Effective Date: March 11, 2020
CATEGORIES OF INFORMATION WE COLLECT ONLINE
We collect information when you interact with us online or on a mobile device, for example, when you visit our website, social media pages, blogs, email us, or purchase our products online.
Certain information we may collect is Personal Information (or personal data) that identifies you (directly or indirectly), describes, or is capable of being associated with you, such as your name, user name, physical address, phone number, email address, or credit card information.
Other information that we may collect is Anonymous Information – or information that does not identify (directly or indirectly), and cannot be used to determine the identity of an individual user. It may include aggregate information about groups or categories of users.
The information we collect varies depending on how you interact with us or others online:
- Information you provide to us: When you make a purchase on our website, we collect personal information that you volunteer: such as your name, email address, postal address, phone number, payment information, and other information necessary to process your order. We also collect the information you provide to us when you register for an online account, participate in a contest or sweepstakes promotion, fill out a survey or questionnaire, subscribe to receive promotional materials, or contact us. Your disclosure of this information is voluntary. However, if you choose not to provide the requested information, you may be unable to access the service in question.
- Information about your web usage: When you visit our website online or on a mobile device, we may collect information like your IP address, your geography, the Web page from which you came, the web browser and type of device you used, and a record of your activity on our site.
HOW WE USE INFORMATION WE COLLECT ONLINE
We use personal information only for the purposes outlined below: to provide, improve, and develop our products and services, to communicate with you, to offer you targeted Ladder promotions, and to protect us and our users. Ladder collects and processes your personal information for the following purposes:
- Providing you our products and services and Communicating with you: We may use your personal information, on the basis of the contract between Ladder and you, in order to provide you our products and services, communicate with you about your order and process your requests, accounts, or orders, and to inform you about our policies and terms. In order to process your purchases, we may send you a confirmation email or we may contact you by email or telephone if we have questions about your order.
- Informing you about products, content, or services that may be of interest: With your prior consent, we may use personal information to send you Ladder marketing communications; for example, we may periodically send you emails about new Ladder products and services, content that may be of interest to you, discounts, special promotions or upcoming events. If you do not wish to receive such emails in the future, please contact us using the contact information below, or click the “unsubscribe” link on any promotional email you receive from us. If you decide to opt out, we may still send you non-promotional communications, such as communications about your existing purchases or the settings or your account as mentioned above. Ladder does not disclose your personal information for third parties’ own direct marketing purposes.
Please note that you have the right to withdraw your consent at any time (without calling into question the processing previously carried out) by sending a request using the contact information below.
- Improving, and developing our products and services: We use your information to help us improve, and develop our services, which is necessary for us to pursue our legitimate interest and provide you with quality services and products. This includes using information for purposes such as data analysis and research. The information we receive allows us to tailor our product offerings, improve your online experience, and customize the content and layout of our pages.
- Promoting safety and security: We use your information to pursue our legitimate interest in helping verify accounts and user activity, as well as in promoting safety and security, such as by monitoring fraud, investigating suspicious or potentially illegal activity or violations of our terms or policies, protecting our rights, or pursuing available remedies.
ENTITIES WITH WHOM WE SHARE INFORMATION WE COLLECT ONLINE
We may disclose personal information we collect online to the following categories of third parties, acting on our behalf and upon our instructions:
- Our affiliates and subsidiaries: We rely on our affiliates and subsidiaries to help us provide our products and services to you, for example, to process payments, fulfill orders, and send Ladder promotional materials;
Vendors and Service Providers: We use third party companies to help us provide our products and services to you, for example, to process payments, fulfill orders, and send Ladder promotional materials. Some of these companies are given access to some or all of the information you provide to us, only as strictly necessary for these companies to help us provide our products and services to you. Some service providers may use anonymized data from Ladder users to improve their own services, but your personal information will not be shared with third parties for their own purposes.
