Brixton Privacy Policy

1. Personal Data We Collect, Use, and Disclose
As used in this Privacy Policy, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes “personal information” and “personally identifiable information” as that term is defined in privacy laws.

Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified or anonymized; or aggregate information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.

We may create aggregated, de-identified, or anonymous information from data by removing certain data components that make the data identifiable, or through aggregation, obfuscation, or other means. Subject to applicable law, our use and disclosure of aggregated, de-identified, or anonymized information is not personal data and is not subject to this Privacy Policy.

Category of Personal Data	Processing Purposes	Categories of Third-Party Recipients (Excluding Service Providers and Corporate Affiliates)
Identifiers, including: Name Postal address Email address Phone number Certain social media account information including username IP address Unique device identifiers Device operating system information	Furnish the products and Services you request, process your transactions, and send you related information, such as order and shipping confirmations and receipts Provide customer support Notify you of products, services, offers, promotions, events and features that may be of interest to you Provide discounts, promotions, and other incentive programs Develop and improve our products and Services Monitor and analyze trends, usage and activities Advertise and market our products and Services, including through targeted advertising Selectively market third-party branded products and branded collaborations Manage your online account(s) and provide updates, security alerts and administrative messages For internal business purposes, including general business administration Debug, identify, and repair errors that impair the functionality of the Sites Detect and prevent fraud and protect the security of the Sites, the Services, and our operations Comply with our legal obligations, including responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims Fulfill any other purpose for which the information was collected in a lawful manner that is consistent with the context in which you provided the information and/or as otherwise disclosed at the time your information is collected Any other purpose consistent with your consent and expressed preferences	Third-party advertising platforms and analytics providers Third-Party Business Partners (defined in Section 2)
Commercial information, including: Products or services purchased, obtained, or considered Purchase histories Information about your interests and preferences	Same purposes as noted for “Identifiers”	Third-party advertising platforms and analytics providers Third-Party Business Partners
Internet or other electronic network activity information, including: Content and information about your communications through the Services Information using cookies and tracking technologies Mobile operating system information Mobile internet browser type Diagnostic data	Same purposes as noted for “Identifiers”	Third-party advertising platforms and analytics providers Third-Party Business Partners
Geolocation data, including: Location information based upon your IP address Location data collected from various devices including your mobile device(s)	Same purposes as noted for “Identifiers”	Third-party advertising platforms and analytics providers Third-Party Business Partners
Audio, electronic, visual, or similar information, including: User-generated content and any reviews you leave about our Services Video data via security cameras that we deploy in some of our retail stores (we provide notice about our use of security cameras to the extent required by applicable law	Same purposes as noted for “Identifiers”	Third-party advertising platforms and analytics providers Third-Party Business Partners
Financial data, including: Credit card, debit card, or bank account data	Furnish the products and Services you request, process your transactions, and send you related information, such as order and shipping confirmations and receipts For internal business purposes, including general business administration Fulfill any other purpose for which the information was collected in a lawful manner that is consistent with the context in which you provided the information and/or as otherwise disclosed at the time your information is collected Any other purpose consistent with your consent and expressed preferences	N/A
Characteristics of protected classifications, including: Veteran or military status Marital status	Provide discounts, promotions, and other incentive programs Monitor and analyze trends, usage and activities For internal business purposes, including general business administration Detect and prevent fraud and protect the security of the Sites, the Services, and our operations Comply with our legal obligations, including responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims Fulfill any other purpose for which the information was collected in a lawful manner that is consistent with the context in which you provided the information and/or as otherwise disclosed at the time your information is collected Any other purpose consistent with your consent and expressed preferences	Third-party advertising platforms and analytics providers Third-Party Business Partners
Professional or employment Information, including: Whether you are a first responder, government employee, or teacher	Provide discounts, promotions, and other incentive programs Monitor and analyze trends, usage and activities For internal business purposes, including general business administration Detect and prevent fraud and protect the security of the Sites, the Services, and our operations Comply with our legal obligations, including responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims Fulfill any other purpose for which the information was collected in a lawful manner that is consistent with the context in which you provided the information and/or as otherwise disclosed at the time your information is collected Any other purpose consistent with your consent and expressed preferences	Third-party advertising platforms and analytics providers Third-Party Business Partners
Sensitive personal data, including: Precise geolocation	Furnish the products and Services you request, process your transactions and send you related information, such as order and shipping confirmations and receipts For internal business purposes, including general business administration Fulfill any other purpose for which the information was collected in a lawful manner that is consistent with the context in which you provided the information and/or as otherwise disclosed at the time your information is collected Any other purpose consistent with your consent and expressed preferences	N/A
Inferences about you using any of the above	Same purposes as noted for “Identifiers”	Third-party advertising platforms and analytics providers Third-Party Business Partners

