Privacy Policy

BlueTriton Brands, Inc. Privacy Notice and Policy

1.    Scope of this Policy

2.   What Personal Information Do We Collect and How Do We Collect It?

3.   How Do We Use the Personal Information We Collect?

4.   To Whom do We Disclose the Personal Information We Collect?

5.    What Rights and Choices Do You Have Regarding Your Personal Information?

6.    Third-Party Websites and Services

7.    How Do We Protect Your Personal Information?

8.    How Long do We Retain Your Personal Information?

9.    Collection of Personal Information of Children

10.  Changes

11.  Contact Us

1. Scope of this Policy

Please read this privacy notice and policy (“Policy”) carefully to understand our policies and practices regarding your personal information and how we will treat it. This Policy applies to individuals who interact with BlueTriton Brands, Inc. and Our services as consumers or members of the public (“you”). This Policy explains how your personal information (which some jurisdictions may refer to as “personal data”) is collected, used, and disclosed by BlueTriton Brands, Inc., our affiliates and certain parties acting on our behalf (collectively “BlueTriton”, “We”, Us”). It also tells you how you can access and update your personal information, exercise certain rights, and make certain choices about how your personal information is used.

This Policy covers both our online and offline data collection activities, including personal information that We collect through our various channels such as Our websites, telephone contacts and Customer Support, and apps (Our "Services"), as well as third-party social media networks, consumer affairs, certain third-party data sources, points of sale, and events where this policy is provided to you. Please note that We might combine personal information from different sources (website, offline event), including by combining personal information that were originally collected by different BlueTriton entities or BlueTriton partners. We also may combine data from third parties with data We already have.

In some instances, if you do not provide personal information to Us, We may not be able to provide you with certain goods and/or services. We will generally indicate to you when this is the case, for example, by stating so on Our registration forms or not enabling the process to continue without that information.

2. What Personal Information Do We Collect?

"personal information" is generally considered any information that can identify you or that relates specifically to you. The personal information that We collect about you depends on how you interact with Us and Our Services, what requests you make from Us, and the context of our relationship.

Information You Give Us

When you interact with Us or the Services, you may provide certain personal information to Us, including:

  • Identifiers, including certain data defined as personal information under the California Customer Records statute or as a protected classifications under California or federal law. This data includes:

    • Identification and Contact Data. Any data that specifically identifies you or allows us to contact you, such as your first name, middle name or initial, last name, nickname or alias, government-issued ID, postal address, e-mail address, social media network details, or phone number.

    • Account Login Data.Any data that is required to give you access to your specific account profile. Examples include your login ID/email address, screen name, password, and/or security question and answer.

  • Payment and Financial Data.Any data that We need in order to fulfil an order, or that you use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). We may also collect information in connection with your credit application, if any.

  • Demographic Data & Interests.Any data that describes or identifies your demographic or behavioral characteristics, including your date of birth, age or age range, gender, geographic location (e.g., ZIP code), favorite products, hobbies and interests, and household or lifestyle data.

  • Audio, Electronic, Visual and Similar Information. Any content that you create and share with Us on third-party social media networks or one of Our Services. Examples include photos, videos, personal stories, or other similar media or content. We may also record and collect information from you during conversations with Customer Service.

  • Commercial Information. Information relating to your use of the Services, including products or services purchased, obtained or considered and other purchasing or consuming history or tendencies.  

  • Sensitive Personal Information. Certain personal information that you provide might also be considered sensitive personal information under certain laws, including governmental IDs, social security number, account log-in information, health information, financial account information, precise geolocation data, and certain demographic information.

Information Collected Automatically

When you interact with Us or the Services, certain information is automatically collected by the systems We use, including:

  • Data from Your Computer/Mobile Device/Browser.Data about the computer or device that you use to access Our Services, such as the Internet protocol (IP) address, and device and browser type, as well as other online identifiers. If you access Our Services via a mobile device such as a smartphone, the collected data will also include, where permitted, your phone’s unique device ID, advertising ID, and other similar mobile device data.

  • Internet or Other Similar Network Activity. As you navigate through and interact with Our Services or emails, We use automatic data collection technologies to collect certain data about your device(s) and your actions. This includes data such as which links you click on, which pages or content you view and for how long, and other similar data and statistics about your interactions, such as content response times, download errors, and length of visits to certain pages, as well as operating system type and web browser type and version. This data is captured using automated technologies such as cookies and web beacons and is also collected through the use of third-party tracking for analytics and advertising purposes (see "Do Not Track/Opt-Out of Targeted Advertising").

