Privacy Policy

1. Categories of Personal Information We Collect

We may collect the following categories of Personal Information, which is 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 (“Personal Information”):

1. Identifiers: Identifiers such as: a real name, alias, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, account name, physical address, month, day and year of your birth.
   
   B. Customer Records: Any of the following types of information: credit card number, debit card number, signature, and telephone number.
   
   C. Commercial Information: Commercial information, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
   
   D. Biometric Information: Biometric information such as: Keystrokes.
   
   E. Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
   
   F. Geolocation Data: Geolocation data.
   
   G. Employment Information: Professional or employment-related information, including information you provide when you apply for a job.
   
   H. Inferences: Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

This Policy does not apply to any data that is publicly available.

2. Categories of Sources

We may collect all categories of Personal Information listed above from the following categories of sources:

SOURCE 1: We Collect Personal Information Directly From You.

We collect Personal Information that you provide directly to us. You may need to provide Personal Information to use certain Site features, for example, to create online accounts, purchase products or services, contact us via email, phone, Live Chat or our Contact Us form (where we may retain your message’s content and our response), submit job application materials, receive or request data from us (e.g., catalogs and newsletters), and respond to communications from us (e.g., surveys and promotional offers).

Company Accounts. To create an online account, you must submit your name and email address, and create a password This data is used to populate a profile within your account.

Order & Payment Data. To make purchases through the Site, you must submit your name, credit or debit card type, number, expiration date, security code, and billing address. All credit and debit card data is provided directly to our PCI-compliant third-party payment processor. We do not directly access, handle, or store your credit or debit card data. We will keep a record of your purchases. We store your payment card’s last four digits to facilitate future orders. We collect tax identification numbers you submit for tax-exempt purposes. Although we do not collect your financial information, we may collect related Personal Information, such as your name and contact information, to facilitate the sale. Payment by credit or debit card is subject to the approval of the card issuer. We will not be liable in any way if a card issuer refuses to accept a credit or debit card for any reason. If you make a purchase using PayPal, you may need to log in to your PayPal account. PayPal may use Personal Information as described in its Privacy Policy. If you make a purchase using Amazon Payments, you may need to log in to your Amazon account. Amazon may use Personal Information as described in the Amazon Payments Privacy Notice. To request an institutional account you will be required to submit a credit application and additional terms may apply.

Marketing Communications; Opt-Out. If you opt-in to receive marketing communications from us, we will collect your name, email, mailing address, and phone number. We use this information to send you promotional and other electronic and hardcopy communications. We may use third-party providers to deliver communications to you. You may opt-out of such emails by using the unsubscribe link in the email or contacting us at info@coldwaacademy.com with “Unsubscribe” in the subject line. To opt-out of other communications (e.g., postal marketing and telemarketing), please contact us as set forth below. Opting out of marketing communications does not opt you out of communications about your account or transactions.

User- Generated Material – Feedback. You are responsible for any comments, data, images, text, photos, artwork, audio, videos, and other content and material that you create, post, upload, transmit, display, publish, distribute, broadcast, or otherwise submit using the Site (together, “User-Generated Material”). User-Generated Material that you submit is posted on the Site at your own risk. With regard to User-Generated Material consisting of CWA comments or feedback about our Site, the content on the Site, or our products or services (“Feedback“), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.

For example, if in providing a product review you elect to include your name, we may excerpt those reviews in our advertising and marketing materials and may include your name with any such excerpts. We cannot guarantee that submitted User-Generated Material will not be viewed by unauthorized persons. You understand that, even after removal, copies of User-Generated Material you have submitted may remain viewable in cached and archived pages and may have been copied or stored by other users.

Sweepstakes & Contests. We may offer sweepstakes or contests. To participate you must submit certain data, which may include your name, email, organization name and type, phone number, physical address, other Personal Information and content such as artwork and other content We use information we collect from sweepstakes and contests (i) to contact you with promotional and related communications, (ii) to share with third-party service providers to assist in the sweepstakes or contests, and (iii) subject to additional terms provided to you at such time.

Cookies & Other Tracking Technologies. We use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) when you use our Site. What are cookies and web beacons / pixel tags? A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

Why do we collect Cookies? We use Cookies to:

• make our Site function properly;
• provide personalized experiences;
• tailor our interactions with you;
• help with our marketing efforts;
• provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and
• help us improve our services.

What type of information do Cookies collect? The Cookies on our Site may collect information such as:

• IP addresses assigned to the computers and other devices you use;
• your internet service provider;
• device ID number;
• approximate geographic location;
• browser type;
• Site pages visited;
• websites you access before and after visiting the Site, and
• data related to how and when you use the Site.

We may combine information from Cookies with Personal Information, including data obtained from third parties.

How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

Flash cookies differ from other browser cookies regarding the amount and types of data collected and how the data is stored. Your browser will not remove and cannot manage Flash cookies in the same way as other Cookies. To learn about managing your Flash cookie settings, visit the Flash player settings page on Adobe’s website here.

