Privacy Policy - Additional California Privacy Disclosures

Last Updated: June 1, 2022

SCOPE OF DISCLOSURES

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Policy and apply solely to individual residents of the State of California (“consumers” or “you”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.

PERSONAL INFORMATION DISCLOSURES

When we use the term “personal information” in these CA Disclosures, we 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 consumer or household.

For the purposes of these CA Disclosures, personal information does not include:

  • Publicly available information from government records.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information excluded from the CCPA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
  • Information relating to our job applicants, employees, contractors and other personnel, which is not governed by these Disclosures.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect various categories of Personal Information in connection with our services. Please review the Our Collection of Personal Information section of the Privacy Policy to learn more about the personal information we collect. In the last 12 months, we have collected the following categories of personal information from the following sources of personal information.

In addition to the specific categories of sources identified above, the following “Common Sources” apply to all categories of personal information we collect: directly from you; indirectly from you; our business partners and affiliates; and/or third parties you direct to share information with us.

CATEGORY OF PERSONAL INFORMATION AND SOURCES

  • Identifiers (e.g., Name, Phone Number, Email Address, I.P. Address)
  • Social Network Services
  • Ben Bridge Owned & Operated Stores, including certain Pandora franchise stores
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your birthdate, name, credit card number or other payment account number (including the three (3) or four (4) digit validation code for your credit card).
  • Social Network Services
  • Ben Bridge Owned & Operated Stores, including certain Pandora franchise stores
  • Protected Classification Characteristics (e.g., age)
  • Social Network Services
  • Ben Bridge Owned & Operated Stores, including certain Pandora franchise stores
  • Customer Account Details / Commercial Information (e.g., your order history, shopping and ordering behavior)
  • Ben Bridge Owned & Operated Stores, including certain Pandora franchise stores
  • Your Brower or Device
  • Internet Usage Information (e.g., information regarding your interaction with our online services)
  • Your Brower or Device
  • Geolocation Data (e.g., if you enable this feature on your device while using our app)
  • Your Brower or Device
  • Sensory Data (e.g., recordings of customer service calls, store security camera footage)
  • Ben Bridge Owned & Operated Stores, including certain Pandora franchise stores
  • Profession/Employment Information, such as job history, qualifications, experience (for job applicants only)
  • For job applicants, from third parties you direct to share information with us
  • Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99), such as educational history, degree (for job applicants only)
  • For job applicants, from third parties you direct to share information with us
  • Other Personal Information, such as information you post on our platform or on social media pages, including pictures or videos of you, or other information you submit to us, including your wedding or anniversary date and personal information of your family/friends.
  • Social Network Services
  • Third parties you direct to share information from us
  • Your Browser or Device
  • Inferences from PI Collected (e.g., your preferences, your likelihood of interest in certain of our services)
  • Analytic Services
  • Your Brower or Device
  • Information Generated or Derived From Your Online Browsing and Usage Activity

Please note: In addition to the categories of sources identified above, we may collect information from publicly available sources and other third-party information providers in order to supplement the information we have otherwise collected.

PURPOSE FOR COLLECTING PERSONAL INFORMATION

We collect, use, sell or disclose personal information about you for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, to allow you to place an order in-store or online, have it delivered to you, or to provide you with the information that you request. In addition, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
  • To fulfill your transactions or purchases (e.g., to process credit card payments in connection with your transaction).
  • To communicate with you, including to send you service-related emails or messages and communications from or about Ben Bridge and to send you important information regarding the services, such as certain changes to our terms, conditions, policies, and/or other administrative information.
  • To process your registration on our services, including verifying your information to ensure its accuracy and validity.
  • To operate, maintain, and provide to you the features and functionality of the service.
  • To market to you, including through email or direct mail, and to inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests, and similar promotions (collectively, "Promotions").
  • To evaluate your eligibility for certain types of Promotions, offers, products, or services that may be of interest to you.
  • To personalize your experience (e.g., to locate the Ben Bridge stores closest to your location) and to deliver custom content and product and service offerings relevant to your interests, including but not limited to targeted offers and ads through our website, email, social media channels, third-party sites, or on other devices you may use.
  • To better understand the demographics of our visitors.
  • To recognize you and remember your information when you return to our website and service.
  • To measure traffic and analytics on our services.
  • To help maintain the safety, security, and integrity of our service, technology assets, and business.
  • For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the services, improving our services, identifying usage trends, and determining the effectiveness of our promotional campaigns, including to inform our machine learning for purposes such as user engagement.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ben Bridge’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ben Bridge about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.