Because of the overlapping nature of certain of the categories of personal data identified above, some of the personal data we collect may be reasonably classified under multiple categories.

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2. Sources of Personal Data
We may collect personal data about you from the following categories of sources:

• Directly from you.
• Through cookies and other tracking technologies, as discussed in more detail in Cookies & Other Tracking Technologies.
• From our corporate affiliates, including our current and future parent companies, affiliates, subsidiaries, and other companies under common control and ownership.
• From other users of our Services, including those participating in our Refer a Friend program.
• From our service providers, including those providing hosting, analytics, customer and technical support, email and text services, and other services. For example, we may collect personal data if you use a live chat or chatbot our Sites, which is provided by our third-party service provider, Gorgias, on our behalf.  
• From other third-party business partners, which may include data providers, business and marketing partners, joint marketing campaign partners, ad network providers, and advertisers.
• From third-party advertising platforms and analytics providers.
• From other third-party business partners, which may include data providers, business and marketing partners, and joint marketing campaign partners (“Third-Party Business Partners”).
• From social media and other content platforms, such as Meta and Google, if you interact with us on these platforms or visit our Sites while logged into these platforms.

We may supplement or combine the personal data we receive from these third parties with personal data we otherwise collect about you through your use of our Services.

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3. Disclosure of Personal Data
We may disclose personal data that we collect to the following: 

• Our corporate affiliates. We may disclose personal data to our corporate affiliates, including our current and future parent companies, affiliates, subsidiaries, and other companies under common control and for the purposes provided in Personal Data We May Collect, Use, and Disclose.
• Our service providers. We disclose personal data to our service providers who provide services on our behalf, such as; payment processors; shipping and delivery providers; analytics providers; advertising and marketing providers; web hosting and cloud storage providers; customer and technical support providers; software development and IT providers; email and text providers; and providers of other services. For example, if you use the chatbot or live chat on our Sites, the information provided may be recorded and stored by our third-party provider, Gorgias, on our behalf. 
• Advertising partners and platforms. We may disclose your personal data to joint marketing campaign partners and third-party advertising platforms and analytics providers, including advertising, social media, and analytics companies who assist us in serving advertising regarding the Services to others who may be interested and who use cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.
• Third-Party Business Partners. We may disclose personal data to Third-Party Business Partners.
• Video hosting platforms. We may host videos on certain of our Sites, which may be embedded and hosted by third party video hosting platforms. These third parties may collect and store viewing data, including video titles and descriptions, viewing times and duration, and interaction data.
• Authorities for compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.
• Business transferees. If we or our affiliates are involved in a merger, acquisition, asset sale, or other corporate combination, your personal data may be transferred to the acquiring or surviving entity.
• Professional advisors. We may disclose personal data to our professional advisors, including lawyers, auditors, bankers, investors, shareholders, and insurers, where necessary in the course of the professional services they render to us.
• Other parties with your consent. We may disclose personal data to other parties with your consent in accordance with applicable law.

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4. Cookies & Other Tracking Technologies
We use cookies that collect information to improve and analyze our Services and provide targeted advertising. Some cookies are offered by third parties who collect your personal data so they can provide services to us and information about your online activity to others. You can modify the use of certain cookies in your browser settings. Note that if you decline certain cookies, some of our Services’ features may not function as designed.