  • Audio, Electronic, Visual and Similar Information. We may visually record your interactions with Our Services, including your mouse clicks, movement, scrolling, and navigation through Our Services, including through the creation of heat maps.

  • Geolocation Data. Our systems record IP addresses, and that often provides your general location.

Information We Create or Generate

We may use certain personal information we collect to create or generate other information, including:

  • Inferences. We may draw inferences from the data We collect from and about you to create a profile reflecting your preferences, characteristics, and behavior. We use this data for personalization and other general business purposes, such as internal or market research, developing  models for prospective customers, analytics, and security.

Information Obtained from Third Parties

We get personal information about you from other sources, including our affiliates and business partners. We may obtain data from companies who compile information about shoppers and their preferences, and we may also get information from parties who we use for financial transaction, verification and fraud prevention. Social media platforms may also give Us data about you. We may get data about your interactions with our ads on third-party sites.  The information that we obtain from third parties may be in any of the above categories.

3. How Do We Use the Personal Information We Collect?

Provide Goods and Services

We use certain personal information, including Identification, Account, Payment and Financial, Commercial Information, Data From Your Device, Internet Activity and Sensitive Personal Information to provide our goods and services to you, including recording, processing, fulfilling, delivering and shipping your orders; payment processing; and customer service.  We also use your personal information to inform you about the status of your orders, correct addresses and conduct identity verification and other fraud detection activities.  Specific uses of this information include providing the products that you order, providing access to your account, tracking orders and resolving issues, responding to your requests and inquiries, and sending you updates regarding products or services (including changes to this Notice and our other terms).

Personalization

We may use certain personal information, including Identification, Account, Payment and Financial, Demographic Data, Commercial Information, Data From Your Device, Electronic and Similar Information, Internet Activity, Geolocation Data and Inferences  to (i) analyze your preferences and habits, (ii) anticipate your needs based on our analysis of your profile, (iii) improve and personalize your experience with Our Services, (iv) ensure that content from Our Services is optimized for you and for your computer or device, (v) provide you with targeted advertising and content, and (vi) allow you to participate in interactive features, when you choose to do so. For example, We remember your login ID/email address or screen name so that you can quickly login the next time you visit Our Services or so that you can easily retrieve the items you previously placed in your shopping cart. We may also show you specific BlueTriton content or promotions that are tailored to your interests.

Improve Our Services and Products, and Do Analysis

We constantly strive to improve our offerings, and in order to do so, We analyze interactions with Our Services and our marketing, reactions to our products, order history, customer comments and Customer Support interactions, and user behavior.  The information we use to do this may include any or all of the categories of information that we collect.

The models we use to analyze this information include the range of tools available to us from spreadsheets and databases to algorithmic models, and technologies like artificial intelligence and machine learning.

Market Our Products to You

We may use your personal information to provide you with advertising and marketing information about Our products and Services, as well as certain other brands and products of others that we market or sell. The information that we use for those purposes may include Identification, Account, Payment and Financial, Demographic Data, Commercial Information, Data From Your Device, Electronic and Similar Information, Internet Activity, Geolocation Data and Inferences.  Our advertising may include targeted online advertising (see "Do Not Track/Opt-Out of Targeted Advertising"). You can always opt out of receiving advertising and marketing materials through your account, by following the instructions for the specific message you receive, or through "Your Privacy Choices" below:

Your Privacy Choices

Rewards Programs, Sweepstakes, Contests and Other Promotions

We have certain rewards programs and may also periodically offer promotions, including coupons, sweepstakes or contests.  In order to participate in these activities, we may collect and use certain personal information based on the nature of the specific promotional activity, and there may be additional terms, rules, requirements and notices associated with those promotions.

General Operations and Administration

In accordance with applicable laws, We use your personal information for other general business purposes, such as maintaining your account, conducting audits, financial calculations and tax reporting, administering our business and operations, evaluating performance, evaluating and maintaining our systems, security and fraud prevention and monitoring.  When and as appropriate, We may also use personal information to exercise Our legal rights or perform our obligations under applicable laws.  The information we use to do this may include any or all of the categories of information that we collect.

Aggregate or De-Identify Personal Information

We may also use certain information that we have de-identified or aggregated (as defined under applicable law) with other information so that it can no longer identify, or be associated with, you.  Under applicable law, this information is no longer personal information, and we can use and disclose the information for any purposes, unless prohibited by applicable law.  The information we use to do this may include any or all of the categories of information that we collect.

4. To Whom do We Disclose the Personal Information We Collect?

Our Affiliates

We may provide your personal information to our affiliates who process that information for the delivery of our Services or for our business purposes as described in this Policy.