DISCLOSURE OF PERSONAL INFORMATION

As described in our Privacy Policy, we share personal information with a variety of third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see The Right to Opt-Out of Personal Information Sales below).

We disclose personal information to the following categories of third parties:

  • Within Ben Bridge-Related Entities. We may share your personal information with other companies owned or controlled by Ben Bridge, and other companies owned by or under common ownership as Ben Bridge, including any subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns;
  • Service providers. We engage a number of third-party service providers that perform business or operational services for us or on our behalf and as needed to provide the services, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, marketing and advertising services, and other similar services, subject to contractual terms restricting the collection, use and disclosure of your personal information for any other commercial purpose.
  • Promotional partners. We may disclose personal information to third parties with whom we partner to provide contests, surveys, joint promotional activities or co-branded or co-sponsored services, and such disclosure is necessary to fulfill your request or application.
  • Ad networks and advertising partners. We work with third-party Ad Networks and Advertising Partners to deliver advertising and personalized content to you on our service, on other sites and services you may use, and across other devices you may use. These parties may collect information directly from your browser or device when you visit the services through cookies or other tracking technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
  • Analytics providers. We work with third-party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our services.
  • Social networks. We may disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks.
  • Third parties at your request. We share your personal information with third parties with your consent or at your direction.
  • Law enforcement and third parties pursuant to legal request. From time to time, we may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Third parties in the context of a corporate transaction. We may disclose personal information as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ben Bridge’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ben Bridge about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.

In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the table above, to third parties for a business purpose.

In the previous 12 months, we have not sold personal information as most people would typically understand that term. However, we do allow certain advertising networks, social media companies and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies and related technologies when you visit or interact with our websites or otherwise engage with us online. Please see the Third-Party Tracking and Online Advertising section below for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.

YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know. You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information we have collected about you;
  • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and,
  • The business or commercial purposes for collecting or, if applicable, selling personal information

The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales. You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

The Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

“Shine the Light.” California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

TO EXERCISE YOUR RIGHT TO KNOW OR RIGHT TO DELETION

To exercise your Right to Know or your Right to Deletion, please submit a request by emailing privacy@benbridge.com with the subject line, “California Rights Request” or by calling 1-888-448-1912. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

TO EXERCISE YOUR RIGHT TO OPT OUT OF PERSONAL INFORMATION SALES

Unless you have exercised your Right to Opt Out of Personal Information Sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we may sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.


As noted above, we do not sell personal information as most people think of that term. You may, however, exercise your right to opt out of any future potential sales by clicking the link below and following the instructions:

DO NOT SELL MY PERSONAL INFORMATION

Enter your information as directed on the form. For “My Question,” select “Other” and in the “Comments” box enter “Do not sell my personal information,” indicating whether you are the consumer the personal information is about or whether you are acting on behalf of the consumer the personal information is about and that you are authorized to act on that consumer’s behalf.

You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. Note: The personal information submitted in connection with this request will be used for the purpose of processing your request. Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@benbridge.com.

THIRD-PARTY TRACKING AND ONLINE ADVERTISING

We utilize third-party partners to engage in online advertising. These ad networks, social media companies and other third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our websites, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services. These third-party businesses use your personal information to serve relevant ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third parties may use such personal information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks. Please see our Cookie Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.

MINORS UNDER AGE 16.

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at privacy@benbridge.com to inform us if you, or your minor child, are under the age of 16.

CALIFORNIA’S ”SHINE THE LIGHT” LAW

At the time of this writing, we do not provide your personal information to third parties for their direct marketing purposes, as described in California's "Shine the Light" law (Civil Code Section §1798.83). To opt-out of having your personal information disclosed to third parties for their direct marketing purposes in the future, please click the Do Not Sell My Info link above. Please note that to opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.

AUTHORIZED AGENT

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

UPDATES TO THESE CA DISCLOSURES

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these CA Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@benbridge.com. Alternatively, inquiries may be addressed to:

Ben Bridge Jeweler, Inc.

Attn: General Counsel

P.O. Box 1908

Seattle, WA 98111