Cookies on the Services generally fall into the following categories:

• Strictly Necessary. We may use cookies that we consider to be strictly necessary to allow you to use and access our Services, including cookies required to prevent fraudulent activity and improve security.
• Functionality. We may use cookies that are required to offer you enhanced functionality when accessing our Services, including identifying you when you sign in to our Services or keeping track of your specified preferences, including in terms of the presentation of content on our Services.
• Performance/Analytics. We may use cookies to assess the performance of our Services, including as part of our analytics practices. For example, we may use Google Analytics or other service providers for analytics services. These analytics services may use cookies to help us analyze how users use the Services. Information generated by these services (e.g., your browser, device, and usage data) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of our Services, compiling statistic reports on our Services’ activity, and providing other services relating to Services activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or by downloading the Google Analytics Opt-out Browser Add-on. 
• Targeting/Advertising. These third-party cookies are placed by third-party advertising platforms or networks to deliver ads and track ad performance, enabling advertising networks to deliver ads that may be relevant to you based upon your activities (sometimes called “targeted advertising”) on the Services.

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party websites or online services (e.g., browser “Do Not Track” signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms, unless otherwise required by applicable law.

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5. Legal Bases for Processing
We rely on one or more legal bases to process your personal data under applicable law. We may process personal data: (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our Terms of Service; (ii) as necessary to pursue our legitimate business interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement, or other government authorities; and/or (iv) with your consent.

We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests generally include:

• Providing, improving, and developing our Services, including to deliver your requested services, send you messages and provide user support, customize the Services to better fit your needs as a user, develop new products and services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
• Protecting you and others and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance with our agreements with you and other third parties, to ensure safe, secure, and reliable Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research based on your interactions on various Services, content you submit to the Services, and information obtained from third parties.
• Providing, personalizing, measuring, and improving our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.

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6. Data Security
The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. We maintain reasonable and appropriate technical, administrative and physical safeguards to help protect the security of your personal data against unauthorized access, destruction, loss, alteration, disclosure or misuse.

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7. Data Retention
We will retain your personal only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal data for internal analysis purposes. Information retained for internal analysis purposes is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable given our legal position, including with regard to applicable statutes of limitations, litigation, or regulatory investigations.

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8. International Transfers of Data
We may transfer, store, and use information we collect and maintain about you, including personal data outside of your state, province, country or other governmental jurisdiction. For example, if you are located outside the United States and choose to provide information to us, please note that we transfer personal data to United States and process it there. The data protection laws in the jurisdiction in which we process personal data may differ from those of your jurisdiction, and in certain circumstances, your personal data may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.

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9. Children’s Privacy
Our Services are not directed to or intended for children. We do not knowingly collect any personal data from anyone under the age of 18. If you become aware that a child has provided us with personal data, we strongly encourage you to Contact Us, and we will do our best to promptly remove such information from our records.

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10. Your Privacy Rights and Choices
You may have certain choices and rights regarding our collection, use, and disclosure of your personal data, based on your location or place of residency.

A. Opting Out of Promotional Communications

Email. You may opt-out of any emails that we send for promotional purposes by clicking the “unsubscribe” links provided at the bottom of those emails. If you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required to provide you with our Sites or services or for other reasons disclosed in this Privacy Policy. This means you will continue to receive these emails even if you unsubscribe from our optional communications.

Text/SMS. With your consent, we may send you SMS messages for promotional purposes, internal business purposes, internal user research, and to provide customer service, including troubleshooting. To cancel the SMS service at any time, text “STOP” to any text message you receive or email customerservice@brixton.com. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have unsubscribed. After this, you will no longer receive SMS messages from us. If you are experiencing issues with the messaging program you can text “HELP” for more assistance or email customerservice@brixton.com.

B. Privacy Rights

Certain states provide residents rights with certain rights with respect to their personal data. Please review California Privacy Notice; Nevada Privacy Notice; Privacy Notice for Residents of Other States; and International Privacy Notices for more information.

You can exercise the rights described in this Privacy Policy by:

• Completing our webform
• Calling us at (866) 264-4245

All requests are subject to certain exceptions under applicable law. Consistent with applicable law, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity. Please note that any request you submit to us is subject to an identification and residency verification process, to the extent permitted under applicable law. We will only use personal data provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request.

We will respond and process consumer requests consistent with applicable law. Except where otherwise noted, we will respond to your request within forty-five (45) calendar days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.