Our Service Providers

We disclose your personal information to service providers who We engage to help Us run our business (e.g., order management and fulfilment, payment processing, fraud detection and identity verification, Customer Support, information technology and computing support, customer relations management systems (CRM), customer and consumer research, operations, managing marketing and promotions, customer and consumer research, and similar activities). For the purposes of fraud prevention, we may share your personal information with Forter, Inc., our third-party provider of fraud screening services; please see Forter's privacy policy.

Other Third Parties

We may also disclose personal information to certain other parties, including:

  • Credit reporting agencies/debt collectors (credit reporting agencies and debt collectors are external companies that We use to help Us to verify your creditworthiness (in particular for orders with invoice) or to collect outstanding invoices).
  • Advertising and marketing partners and agencies, including digital advertising networks, publishers, and technology providers.
  • Joint promotion partners, if any, as disclosed in the applicable joint promotion terms.
  • Other parties in connection with a corporate transaction, including a merger, acquisition, restructuring, or bankruptcy. Personal information may be disclosed in the context of due diligence relating to the transaction and/or to the successors to Our business or the applicable parts of it.
  • To law enforcement, governmental authorities or third parties when and as required by law; in response to legal proceedings; in response to a required from law enforcement; to protect Our rights, security, safety, or property, or those of other parties or the public; to enforce the terms of any agreement, including the terms of our Services.

5. What Rights and Choices Do You Have Regarding Your Personal Information?

General Privacy Rights

You have certain rights with respect to your personal information under various privacy and data protection laws. If you are a resident of California, you may have additional rights (See "Your California Privacy Rights" ). The rights that you have, and the process to exercise those rights, are as follows:

Right to Know/Access

This allows you to request that we tell you the information we have collected, used, sold, or shared about you, as well as categories of personal information or categories of sources from which your personal information was collected, the purposes for which Personal Information was collected, and/or the specific pieces of personal information collected about you during a particular time period, as defined under appliable law.  You also have a right to request a transportable copy of certain personal information.

Right of Correction

You have the right request the correction of any incomplete or inaccurate personal information that we hold about you.

Right of Deletion (Erasure)

This enables you to ask us to delete all or certain elements of your personal information where there is no valid business reason for us to continue to process it or where we are required to erase your personal information to comply with applicable law. Note, however, that there are exceptions to this right, and we may not always be able to comply with your request of erasure for specific reasons which will be notified to you, if applicable, once we review and process your request. In addition, once deleted from our active systems, certain information may remain in our archiving or backup systems until deleted in accordance with our standard practices.

Do Not Track/Opt-Out of Targeted Advertising

The Services use several common tracking tools. These may include browser cookies, web beacons, flash cookies, and similar technologies. Service providers also use these tools on Our Services. and elsewhere on our behalf.  We also share information about your use of Our Services with our social media, advertising and analytics partners.

If Our system detects a Global Privacy Control (GPC) opt-out preference signal, Our system will generally recognize and honor it. Because there is no standard process to interpret other opt-out preference signals, Our system may not recognize them.

You may also disable or block cookies and certain other tracking technologies through certain software and browsers.  If you block or reject all cookies through your browser some of the functionality of the Services may not work properly.

For more information on cookies and tracking technologies, and to control those uses, click on the Your Privacy Choices at the bottom of this page.

How to Exercise Your Rights

To exercise most of these rights, or if you have any questions or concerns, you may submit this form with your request, or you may contact us at 844-887-3758 or at dataprivacy@bluetriton.com.  For any personal information that is automatically collected and is associated with your browser or device, you can exercise your rights through Your Privacy Choices at the bottom of this page. You are limited in the number of times that you can exercise specific rights in any 12-month period.

For verification purposes, we may request any or all of the following: your first and last name, account number, email address and any email address you may have used when registering with BlueTriton, phone number associated with your account, and a physical mailing/delivery address.

We will generally respond to your access or deletion request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.   The response we provide will also explain the reasons we cannot comply with a request, if applicable.  

Right to Appeal

Under the laws of certain jurisdictions, you have the right to appeal our decision not to act on your request to exercise certain of the rights described above.  To appeal our decision if you are in an eligible jurisdiction, please email us at:  dataprivacy@bluetriton.com the subject line "Individual Rights Request Appeal."

Your California Privacy Rights

In addition to the rights set forth above under General Privacy Rights California residents have certain rights with respect to personal information under certain laws including the providers California Consumer Privacy Act and the California Privacy Rights Act (as each may be amended or modified, from time to time, and including any regulations promulgated thereunder) (collectively referred to as the “CCPA”): 

Notice at Collection

At or before the time of collection of your personal information, you have a right to notice of our privacy practices, as provided above in this Policy, including the categories of personal information and sensitive information that We collect, the purposes for which We collect and use that information, how long the information is retained, and whether that information is sold or shared .

