Spinster Sisters, Inc. (“Spinster Sisters,” “we,” or “us”) respects your privacy. This Privacy Statement describes the types of “Personally Identifiable Information” (“PII”) that we may collect from you when you visit https://spinstersistersco.com/ or use our other products and services that include an authorized link to this Privacy Statement (collectively, the “Services”). Please read our Privacy Statement carefully to get a clear understanding of: (i) what PII we collect, (ii) how we use your PII, (iii) with whom we share you PII, (iv) how we protect your PII, and (v) the choices we offer you regarding our collection and use of such PII. If you do not agree with this Privacy Statement, please do not access or use any part of the Services.

WHAT PII DO WE COLLECT FROM THE PEOPLE THAT USE OUR SERVICES?

The PII we collect about you may include, without limitation:

• Contact information, such as name, email address, mailing address, and phone number;
• Payment information and financial details, such as payment card number and billing address, which are processed and stored by third-party payment processors; 
• Communication information, such as feedback or information you may send to us when you contact us; and 
• Any other details you provide to us during your use of the Services. 
• WHERE DO WE COLLECT PII FROM?

We may collect PII about you from various sources, such as:

• directly from you when you use the Services, such as when you register on our Site, place an order, subscribe to a newsletter, respond to a survey, fill out a form, or enter information on our Site; and 
• service providers, business partners, and other third parties. 
• HOW DO WE USE YOUR PII?

We may use the PII we collect about you in the following ways:

• Process orders you place and complete other transactions you have requested using the Services, and provide you with products and services you request;
• Send you information or materials you request;
• Maintain a record of your purchases and other transactions using the Services;
• Respond to your questions and comments and provide customer support;
• Communicate with you about our products, services, offers, and promotions;
• Operate, evaluate, and improve our business and the products and services we offer;
• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
• To improve our Services in order to better serve you;
• Analyze trends and statistics regarding use of the Services and transactions conducted using the Services;
• Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
• To allow us to better service you in responding to your customer service requests;
• Enforce our Terms of Service and other agreements; and
• Comply with applicable legal requirements and industry standards.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

WHO DO WE SHARE YOUR INFORMATION WITH?

We may disclose PII about you:

• To contractors, service providers, and other third parties we use to support our business or serve our users, as long as those parties agree to keep your PII confidential;
• To comply with any court order, law, or legal process, including responding to any government or regulatory request;
• To enforce or apply our Terms of Service and other agreements;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Spinster Sisters, users of the Services, or others; and 
• With your consent. 

We do not sell, trade, or otherwise transfer to outside parties your PII unless in accordance with above list. However, non-PII may be provided to other parties for marketing, advertising, or other uses.

We also reserve the right to transfer your PII to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets, equity, or similar transaction. Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your PII in a manner that is consistent with our Privacy Statement.

HOW DO WE PROTECT YOUR INFORMATION?

We have implemented the following measures intended to protect your PII from accidental loss and from unauthorized access, use, alteration, and disclosure.  

• Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
• Your PII is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. 
• All sensitive/credit information you supply is encrypted via Secure Socket Layer (“SSL”) technology.
• All transactions are processed through a gateway provider and are not stored or processed on our servers.

However, please note that the electronic transmission of information is not completely secure. We cannot guarantee that the security measures we have in place to safeguard PII will never be defeated or fail, or that such measures will always be sufficient or effective. Any transmission of PII is at your own risk.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Yes. When you use the Services, we may collect certain information by automated means, such as by cookies.  A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.  We may also use third-party analytics tools (such as Google Analytics, Google Tag manager, Meta Pixel, and TikTok Pixel) that collect information about use of the Services and user traffic. The information we collect by automated means may include, without limitation: 

• Information about the devices you use to access the Services (such as the IP address and the type of the device, operating system, and web browser);
• Dates, times, and duration of use of the Services (including whether you are a repeat or first-time visitor); and
• Information on actions taken when using the Services (such as page views and website navigation patterns).

We may use the information collected by this tracking technology to help us improve and personalize our Services, including to:

• Help remember and process the items in the shopping cart;
• Understand and save user’s preferences for future visits; and
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences, social media and digital marketing, and tools in the future. 
• YOUR CHOICES. 

