Welcome to Solo New York. This Privacy Notice explains what we do with your personal information when you are visiting https://solo-ny.com (including the mobile optimized version accessible from your portable hand-held device) (“Website”) [and social media pages], making a purchase on the Website [or telephone] or when you contact us by phone. It describes how we collect, use and process your personal information, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your rights.
For the purpose of applicable data protection legislation United States Luggage Company, LLC, whose registered office is at 400 Wireless Blvd, Hauppauge, NY 11788 (“we”, “our” or “us”) is the ‘controller’ of your personal information. This means we decide why and how your personal information is used and are responsible for protecting it. Please refer to the end of this notice for our contact and company information.
We work with other, more independent, organizations in connection with some of the processing activities described in this notice, such as social media platforms and our group companies. Where that information is collected and sent to other organizations for processing that is in both our and their interests, we will be making decisions together in relation to that particular processing and will be ‘joint controllers’ with the organizations involved. As joint controllers, we and the other organisations involved in making these decisions will be jointly responsible to you under data protection laws for this processing. In other circumstances, the organization receiving your information will be separately responsible to you and use your personal information in the ways described in its privacy statement (and not ours).
We may amend this Privacy Notice from time to time. Please visit this page regularly as we will post any changes here. Where appropriate, we may also notify you of the changes by email. Please see further the section Changes below.
If you are dissatisfied with any aspect of this Privacy Notice, you may have legal rights which we have described below where relevant.
1. Information we collect about you
2. How we use your information
4. Use of device and software usage information
6. Sharing your information with third parties
7. Social Media Platforms
8. Where we store your information
9. How we safeguard your information
10. How long we keep your information
11. Your rights
12. California and CCPA-specific information
14. How to contact us
1. INFORMATION WE COLLECT ABOUT YOU
When you use the Website or interact with us offline we collect and use information about you in the course of providing you with our products and services and with customer support. We may collect some or all of the information listed below to help us with this:
Depending on the type of personal information in question and the legal grounds (i.e. the ‘lawful bases’) on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfill our contractual requirements or, in extreme cases, may not be able to continue with our relationship with you.
For details of the lawful bases that we rely on to be able to use and process your personal information, please see How we use your information.
2. HOW WE USE YOUR INFORMATION
The purposes for which we use your personal information and the lawful basis under data protection laws on which we rely to do this are explained below.
Where you have provided CONSENT
We will rely on your consent to send you the following where we invite you to opt-in on the Website:
We may also rely on consent to use your name and image for publicity purposes. For example, we may rely on consent to feature winners in advertising for future competitions or prize draws.
You may withdraw your consent at any time. Please see the Marketing section below for further details.
Where it is required to complete or, at your request, take steps to enter into, a CONTRACT
The use of your personal information may be necessary to perform a contract that you have with us or perform steps you request to enter into a contract. For example, when you buy a product from us, we need to use your personal information to process your order, to send you the product, for billing purposes and to respond to any requests you may have. We also need to use your personal information to notify you about changes to our services.
Where there is a LEGAL REQUIREMENT
We will use your personal information to comply with our legal obligations, including where the law requires us:
Where it is in your VITAL INTERESTS
We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue the following legitimate interests (whether ours, in connection with our business, or that of a third party), for the following purposes:
Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns
Processing necessary for us to support Website visitors and customers with their inquiries
Processing necessary for us to respond to changing market conditions and the needs of our guests and visitors
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
We may collect your preferences to receive marketing information directly from us by email or SMS in the following ways:
From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above at any time. Please see Your rights below for further details on how you can do this.
4. USE OF DEVICE AND SOFTWARE USAGE INFORMATION
We may monitor your use of the Website and record your IP address, operating system and browser type, and the geographical location for system administration purposes.
We collect aggregated statistics data about visitors to the Website and sales and traffic patterns. This information does not identify users in any personal capacity and we do not use this information to build profiles on individual users: it just contains generalized information about the users of the Website.
A cookie (and other technologies like pixels and beacons) is a small data file that is placed on your browser or the hardware of your computer or other device to allow a website to recognize you as a user when you return to the website.
