Hunter Bell Inc. d/b/a Hunter Bell respects your privacy. This Privacy Policy (“Policy”) describes how we may collect, use, and share your Personal Information. It applies to Personal Information we obtain in various contexts, both online and offline, including when you access or use our websites or other online services we operate that link to this Policy (sometimes referred to individually as a “Service” and collectively as the “Services”), communicate with us, engage with us on social media, or otherwise interact with us. The Policy also explains related rights you may have.

You may see other privacy notices when we collect your Personal Information for specific purposes. Those notices supplement this Policy. This Policy also contains statements specific to residents of particular geographic regions that have their own applicable laws. Those statements supplement the rest of this Policy, but to the extent they differ from other parts of the Policy, they govern in their respective regions. 

By using a Service, you consent to the practices described in this Policy. 

When we say “Personal Information,” we mean information that can reasonably be linked to a particular individual or household. Generally speaking, your Personal Information includes your unique identifiers (full name, phone number, email address, username, etc.) and information about your characteristics, conditions, or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you. 

“Non-Personal Information,” on the other hand, has been anonymized, aggregated, or de-identified such that it cannot reasonably be linked to a particular individual or household.

Categories

The Categories of Personal Information that we collect about you depend on how you interact with us, and they may include the following: 

• “Identifiers,” such as first and last name, address, email address, phone number, username, signature, IP address, cookie ID, and similar information. 
• “Demographic Information,” such as age. Demographic Information may include legally protected classifications.
• “Financial Information,” such as payment card information. (For your security, we do not store full payment card numbers; a secure payment processor processes transactions on our behalf.)
• “Commercial Information,” such as products purchased, obtained, or considered, or information about how you use our Service. 
• “Professional or Employment Information,” such as job title and business or employer name (if, for example, you interact with us on behalf of an organization that is our vendor or business partner.) 
• “Device/Browser Information” and “Internet Activity,” such as device or browser type and configuration, comments or other content posted to our Service or shared with us via email, browsing activity, social media content, and interactions with marketing communications sent on our behalf. 
• “Profile Information,” which means inferences about you drawn from other information.
• “Job Applicant Information,” if you apply for a job with us, such as education and employment history and any other information you provide in connection with applying and interviewing for employment at Hunter Bell. This may also include information we collect from other sources as part of a background check. 

Collection Sources:

From You When You Provide It. We may collect Personal Information from you directly when you fill out a form on the Service; create a user account; use the Service; place an order; subscribe to receive emails, catalogs, or newsletters from us; or otherwise communicate with us.

Automatically From Your Device. Like most online services, our Services may passively collect some information from users’ devices to make features function correctly, customize the user experience, understand how the Service is being used, measure the effectiveness of marketing efforts, or deliver personalized advertising or technologies, as explained in this Policy. In some cases, we limit this type of collection to Non-Personal Information. However, this data may include Personal Information such as online Identifiers, Internet Activity, and Commercial Information.

From Third Party Sources. We may obtain information about you from other sources. For example, we may collect Identifiers, Professional or Employment Information, or Internet Activity that you have chosen to disclose on social media platforms.We may combine information collected from other sources with information collected from you or your device. To the extent the information, alone or in combination, constitutes Personal Information, we will treat it as Personal Information as described in this Policy. 

We use Personal Information for the following purposes: 

• To process orders and payments
• To maintain your account
• To present our Services and analyze how they are used; 
• To secure our Services and physical locations against fraud, malicious activity, or conduct that may violate our terms or use; 
• To personalize and improve your experience with the Service;
• To provide you with information, products, or services that you request from us
• To show you ads tailored to your preferences; 
• To notify you about changes to our Service and any products or services we offer or provide through them; 
• To allow you to participate in interactive features of the Service;
• To provide you with periodic product newsletters, catalogs, and offers; 
• To contact you and provide you with help if you have customer service issues; 
• To contact you to fill out surveys and participate in other types of market research; 
• To notify you of new products or services we think you might be interested in;
• To comply without legal obligations; 
• In any other way we may describe when we collect the information; and 
• For any other purpose, with your consent

We may use Non-Personal Information for any purpose. 