In addition, please note that Ladder may disclose your personal information in the context of:
- Legal Compliance and Security: In certain special cases, we may disclose your personal information when we have reason to believe that disclosing this information is necessary to identify or contact you, or bring legal action against someone who may be causing injury to you, Ladder, or someone else. We may disclose your personal information when we believe the law requires it, in response to any demand by law enforcement authorities in connection with a criminal investigation, in response to civil or administrative authorities in connection with a pending civil case, governmental authorities or administrative investigation, or in connection with an investigation conducted by Ladder.
INTERNATIONAL DATA TRANSFER
When we disclose personal information to the entities mentioned above, it may imply transfers of personal information outside of the European Economic Area (“EEA”). Certain countries located outside the EEA have been approved by the European Commission as providing an adequate protection and therefore no additional safeguards are required to export personal information to these countries.
In countries which have not been certified as providing an adequate protection, Ladder has implemented appropriate safeguards. For more details with respect to the safeguards, please contact: email@example.com.
COOKIES & PIXELS
“Cookies” and “pixels” are small data files stored on your computer when you browse our website. We place a unique identifier in the cookie and use the cookie to connect your computer with the information we store for you in our database. Some examples of the data we store in our database from cookies include your account preferences, items added to your shopping bag, pages accessed, and previous visits to our site. Through cookies, pixels, and similar technologies, we may alert you to new areas that we think might be of interest to you when you return to our site, record past activity at our site, provide Ladder advertisements that are tailored to your interests, or customize webpage content. Some of these cookies remain on your browser and allow the installer of the cookie to track you over time and across the Internet.
You have the ability to accept or decline cookies. The “Help” tab on your toolbar may guide you to the settings for your browser that will allow you to change your browser settings with regard to cookies. If you decline cookies, your use of our website may be impaired.
Alternatively, the following links provide instructions in order to manage your cookies preferences:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies
COMPANIES OTHER THAN LADDER
We have implemented physical, technological, and organizational safeguards and security measures designed to protect against the loss, misuse, or unauthorized access or disclosure of your personal information under our control. We also take measures to protect the personal information we disclose to third parties, for example by entering into contractual agreements in compliance with applicable laws. Please be aware that, despite our efforts, no security measures are perfect or impenetrable. You can help us by protecting and keeping your passwords safe at all times, and not using the same password for different applications or sites. You also can protect yourself and help us reduce the risk of fraud by promptly notifying us if you suspect that your credit card, user name or password is lost, stolen or used without permission. In the event of a personal data breach, we will promptly notify you and the proper authorities if required by law.
From a general perspective, we will keep your personal information during the period of our contractual relationship, extended by the applicable limitation period.
With regard to marketing communications with prospects, we will keep personal information for 3 years after the last correspondence with us.
As to the processing carried out in order to ensure security and safety, we will keep your personal information for 3 years.
As to the processing of cookies, we will keep your personal information for thirteen (13) months as from their collection.
On the expiry of the applicable data retention period, we will erase or irrevocably anonymize the relevant personal information.
You have various rights in relation to the processing of your personal information. In particular, you have the right to:
- access to personal information processed concerning you;
- rectification of inaccurate personal information concerning you and a right to erasure;
- restriction of processing;
- data portability;
- object to the processing on grounds relating to your particular situation.
In order to exercise any of your rights, or if you have any other questions about our use of your personal information, please contact us at the following address: firstname.lastname@example.org.
In any case you also have the right to lodge a complaint with the competent data protection authority.
As described in our Terms of Service, Ladder’s services are not directed to persons under age 18, and thus we do not knowingly collect, use, or disclose personal information from persons under this age, including from persons under age 16. If you are a parent and you think we have inadvertently collected personal information from your child who is under age 16, you may contact us to request instructions on how to delete this content.
If you are a California resident, California law permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. Ladder does not disclose your personal information for third parties’ direct marketing purposes. California law also permits minors to request and obtain deletion of certain posted content. For additional information or to make such a request, please contact us.
Email: email@example.comAttn: Privacy
PO Box 5168
Santa Monica, CA 90409