We do not charge a fee to process or respond to a consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. You may be limited in how many verifiable or authenticated consumer requests you make within a twelve (12) month period. 

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11. California Privacy Notice
This California Privacy Notice supplements the information contained in the rest of our Privacy Policy and is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy. For the purposes of this California Privacy Notice, except where a different definition is noted, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal data does not include publicly available information, information that has been de-identified or aggregated, or other information subject to certain federal and state regulations.

A. Personal Data We Collect
We have collected the following categories of personal data from consumers within the last twelve (12) months:

• Identifiers
• Commercial information
• Internet or other electronic network activity information
• Geolocation data
• Audio, electronic, visual, or similar information
• Categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)) (i.e., financial data)
• Characteristics of protected classifications under California or federal law
• Inferences

B. How We Use Personal Data
We may use or disclose the personal data we collect for one or more of the following purposes:

• Furnish the products and Services you request, process your transactions, and send you related information, such as order and shipping confirmations and receipts
• Provide customer support
• Notify you of products, services, offers, promotions, events and features that may be of interest to you
• Provide discounts, promotions, and other incentive programs
• Develop and improve our products and Services
• Monitor and analyze trends, usage and activities
• Advertise and market our products and Services, including through targeted advertising
• Selectively market third-party branded products and branded collaborations
• Manage your online account(s) and provide updates, security alerts and administrative messages
• For internal business purposes, including general business administration
• Debug, identify, and repair errors that impair the functionality of the Sites
• Detect and prevent fraud and protect the security of the Sites and our operations
• Comply with our legal obligations, including responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims
• Fulfill any other purpose for which the information was collected in a lawful manner that is consistent with the context in which you provided the information and/or as otherwise disclosed at the time your information is collected
• Any other purpose consistent with your consent and expressed preferences

C. To Whom We Disclose Personal Data
We limit our disclosure of the categories of personal data above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal data for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal data was collected.

We may “sell” and/or “share” personal data with third-party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms. We may also “sell” and/or “share” personal data to Third-Party Business Partners for marketing and promotional purposes. 

In the last twelve (12) months from the last updated date listed at the top of this Privacy Policy, we have “sold” or “shared” the following categories of personal data:

• Identifiers
• Commercial information
• Internet or other electronic network activity information
• Geolocation data
• Audio, electronic, visual, or similar information
• Characteristics of protected classifications under California or federal law
• Inferences

D. Retention of Personal Data
Your personal data will be retained by us for as long as necessary for the purposes outlined in this Privacy Policy. This information will be used and retained to the extent necessary to comply with any legal obligations or policies, to resolve disputes, and/or enforce legal agreements. Personal data may also be retained for internal analytic purposes. This information is retained for a shorter period, unless it used to enhance security features or improve the functionality of our Services. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (ii) whether retention is advisable considering our legal position, including with regard to applicable statutes of limitations, litigation or regulatory investigations.

E. Privacy Rights
The CCPA provides California residents with specific rights regarding their personal data. If you are a California resident, you may have the following rights under applicable California law:

• Right to know and access. You have the right to know what personal data we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
• Right to delete. Under certain circumstances, you have the right to request that we, as well as our service providers and contractors, delete the personal data that we collect about you.
• Right to correct. You have the right to request the correction of inaccurate personal data.
• Right to limit. You have the right to limit the use or disclosure of your sensitive personal data to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal data after you have exercised your right, unless you subsequently provide consent for the use of your sensitive personal data for additional purposes.
• Right to opt out. You have the right to opt out of our sale and/or sharing of your personal data.
• Sharing with third parties for their own direct marketing purposes. You have the right to request information regarding third parties to whom we have disclosed certain categories of personal data during the preceding year for the third parties’ direct marketing purposes under California’s “Shine the Light” law (Cal. Civ. Code §1798.83). If you wish to request information regarding such practices, please Contact Us. You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond. California’s “Shine the Light” law also provides you the right to opt-out of such disclosures on a going forward basis. You may exercise this right as referenced above under “right to opt out.”
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

F. How to Exercise Your Rights
Please send your request(s) to exercise your California privacy rights by following the instructions in Your Privacy Rights and Choices. For requests to know/access, delete, and correct, we will confirm receipt of your request within ten (10) business days. We will respond to your request within forty-five (45) calendar days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. For requests to opt out of sale/sharing and requests to limit, we will fulfill your request within fifteen (15) business days from the date we receive your request.