Vendors

We may share Personal Information with contractors, service providers, and other vendors who assist or support us in providing the Services. Examples of these third-party services may include hosting our site, storing data, performing analytics, processing payments, or sending marketing communications. Our agreements with vendors prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing services to us.

Analytics, Social Media, and Advertising Partners

We may share your Personal Information with analytics providers, advertising networks, or social media companies to measure the performance of our Service or marketing efforts, offer social media features, or facilitate interest-based advertising. This sharing may involve browser cookies and similar technologies placed through our partner's Service, as explained in this Policy. For example, when you visit our site, our partner’s cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other identifiers, Device Information, and Internet Activity. 

Mandatory Disclosures and Legal Proceedings

We may have a legal obligation to disclose Personal Information to government authorities or other third parties pursuant to a valid regulatory request, subpoena, or court order. We may also need to disclose and otherwise process your Personal Information by the applicable law to prevent physical harm or financial loss, protect the vital interests of a person, enforce our various policies or terms of use, protect our property, services, and legal rights, prevent fraud, support auditing, compliance, and corporate governance functions, or comply with applicable law. 

With Your Direction or Consent

We will share your Personal Information with other third parties as you may direct or otherwise consent. 

Our Services are not directed to children under the age of 16. We do not knowingly collect, maintain, or process children’s Personal Information unless the child’s parent or guardian consents and provides the information. If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will immediately delete the information. If you believe that we might have any Personal Information from a child under the age of 16, please contact us via the information set forth in Section 17 of the Policy.

For Italian Customers: Where consent is required to process Personal Information, the consent of visitors under the age of 14 shall be expressed by the child’s parent or legal guardian.

What are Cookies? 

A browser cookie is a small piece of data that a website stores in your device’s browser. It holds information that the site uses to function properly, remember your preferences, or personalize your experience. A typical cookie contains a cookie ID, which is a unique string of characters used to identify your browser during the browsing session, or in some cases, during subsequent browsing sessions. Cookies, cookie IDs, and similar pieces of data may be considered Personal Information (Identifiers and Internet Activity) under applicable law. 

Other online technologies, similar to cookies, may allow users to be identified and tracked across multiple browsing sessions and, in some cases, tracked across different websites and online services for marketing or advertising purposes. These technologies include but are not necessarily limited to, pixels, web beacons, and scripts (collectively with browser cookies, “Cookies”).

Cookies May Be Used On Our Services 

Our Service uses “first-party” Cookies, which are set by our web domain (such as hunterbellnyc.com). Our Service also accesses some " third-party” Cookies, which are set by other web domains associated with our vendors or partners. This means that when you visit our site, your browser may automatically connect to our partner’s web server, as well as ours, and provide our partner with access to your online Identifiers and Internet Activity, including information about how you use our site.

Cookies are used on our Service for the following purposes: 

• Essential: Essential Cookies are necessary for site security and to enable you to move around our site and use its features.
• Preferences: Preference Cookies allow us to remember your preferences and personalize the Service during browsing sessions or across browsing sessions. 
• Analytics: Analytic Cookies allow us to analyze the use of our Site or Service to evaluate and improve performance. 
• Marketing: Also known as “Targeting” Cookies, these are used to display ads or other content based on your interests and may be used by our partners to track your activity across different online services.

You have several choices regarding the use of information on our Site:

Opt-Out of Marketing Communications

You may opt-out of our marketing emails by using the unsubscribe link provided in the email.

Your Browser and Device Settings

See Section 7 for options to restrict Cookies. 

You are not required to register an account with us in order to make a purchase, but you can do so if you wish.

We may send you marketing material via email, text message, or direct mail (with your consent where required). You can update your marketing preferences through the applicable processes, including by replying STOP to a text/SMS message, clicking on the unsubscribe link in email marketing messaging, or contacting us at privacy@hunterbellnyc.com.

Please see the “Cookies” section of the Policy for more information about how to update your preferences for information that the Site collects automatically, including links to opt-out of targeting and advertising cookies.

For our customers in the United States, you can request that we not share your Personal Information with our Data Providers by following the instructions in the “How We Share Your Personal Information” Section above.