We use non-essential cookies when you consent for us to do so and essential cookies on the Website. Please see our Cookies Notice for more information about the type of cookies and tracking technologies that we use on the Website and why, and how to accept and reject them.
6. SHARING YOUR INFORMATION WITH THIRD PARTIES
We may share your information with any of the following trusted third parties:
7. SOCIAL MEDIA PLATFORMS
We use a number of different social media platforms to communicate with you and to promote products and services. We process your personal information using these platforms in a variety of ways, as follows:
Pages. We use your personal information when you post content or otherwise interact with us on our official pages on Facebook, Instagram, Twitter, Snapchat, YouTube, LinkedIn and other social media platforms. We also use the Page Insights service for Facebook, Instagram and LinkedIn to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content. Where those interactions are recorded and form part of the information we access through these Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us.
Facebook uses this information to provide services to us and also for further processing for its own business purposes. We and Facebook are joint controllers of the processing involved in collecting and sending your personal information to Facebook using cookies and similar technologies as each of us has a business interest in Facebook receiving this information. You can find out more about these technologies by visiting our Cookies Notice. The services we receive from Facebook that use this information are delivered to us through Facebook’s Business Tools, which include Facebook Pixel, App Events SDK and Website Custom Audiences. These tools allow us to target advertising to you within Facebook’s social media platform by creating audiences based on your actions on our website and applications and allow Facebook to improve and optimize the targeting and delivery of our advertising campaigns for us.
We use LinkedIn Insight Tag, a small piece of code that we embed in our websites that allows us to perform in-depth campaign reporting and unlock insights about users that may visit our websites via our LinkedIn campaigns (e.g. by allowing us to discover business demographics by layering LinkedIn data on data about our website visitors). LinkedIn Insight Tag enables the collection of metadata such as IP addresses, timestamps, and events such as page views. You can find out more about these technologies by visiting our Cookies Notice.
Our relationship with Facebook and LinkedIn. As we are joint controllers with these platforms for certain processing, we and each platform have:
Facebook and LinkedIn also processes, as our processor, personal information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes. These services include the processing these platforms carry out when they display our advertisements to you in your news feed at our request after matching contact details for you that we have uploaded to them. These advertisements may include forms through which we collect contact information you give to us.
Further information. The Facebook company that is a joint controller of your personal information is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The LinkedIn company that is a joint controller of your personal information is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. For further information regarding these platforms and their use of your personal information, please see:
8. WHERE WE STORE YOUR INFORMATION
We store your personal information on secure servers in Hauppauge, NY.
We are headquartered in the United States. Your information will likely be collected in your country and subsequently transferred to or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, we implement measures, such as standard contractual clauses and a global data transfer agreement, to ensure that any transferred Personal Information remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out below.
9. HOW WE SAFEGUARD YOUR INFORMATION
We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorized access to, and misuse of, your personal information.
We have a management system and implements appropriate security measures to maintain integrity and security and prevent unauthorized access, loss, manipulation or leaks etc., of personal information. Furthermore, where the processing of personal information is subcontracted, we make efforts to protect such personal information by selecting subcontractors who handle personal information appropriately and by prescribing the necessary measures to the subcontractor for appropriate management of personal information.
If you suspect any misuse or loss of or unauthorized access to your personal information please let us know immediately by contacting our customer care using the details provided at the end of this notice.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to the Website and any transmission is at your own risk.
The Website may from time to time contain links to and from other websites. If you follow a link to any of those websites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or for their privacy policies. Please check those privacy policies before you submit your information to those websites.
10. HOW LONG WE KEEP YOUR INFORMATION
We will retain your personal information for as long as you have a relationship with us and for a period of time after your relationship with us has ended.
When determining how long this retention period will last once the purpose of processing the personal information has been satisfied, we take into account the length of time personal information is required to:
When personal information is no longer required due to the expiration of the personal information holding period, or the purpose for which the personal information has been obtained has been achieved, we will destroy the personal information in accordance with our retention policy. If applicable laws require us to continue to store this personal information, we will transfer such information to a separate database or place in a separate storage compartment.
