AAA RULES, AND THE RIGHT TO CERTAIN REMEDIES AND FORMS OF RELIEF. OTHER RIGHTS THAT YOU OR WE WOULD HAVE IN COURT ALSO MAY NOT BE AVAILABLE IN ARBITRATION.