Area-Specific Rights and Choices

If you are a resident of the States of California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, or Virginia, or a resident of the EEA, United Kingdom, Italy, Switzerland, or Australia, you may have other rights and choices as set forth in this Policy. 

Our online Services may contain links to third-party websites, products, or services. If you use these links, you will leave our site. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by us of the third party, the third-party website, or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

We value the security of your Personal Information, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. 

Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention is required or permitted by law. Please note that in many situations, we must retain all, or a portion, of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes. 

We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”). If you are located in the EEA, the U.K., or Switzerland, you have the rights as outlined below. We will respond to any rights request by local legal regulations. If you wish to make a request regarding any of the rights below, please contact us using the methods provided at the end of the  Policy.

Right of access

• You have the right to access information about the categories of personal information we have collected about you. You may also request a copy of the personal information we have collected, and upon request, we will provide this information to you in electronic form or transfer it to a third party. Depending on your jurisdiction, you may request a list of our service providers who may receive your personal information, including particular recipients in third countries or international organizations, where possible, the predicted period that the personal information will be stored, or, if not possible, the criteria used to determine that period, your rights, etc.

Right to rectification

• You may have the right to rectify, correct, or complete your personal information if inaccurate or incomplete.

Right to erasure (‘right to be forgotten)

You may have the right to the erasure of your personal information in certain circumstances. For examples, see below:

• Your personal information is no longer necessary for the purposes for which it was processed
• You withdraw your consent on which the processing is based, and we have no other legal ground for the processing
• You object to the processing, and there are no overriding legitimate grounds for the processing
• Your personal information has been unlawfully processed
• Your personal information has to be erased for compliance with a legal obligation to which we are subject
  

This right shall not apply to the extent that processing is necessary for the below purposes.

• For exercising the right of freedom of expression and information
• For compliance with a legal obligation which requires processing by a law to which we are subject
• For the performance of a task carried out in the public interest
• For the establishment, exercise, or defense of our legal claims

Right to restriction of processing

You may have the right to restrict the processing for the following reasons:

• You contest the accuracy of your personal information for a period enabling us to verify the accuracy of the personal information
• The processing is unlawful, and you oppose the erasure of the personal information and request the restriction of their use.
• We no longer need the personal information for the purposes of the processing, but they are required by you for the establishment, exercise, or defense of legal claims.
• You exercised your right to object to processing pending the verification of whether our legitimate grounds override yours.

Right to object to processing based on legitimate interests.

• You may have the right to object, on grounds relating to your particular situation, to the processing of your personal information, which is based on our legitimate interests. We will stop processing the personal information unless we have compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims. If personal information is processed for direct marketing purposes, including profiling, you may object at any time.

Right to obtain information about international data transfers

• You have the right to obtain information about, and a copy of, the safeguards we use to transfer personal data across borders to third countries.

Right to lodge a complaint with a supervisory authority.

• We are committed to working with you in the event that you have a complaint of concern about privacy. If you need help lodging a complaint, you can contact us through the contact methods provided at the end of the Policy. You may also have the right to lodge a complaint with a supervisory authority. Contact details for data protection authorities are available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Contact information for the UK Information Commissioner is here: https://ico.org.uk/global/contact-us/contact-us-public/ Contact information for the Swiss Federal Data Protection and Information Commissioner is here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.

• For Italian customers, you may lodge a complaint with the Office of the Garante per la Protezione dei Dati Personali (the “Italian Data Protection Authority”). For further information about your rights and our obligations regarding your Personal Data, you can also contact the Italian Data Protection Authority at the following addresses: Piazza Venezia n. 11 – 00187 (Roma), tel. 06.696771, email: garante@gpdp.it; or you can visit the following link: https://www.garanteprivacy.it/.

• For Australian customers: you may be able to lodge a complaint with the Office of the Australian Information Commissioner: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint.

• For UK customers: The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your Personal Data, as well as handle any complaints that you have about our processing of your Personal Data. For further details, please see https://ico.org.uk/.

• For Irish customers: The Data Protection Commission of Ireland is the supervisory authority in Ireland and can provide further information about your rights and our obligations in relation to your Personal Data, as well as handle any complaints that you may have about our processing of your Personal Data. For further details, please see https://www.dataprotection.ie/.