G. Notice of Right to Opt-out of Sale/Sharing
California residents may opt out of the “sale” or “sharing” of their personal data. As noted above, we may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms and Third-Party Business Partners for marketing and promotional purposes. You may opt out by following the instructions in Your Privacy Rights and Choices.

We do not knowingly sell or share the personal data of individuals under 16 years of age.

H. Notice of Financial Incentives
We may provide programs and offers, such as promotional campaigns, email newsletters, and referral programs. When you sign up for one of these programs, we typically ask you to provide your first and last name, email address, phone number, and birth month/day. Because these programs involve the collection of personal data and offering of certain benefits, they might be interpreted as a “financial incentive” program under California law. Such programs may include:

• Email Newsletter. When you subscribe to our newsletter, we may offer you special savings in the form of digital coupons for free or discounted products and announcements of sweepstakes, contests, and giveaways. You may opt in to the email newsletter on our Sites. To receive the newsletter, you must provide a valid email address. To opt out of our newsletter, please click “unsubscribe” located at the bottom of any email newsletter.
• Refer a Friend. We may offer digital coupons for free or discounted products, store credit, or gift cards through our Refer a Friend program. You may opt in to the program here. When you sign up, you will be asked to provide your email address.
• Brixton Rewards. We may provide special offers and benefits to customers who participate in our loyalty rewards program, Brixton Rewards, including digital coupons for free or discounted products, free shipping, and access to member-only savings events. You may opt in to Brixton Rewards here. When you sign up, you will be asked to provide your email address. You can also provide your name, address, phone number, and birth month/day. You may opt out at any time by email at customerservice@brixton.com . More information on our Brixton Rewards is found in the program’s terms and conditions here .

When you sign up for the above incentives, you will get a chance to review specific policies and terms related to the offer. If you withdraw from these programs, we will not contact you for at least twelve (12) months before requesting your participation again.

The value we place on personal data collected for these promotions varies, but we estimate it equals the additional spending per promotion participant, compared to individuals for whom we do not have email addresses, shopping history and preferences, or other collected information.

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12. Nevada Privacy Notice
We may “sell” personal data as that term is defined under Nevada law. Nevada residents have the right to opt out of any future sale of their personal data under Nevada SB 22 0. If you are a Nevada resident and would like to make such a request, please email us at privacy@brixton.com. You must include your full name, email address, and postal address in your email or mail request so that we can verify your Nevada residence and respond.

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13. Privacy Notice for Residents of Other States
This section contains additional information for residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia about personal data that we collect, how we use it, what sources it is derived from, and who we disclose it to, and provides information regarding your rights, and our responsibilities, under applicable laws and regulations.

The provisions contained within this section, in addition to the disclosures throughout the rest of this Privacy Policy, are intended to provide notices in compliance with the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Indiana Consumer Data Protection Act, the Iowa Consumer Data Protection Act, the Kentucky Data Protection Act, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Data Privacy Act, the New Jersey Privacy Act, the Oregon Consumer Data Privacy Act, the Rhode Island Data Transparency and Privacy Protection Act, the Tennessee Information Protection Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act, as may be amended from time to time (collectively, the “State Privacy Laws”).

This section does not apply to certain personal data that is collected from an individual in a business-to-business or employment context.

A. Personal Data Practices
The State Privacy Laws provide rights to residents of those states to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data. More detail about what kinds of personal data we collect or have collected, how we collect it, why we collect it, and who we may disclose it to is found in the Personal Data We Collect, Use, and Disclose; Sources of Personal Data; and Disclosure of Personal Data sections of this Privacy Policy.

We may “sell” personal data to (i) third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms; and (ii) Third-Party Business Partners for marketing and promotional purposes. 