We are not responsible for third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over third-party Cookies. Third-party Cookies are not governed by this Policy.

How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.

Analytics. The Services use third-party analytics tools (e.g., Google Analytics, Hotjar, and New Relic) to collect and process data about your use of the Services, including when you visit the Services, URLs of the websites that you visit prior to visiting the Services and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content. For more information on how Google uses this data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics opt-out browser add-on will not prevent Company from using other analytics tools and will not prevent data from being sent to the Services itself or to Google. You may opt out to Hotjar’s creation of a user profile, Hotjar’s storing of data about your usage of the Services, and Hotjar’s use of tracking cookies on other websites by opting out here. You may disable cookies as discussed above, but that may impact your use and enjoyment of the Services.

Google Analytics’ Advertising Features. Additionally, we have enabled and implemented the following Google Analytics Advertising Features: Remarketing with Google Analytics, Demographics and Interest Reporting, Segments, DoubleClick Campaign Manager Integration, and DoubleClick Bid Manager Integration. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Services. Demographics and Interest Reporting uses a third-party cookie to collect information about our Services traffic by tracking users across websites and across time, which generates a report for us to better understand our Services users. Segments allows us to isolate and analyze subsets of Services users by sorting our Google Analytics data. DoubleClick Campaign Manager Integration and DoubleClick Bid Manager Integration allow us to view, analyze, and create remarketing lists using our DoubleClick Campaign data. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Services.

Google AdWords. We also use Google AdWords, an online advertising service provided by Google, to serve ads on our behalf across the Internet and sometimes on the Services. Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect anonymous information about your visits to the Services and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Services.

Advertising Networks, Personalized Advertising, Remarketing, and Retargeting. From time to time the Services may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms. These services collect anonymous information about your visits to and interactions with the Services and other websites and will use that information to target advertisements for goods and services. The information collected may be associated with your personal information. These targeted advertisements may appear on the Services or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of Internet browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Services and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.

Google Maps. In addition to the approximate geographic location information collected as discussed above, we may, with your consent, access more specific location information in order to enhance the user experience and increase the usefulness of the Services. This includes both geographical location information that you input using the Services (e.g., using our Find a Store feature) and geographical location information collected by device-based location services (including GPS data). You may choose to allow us to access your location by granting the Services access to your location when prompted or through your device’s location services settings.

SOURCE 2: We Collect Personal Information From Third-Party Sources.

We obtain data about individuals from various third-party companies and public sources and we may combine that data with Personal Information or other data we collect. This enhances our existing data about our users (e.g., adding address data), improves our ability to contact you, and enhances our marketing capabilities.

3. Purpose for Collecting Personal Information

We may use all categories of Personal Information listed above for the following business purposes:

As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to process and communicate with you in connection with your purchases and account and to provide you with information and communications that you request. Your location information will be used to identify CWA locations near you and to understand where our users are located. If you provide us with your telephone number in connection with your account, we may call you at that telephone number regarding your purchases and account. We will make User-Generated Material available to other users of the Services as applicable. For example, if you submit materials while entering an online CWA contest or if you submit product reviews, other users of the Services will be able to view, copy, and use that content. If you contact us for support or assistance in using the Services, we may use Personal Information to determine whether or not your system meets the minimum requirements needed to access and use the Services and otherwise to contact you regarding your request. We may also use Personal Information as requested or consented to by you.

Communication with You. We may use Personal Information to notify you of changes made to the Services (for example, changes to our Terms of Use and this Privacy Policy), market products and services to you, and to send you promotional materials and other communications as described above. CWA maintains a list of current and potential customers. If you order from us, or if you request a catalog, then we will send you a new catalog from time to time.

Sharing Collected Information with Our Service Providers. We may share Personal Information with our management and hosting suppliers, payment processors, marketing and public relations service providers, email service suppliers, and other suppliers as necessary for us to provide the Services and our products and services to you and as may otherwise be permitted by applicable law. Our suppliers are authorized to and may use and disclose Personal Information as necessary for them to provide the applicable services to us.

Aggregate Data. We may aggregate Personal Information and to create anonymous aggregate data on users of our Site, which describes users as a group but does not reveal the identity of individual users. We may use aggregate data to understand users’ needs, to determine user demographics and usage patterns, to determine what kinds of products and services we can provide, and to improve and enrich our products and services and the Sites.

Evaluation and Improvement of the Site. We may use Personal Information: to analyze, develop, and improve the content, materials, products, and services that we make available through the Site and the Sites’ functionality; to inform marketing and communication plans and strategies; to evaluate user needs and customize content, promotional emails, and your browsing experience; and for other legitimate and lawful business purposes.

Administration. We use Personal Information for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, to understand the Site’s demographics and user preferences, for evaluating applications, and managing profiles.

Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.

Advertising. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Site, to notify you of changes to our Terms or this Policy, and for other similar communications.

To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to address any DMCA claims or counterclaims to seek business, financial or legal advice, and to respond to other legal requests.