We offer you the following choices about the information we collect from you and how we communicate with you: 

• Cookies. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, though, that without cookies you may not be able to take full advantage of all of the features of the Services.  However, you will still be able to place orders.
• Promotional Communications.  If you do not want us to use your contact information to promote our products or services, you can opt out by sending us an email stating your request to suds@spinstersistersco.com. If you have received a promotional communication from us, you can also opt out of receiving future promotional communication from us by following the unsubscribe instructions contained in such communication. 
• Web Analytics.  
• You may opt out of the aggregation and analysis of data collected about you on our website by Google Analytics by visiting https://tools.google.com/dlpage/. 
• For more information on how Google Tag Manager collects and processes data and how you can control such online activities, please visit: https://tools.google.com/dlpage/gaoptout, and www.google.com/policies/privacy/partners/.
• To learn more about Meta’s privacy practices, see facebook.com/policy.php.
• ACCESSING AND CHANGING YOUR INFORMATION. 

You may make changes to your PII through your customer account.  You may also send us an email at suds@spinstersistersco.com to request access to, correct, or delete any PII that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

DO NOT TRACK SIGNALS 

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track (“DNT”) browser mechanism is in place. We do not allow third-party behavioral tracking.

CHILDREN UNDER THE AGE OF 13. 

The Services are not directed to, and we do not knowingly collect or solicit PII from, children under the age of 13. If we learn we have collected or received PII from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at suds@spinstersistersco.com. 

CHANGES TO OUR PRIVACY STATEMENT. 

We reserve the right to update or change this Privacy Statement at any time. If we make a material change to our Privacy Statement, we will provide notice to you (for example, by email) that our privacy practices have changed and will provide a link to the new statement. In the event we make a material change to how we use your PII, we will provide you with an opportunity to opt out of such new or different use. The date this Privacy Statement was last revised is at the top of this Privacy Statement. We encourage you to review this Privacy Statement periodically to check for any updates or changes.

DATA TRANSFERS. 

We are based in the State of Colorado in the United States. When we obtain information about you, we may transfer, process, and store such information outside of the country in which you reside, including in the United States. By using the Services, you consent to the transfer to and processing and storage of your information in countries outside of your country of residence, which may have different data protection laws than those in the country where you reside.

NOTICE TO EEA AND UK RESIDENTS. 

Privacy and security are key to our approach to product development and business. We continuously evaluate all our practices in an effort to safeguard your information as effectively as possible. In that vein, we’re glad to comply with the General Data Protection Regulation (“GDPR”) and to help our customers comply with GDPR. 

Legal Basis. Our legal basis for processing and collecting personal information varies based on the context for which it is collected. However, we will normally collect personal information only as necessary to perform a contract with you (such as when we provide the Services you request), as noted in this Privacy Statement, and otherwise with your explicit consent.

Transfers of Data. We are based out of the United States and thus must transfer your personal information across borders. We have taken appropriate safeguards to ensure your personal information is protected in accordance with this Privacy Statement through implementing additional safeguards, such as the standard contractual clauses.

Retention of Data. We will only retain personal information for as long as it is required to provide you the Services you have requested, or as otherwise required by applicable law. We delete all marketing and promotional communications with your PII in it after 12 months of usage.

Your Rights. You may exercise the rights afforded to you under the GDPR, including the right to access, correct, update, and/or delete your personal information. You may also object to the further processing of your personal information and request portability of your personal information at any time by contacting us using the information provided below.

Consent. At any time, you may withdraw your consent that allows us to collect, store, and otherwise process your personal information. Please contact us using the information provided below to do so.

Data Protection Authority. You have the right to complain to an applicable data protection authority. For more information, please contact your local data protection authority, contact information may be found at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. 

 CONTACTING US

If you have any questions about this Privacy Statement or our information practices, please call us at 844.SPINSTER (844.774.6783), email us at suds@spinstersistersco.com, or write to us at 301 Commercial Rd., Suite G, Golden, CO 80401.

Last Revised: July 15, 2022