Financial Incentives

See our Notice of Financial Incentives.

Rights to Know, Correct and Delete

You have a right to request that We tell you the personal information we have collected about you, the right to request additional information about how we use, sell and share your personal information, the right to correct inaccurate personal information that we have about you, and the right to request the deletion of your personal information.

Note that we have provided much of this information in this Privacy Policy. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. Those rights are described above under "General Privacy Rights", and to exercise those rights, see "How to Exercise Your Rights" .

Do Not Sell or Share My Personal Information

If you are a California resident, you have a right to opt-out from the “sale” or “sharing” (as those terms are defined under the CCPA) of your personal information with third parties. To exercise this right, click on "Your Privacy Choices" below:

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or at the bottom of the page, or in the "About" section in our app. We do not knowingly “sell” or “share” the personal information of minors under 16 years old.

Authorized Agents

In certain instances, you may designate an authorized agent to exercise your rights under this section. The agent may submit the requests as in this section.  We have verification processes that we will need to follow, and as part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent and that you verify your identity and confirm that you provided the agent permission to submit the request.

Non-Discrimination

We will not unlawfully discriminate nor retaliate against you for exercising the rights under this section.

Right to Limit the Use and Disclosure of Sensitive Personal Information

You have a right to limit Our use of sensitive personal information for any purposes other than to provide the Services or goods that you request or as otherwise permitted by law. To exercise this right, see "How to Exercise Your Rights".

“Shine the Light” Law Rights

Under the California “Shine the Light” law, California residents may opt out of Our sharing their personal information with certain parties for their direct marketing purposes. In order to exercise this right, see "How to Exercise Your Rights"  and include the subject line “Shine the Light Opt-Out” in the subject line and your name and in the body of the message.

6. Third-Party Websites and Services

The Services may include links to third-party websites or apps, including social media platforms. Those third-party websites and services are not Services operated or controlled by Us. This Policy does not apply to, and We do not control and are not responsible for, the privacy practices of those third-party websites or services. Please read their privacy policies carefully, since they have their own practices and policies, and they may collect and use your personal information in very different ways that We do.

Our Services may also include third-party content that collects data. This includes data collected by cookies, pixels, or other tracking tools, as further described above under "Do Not Track/Opt-Out of Targeted Advertising".

7. How Do We Protect Your Personal Information?

We use reasonable and appropriate security measures to protect your personal information.  No method of transmitting or storing data is completely secure, and despite our efforts to protect your personal information, We cannot guarantee the security of your personal information.

It is important that you also play a role in keeping your personal information safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else – generally meaning a unique, long and complex password. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer or other device, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer or device. You should also make use of any privacy settings or controls We provide you in our Services.

8. How Long do We Retain Your Personal Information?

We keep personal information as long as it is necessary, relevant, or permitted for the purposes described in this Policy. We also keep personal information when and as otherwise required by law. 

This might mean that We keep some or all of your personal information even after you close your account with Us or otherwise end your relationship with Us, even if you exercise your deletion rights. When determining how long to retain your personal information, we take into account a number of factors, including the length and nature of our business relationship and the Services you obtain, the applicable statute(s) of limitation, and whether we are subject to any legal obligations relating to your personal information.  We also might de-identify certain personal information rather than deleting it.

9. Collection of Personal Information of Children

Our Services are intended for a general audience, and are not directed at children under the age of 13. We do not knowingly solicit or collect personal information from children below the age of 13. If you are a parent or legal guardian and think that your child under 13 has given Us data, you can contact Us in writing or by email as provided below under the section titled Contact Us. Please mark your inquiries “COPPA Information Request.” We do not knowingly sell the personal information of minors under the age of 16 without affirmative authorization.

10. Changes to this Policy

We are always improving our products and services, and we may change how we collect, use or disclose your personal information. In addition, the laws regarding personal information and privacy change frequently. Because of these changes in our practices and applicable laws, we periodically update this Privacy Policy.

When we make changes to this Policy, we will post any changes on this page so please check back frequently.  If we make material changes, if we have your contact information, we will notify you prior to the changes taking effect, and we will also post a notice through the Services.

Any use of our Services after we post the updated Policy will be subject to that updated Policy.

11. Contact Us

To contact us about this Policy and/or our privacy practices, please contact Us at dataprivacy@bluetriton.com, 900 Long Ridge Road, Building 2, Stamford, CT 06902, or 844-887-3758.

Last Updated: June 9, 2023