11. YOUR RIGHTS
In accordance with applicable law, you may have a number of rights in relation to your information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either: (i) the date that we have confirmed your identity; or (ii) where we do not need to do this because we already have this information, from the date we received your request.
We will process all such requests in accordance with local laws. The California Privacy Rights section below provides additional information for California residents.
Right to object
This right enables you to object to us processing your personal information where we do so for one of the following reasons:
Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your personal information for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your personal information.
Right to withdraw consent
Where we have obtained your consent to process your personal information for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your personal information for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
To withdraw your consent to marketing communications, please use the unsubscribe tool in the relevant communication. Alternatively, you can contact us via email at firstname.lastname@example.org and type "unsubscribe" in the subject line or call us at 1-800-333-6292. You may opt-out of receiving future mailings at any time.
Right of access (‘Data Subject Access Requests’)
You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
If you would like to request access to your information, it would assist us with dealing with your request if you could use the subject heading ‘Data Subject Access Request’, or quote this over the phone, when contacting us. Please note that this is not mandatory and we will still deal with any requests without this reference.
Right to erasure
You have the right to request that we erase your personal information in certain circumstances. Normally, this right exists where:
We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right to restrict processing
You have the right to request that we restrict our processing of your personal information in certain circumstances, for example if you dispute the accuracy of the personal information that we hold about you, you object to our processing of your personal information for our legitimate interests or you require us to keep it in connection with legal proceedings. If we have shared your personal information with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal information.
We may only process your information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties to whom we have disclosed the inaccurate or incomplete personal information. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
You can access and update certain parts of your information by logging into your account on the Website.
Right of data portability
If you wish, you have the right to transfer your personal information between service providers where we rely on your consent or the performance of your contract as the lawful basis to use that information. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you if technically possible.
Rights relating to automated decisions
In certain circumstances, you may contest a decision made about you based purely on automated processing and where the processing is not required by law. You may also ask us to stop making such decisions using automated processing alone.
Right to complain
If you would like to make a complaint or if you have any questions about how we use or keep your Personal Information, you may contact us at email@example.com
For visitors to our Services you may have the right to lodge a complaint with the relevant supervisory authority for your jurisdiction, if you believe our processing of your Personal Information violates applicable law. Please see our list of global entities at the top of this Policy.
You have the right to lodge a complaint with the relevant local supervisory authority for your jurisdiction.
How to exercise your rights
If you would like to exercise any of these rights, please contact us on the details provided under How to contact us. Please note that we may keep a record of your communications to help us resolve any issues that you raise.
12. CALIFORNIA AND CCPA-SPECIFIC INFORMATION
California Privacy Rights
California residents are entitled to request and obtain certain information about the disclosure of certain categories of their personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.
“Do Not Track.” Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.
California residents who are registered members or users of the services and are under the age of 18 may be entitled under California law to request and obtain removal of content and information that they themselves post on the services. You may request such removal by emailing us at firstname.lastname@example.org. In your request, please provide a description of the material that you want removed and information sufficient to permit us to locate the material, including your name, email address, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request.” Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.
California Consumer Privacy Act (CCPA)
We have explained our privacy practices in the other sections of this Privacy Notice. In this section, we supplement those descriptions for California residents by providing a list of categories of personal information as set forth in the CCPA that have been collected or disclosed for a business or commercial purpose during the preceding 12 months, as well as certain other information. Please see the other sections of the Privacy Notice for additional information and context.
“Sales” of personal information under the CCPA
For purposes of the CCPA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us on the details provided below.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, phone number, and/or mailing address.
Information about how you may exercise your rights as a California resident can be found on the details provided below. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the services may change or no longer be available to you.
We may make changes to this Privacy Notice at any time by posting a copy of the modified notice on the Website or, where appropriate, by sending you an email with that notice. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Website, whichever is the earlier.
14. HOW TO CONTACT US
If you have any queries about this Privacy Notice, including your rights in relation to your personal information, please contact us at email@example.com or call us at 800-333-6292
If you wish to contact us with any general queries or concerns, you can use our Contact Us page.
When contacting us by email or post, please use the subject heading ‘Data protection query’ so that we can direct your query to the appropriate department and deal with it promptly.
LAST UPDATED October 1, 2021