B. Privacy Rights
If you are a Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia resident, you have the following rights under applicable law in relation to your personal data, subject to certain exceptions:  

• Right to know and access. You have the right to know what personal data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period. Residents of Delaware, Maryland, Minnesota, and Oregon have the right to obtain a list of specific third parties to which we have disclosed personal data.
• Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
• Right to correct inaccurate personal data. If you are a resident of Connecticut, Colorado, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Rhode Island, Tennessee, Texas, or Virginia, you have the right to request the correction of inaccurate personal data.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
• Right to opt out. You have the right to opt out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning you.
• Rights concerning sensitive personal data. If you are a Connecticut, Colorado, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Rhode Island, Tennessee, Texas, or Virginia resident, we cannot process your sensitive data or your sensitive data inferences, or use your personal data for certain purposes without your affirmative consent. If you are an Iowa or Utah resident, you have the right to opt out of having your sensitive personal data processed.

C. Exercising Your Rights
You may exercise any of the rights described in this section by following the instructions in Your Privacy Rights and Choices.

D. Appealing Decisions About Your Rights
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, and Virginia residents can appeal our decisions concerning privacy rights requests, as follows: 

• Colorado residents. If you are a Colorado resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Colorado’s Office of the Attorney General by phone at (720) 508-6000 or by submitting a form here.
• Connecticut residents. If you are a Connecticut resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.
• Delaware residents. If you are a Delaware resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Delaware’s Department of Justice by phone at (302) 683-8800 or by submitting a form here.
• Indiana residents. If you are an Indiana resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Indiana’s Office of the Attorney General by phone at (800) 457-8283 or by submitting a form here.
• Iowa residents. If you are an Iowa resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Iowa’s Office of the Attorney General by phone at (888) 777-4590 or by submitting a form here.
• Kentucky residents. If you are a Kentucky resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Kentucky’s Office of the Attorney General by phone at (888) 432-9257 or by submitting a form here.
• Maryland residents. If you are a Maryland resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Maryland’s Office of the Attorney General by phone at (888) 743-0023 or by submitting a form here.
• Minnesota residents. If you are a Minnesota resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Minnesota’s Office of the Attorney General by phone at (800) 657-3787 or by submitting a form here.
• Montana residents. If you are a Montana resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Montana’s Office of the Attorney General by phone at (406) 444-4500 or by submitting a form here.
• Nebraska residents. If you are a Nebraska resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Nebraska’s Office of the Attorney General by phone at (402) 471-2683 or by submitting a form here.
• New Hampshire residents. If you are a New Hampshire resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact New Hampshire’s Office of the Attorney General by phone at (603) 271-3658 or by submitting a form here.
• New Jersey residents. If you are a New Jersey resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact New Jersey’s Office of the Attorney General by phone at (800) 242-5846 or by submitting a form here.
• Oregon residents. If you are an Oregon resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Oregon’s Office of the Attorney General by phone at (877) 877-9392 or by submitting a form here.
• Rhode Island residents. If you are a Rhode Island resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an Rhode Island’s Office of the Attorney General by phone at (401) 274-4400 or by submitting a form here.
• Tennessee residents. If you are a Tennessee resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Tennessee’s Office of the Attorney General by phone at (615) 741-3491 or by submitting a form here.
• Texas residents. If you are a Texas resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Texas’ Office of the Attorney General by phone at (800) 621-0508 or by submitting a form here.
• Virginia residents. If you are a Virginia resident and want to appeal our decision about a request that you have previously made, please Contact Us or notify the Office of the Attorney General of Virginia online here. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Virginia’s Office of the Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or online here.

E. Notice of Bona Fide Loyalty Program for Colorado Residents
We may provide special offers and benefits to customers who participate in our loyalty program, Brixon Rewards, including digital coupons for free or discounted products, free shipping, and access to member-only savings events. You can join here. When you sign up, you will be asked to provide your email address. You can also provide your name, address, phone number, and birth month/day. You may opt out at any time by email at customerservice@brixton.com. More information on our Brixton Rewards is found in the program ’s terms and conditions here.

We may collect, use, and disclose each category of personal data listed above in Personal Data We Collect, Use, and Disclose in connection with Brixton Rewards. Please note that we do not collect sensitive personal data in connection with Brixton Rewards. We may sell the following categories of personal data to third party advertising platforms and analytics providers and Third-Party Business Partners for targeted advertising and promotional purposes in connection with Brixton Rewards: identifiers; commercial information; Internet or other electronic network activity information; and inferences.