We collect and use personal information when we have a lawful basis to do so, as follows:

• At your direction and with your consent.
• To fulfill contracts we might have with you.
• For other legitimate business purposes.
• To comply with a legal obligation.
• To protect your vital interests or the vital interests of another natural person.

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is any change in the purposes for which we collect your personal information, we will inform you of such change. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purposes, please contact us through the contact methods provided at the end of this Privacy Policy.

Your Privacy Rights: For Residents of California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, and Virginia

The rights available to you may differ depending on your U.S. state of residence. We will respond to any rights request in accordance with local legal regulations. If you wish to make a request regarding any of the rights below, please contact us at privacy@hunterbellnyc.com.

Right of access/Right to know

• Residents of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia may have the right to get confirmation about whether or not your personal information is being processed. If so, you have the right to access specific pieces of personal information and other information, such as the purposes, the categories of personal information, and the recipients (or categories of recipients) to whom the personal information has been or will be disclosed.  You may make such a request by contacting us using the information below. You also have the right to know if we have sold or disclosed your personal information. You may also request a copy of the personal information we have collected, and upon request, we will provide this information to you in electronic form.
• Where feasible and permitted by law, we will provide a copy of the personal information we are processing. For any further copies, we may charge a reasonable fee based on administrative costs. If you make the request by electronic means, and unless otherwise requested, the information shall be provided in electronic form.
• Oregon residents may also request a list of third parties, other than individuals, to which we have disclosed their data.

Right to correction or completion

• Residents of California, Colorado, Connecticut, Montana, Oregon, Texas, or Virginia may have the right to rectify, correct, or complete your personal information if inaccurate or incomplete.

Right to data portability

• Residents of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia have the right to receive the personal information you gave us in a structured, commonly used, and machine-readable format. You have the right to send that personal information to another controller if the processing is based on consent pursuant to or on a contract and is carried out by automated means.

Automated individual decision-making, including profiling

• Residents of California, Colorado, Connecticut, Montana, Oregon, Texas, or Virginia may have the right not to be subject to a decision based solely on automated processing, including profiling, except under certain exceptions under local law.

Right to withdraw consent

• Where the processing of personal information is based on your consent, residents of California, Colorado, Connecticut, Montana, and Oregon may have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

Right to anonymity

• You may also have a right to request anonymity. This means that your personal information will not be collected or processed. If you choose to exercise this right, we may not be able to provide you with your requested goods or services.

 Right to opt out of the sale of your personal information or the sharing of your personal information for targeted advertising purposes

• Though we do not share your personal information with third parties for their direct marketing purposes, and we do not sell the personal information of children under 16 years old, if you are a resident of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia, you may have the right to opt-out of the selling of your personal information and/or the sharing of your personal information to third parties for targeted advertising purposes. 

Right to request deletion 

• If you are a resident of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia, you also have a right to request that we delete your personal information under certain circumstances, subject to a number of exceptions.

Right to Limit the Use and Disclosure of Your Sensitive Personal Information

• Residents of California have the right to limit our use of your sensitive personal information to that which is necessary to perform services, provide the goods reasonably expected, or as authorized under applicable regulations. We do not use sensitive personal information beyond the purpose for which it was provided, so we do not offer the right to limit it.

Right to not be discriminated against

• Residents of California, Colorado, Connecticut, Utah, or Virginia have the right not to be discriminated against for exercising any of the rights afforded to them under applicable privacy laws. This includes not being discriminated against in connection with financial incentives, which we may offer occasionally. See our Financial Incentives section below.

Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. Residents of California, Colorado, Connecticut, Montana, Oregon, and Texas may designate an authorized agent to make a request on your behalf. Such authorized agents must have permission to submit requests on your behalf. We may deny a request from an agent that does not submit proof that you have authorized them to act on your behalf.

We may have a reason under the law why we do not have to comply with your request or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response. Residents of California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, or Virginia can exercise their rights to appeal our refusal to act within a reasonable time by contacting us using the details set out in the Contact Us section below.