Please note that if you exercise your right to delete your personal data with us, we will not be able to continue to offer Brixton Rewards to you because we will not be able to communicate with you about the program, accurately track your purchases to allocate rewards or discounts, and/or determine your eligibility for certain rewards or discounts.

The value we place on personal data collected for Brixton Rewards may vary, but we estimate it equals the additional spending per promotion participant, compared to individuals for whom we do not have email addresses, shopping history and preferences, or other collected information.

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14. International Privacy Notices
Certain jurisdictions provide individuals rights with respect to their personal data. Note that we are providing the following disclosures and rights regarding personal data in the interest of transparency and our commitment to privacy; such disclosures and rights are not intended to waive any exemptions under applicable laws. 

A. Notice to Individuals in the EEA, UK, and Switzerland
This notice applies to any individuals located within the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland about whom we may have collected personal data from any source, including through your use of our Services. We provide this notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with the General Data Protection Regulation (“GDPR”), the UK GDPR, Switzerland’s Federal Act on Data Protection, and related laws, regulations, and guidance from the European Union and/or its member states.

In certain circumstances, individuals located within the EEA, UK, and Switzerland have following privacy rights, subject to certain exceptions:

• Right to access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to erasure. You have the right to request that we erase your personal data in certain circumstances provided by law.
• Right to rectification. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to object. You have the right to object to our processing of your personal data.
• Right to restrict. You have the right to request that we restrict the processing of your personal data.
• Right to data portability. You have the right to request that we provide you with a copy of your personal data in a structured, machine-readable, and commonly used format.
• Right to withdraw consent. You have the right to withdraw your consent at any time where we rely on your consent to process your personal data.
• Right to lodge complaint. You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
• A list of EU supervisory authorities is available here.
• The relevant UK supervisory authority is the UK Information Commissioner’s Officer.
• The relevant Swiss supervisory authority is the Federal Data Protection and Information Commissioner.

To exercise your privacy rights described above, please use our webform. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

Brixton Europe B.V. is the controller of the personal data that is subject to this Notice. Contact information is below:

• Email: info.eu@brixton.com

B. Notice to Individuals in Canada
This notice applies to individuals in Canada about whom we may have collected personal data. We provide this notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and/or provincial privacy laws. For the purposes of this notice, "personal data" means information about an identifiable individual. Personal data does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work email address. Personal data also does not include information that has been de-identified, anonymized, or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other available information.

In certain circumstances, individuals in Canada are entitled to the following privacy rights:

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to Withdraw Consent. If you have already consented to the collection, use, and/or disclosure of your personal data, you may subsequently withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

To exercise your privacy rights described above, please use our webform. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

If you have any questions or concerns about our privacy practices, please email us at privacy@brixton.com. You may also contact the Office of the Privacy Commissioner at (800) 282-1376 if you are unsatisfied with our response to your privacy concern.

Brixton Canada Inc. is the controller of the personal data that is subject to this Notice.  Contact information is below.

• Email: cainfo@brixton.com
• Phone: 514-670-2237

C. Notice to Individuals in Australia or New Zealand
This notice applies to any individuals located within Australia and New Zealand about whom we may have collected personal data. We provide this notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Australia Privacy Act 1988 and the New Zealand Privacy Act 2020.

In certain circumstances, individuals located in Australia and New Zealand have the following privacy rights, subject to certain exceptions:

• Right to access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.

To exercise your privacy rights described above, please use our webform. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

Brixton Products Pty Ltd is the controller of the personal data that is subject to this Notice. Contact information is below.

• Email: ausinfo@brixton.com
• Phone: +61 2 9666 9822

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15. Changes to This Privacy Policy
We may change this Privacy Policy from time to time to reflect changes in our data practices or applicable law. We will notify you of any changes consistent with applicable law, including by posting the new Privacy Policy on this page and updating the “Effective Date” at the top of this Privacy Policy. We recommend periodically reviewing this page for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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16. Contact Us
If you have any questions about this Privacy Policy, you may email us at privacy@brixton.com or call us at (866) 264-4245.

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