Financial Incentives

For reference, we may offer various financial incentives occasionally, primarily requesting your identifiers and contact information as part of an offer. The terms of the financial incentive, including the personal information requested in connection with the offer, will be provided at the time you sign up for the financial incentive. We have calculated the value of the financial incentive by using the expense related to the offer, and the value of your data is the value of the offer presented to you. You may withdraw from any of the financial incentives at any time, following the instructions provided. For offers involving email, you may unsubscribe via the “unsubscribe” link in any marketing email you have received.

Notice at Collection for California Residents. This section describes our practices currently and during the past twelve (12) months regarding the Personal Information of California residents.

• Information practices.  The following summarizes the categories of Personal Information we collect by reference to the statutory categories specified in the California Consumer Privacy Act (“CCPA”), the sources from which we collect it, and the categories of third parties to whom we may disclose it for a business purpose:

• identifiers, such as contact information, biographical information, and data about others, from you, data providers, and public sources, which we disclose to vendors, advertising partners, payment processors, and data providers
• commercial information, such as profile data, payment and transactional data, marketing data, and online activity data, from you, data providers, public sources, and automatic collection, which we disclose to vendors, advertising partners, and payment processors
• financial information, such as payment and transactional data and information about products you purchase, from you, data providers, and public sources, which we disclose to vendors and payment processors
• online identifiers, such as profile data, device data, and online activity data, from you, data providers, and public sources, and through automatic collection, which we disclose to vendors, advertising partners, and payment processors
• internet and network information, such as marketing data, device data and online activity data, through automatic collection, which we disclose to vendors, advertising partners, and payment processors
• geolocation data, such as the general location of your device, through automatic collection, which we disclose to vendors, advertising partners, and payment processors
• protected classification characteristics, such as profile data and publicly available information, from you, data providers, and public sources, which we disclose to vendors
• the personal information described in California’s customer records law, including contact information, profile data, physical characteristics (e.g., dress size), credit or debit card numbers, and other transaction data, from you, data providers, and public sources, which we disclose to vendors, payment processors, and data providers
• sensitive personal information, such as your Hunter Bell username/password credentials and payment details for example.
• inferences about you that we may derive from any of the categories of Personal Information above, which we disclose to vendors and advertising partners

Information you voluntarily provide to us, such as in free-form web forms or via email, may contain other categories of Personal Information not described below. We describe (a) the business/commercial purposes for which we collect Personal Information and (b) the categories of third parties to whom we disclose your Personal Information and the purposes for those disclosures in other Sections of this Policy.

• Sales/Sharing of Personal Information.  We use and disclose Personal Information for targeted advertising purposes as described in the Opt-out section above and for data as described above. The CCPA may classify these activities as the “sale” or “sharing” of Personal Information from which you have the right to opt-out. You may request to opt-out by clicking the “Do Not Sell My Info” link in that Section or by emailing us at privacy@hunterbellnyc.com.
• Global Privacy Control. If you have enabled a legally recognized browser-based opt-out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance with and to the extent required by applicable law. You will need to turn this on for each browser you use. 
• Children. While our Site is not directed to children under 16, we are required to inform you that we have no actual knowledge that we “sell” or “share” the Personal Information of California residents under 16, as the CCPA defines those terms.
• Sensitive personal information. We do not use or disclose sensitive personal information (as defined by the CCPA) for purposes that California residents have a right to limit under the CCPA.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Deidentified data. We do not to attempt to reidentify deidentified information that we derive from Personal Information, except that we may do so for the purpose of testing whether our deidentification processes comply with applicable law.

If a company shares “personal information” (as defined in California’s “Shine the Light” law, Civil Code § 1798.83) with third parties for their direct marketing purposes (e.g., to send offers and information that may be of interest to you), California law requires either providing a mechanism by which consumers can obtain more information about such sharing over the prior calendar year, or providing a mechanism by which consumers can opt out of such sharing. We do not share your personal information with third parties for their direct marketing purposes.

Residents of the State of Nevada have the right to opt-out of the sale of certain pieces of their information to third parties. As defined by Nevada law, we do not currently engage in such sales. If you would like more information about our data-sharing practices, you may contact us at privacy@hunterbellnyc.com.

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers. It allows you to opt-out of tracking by websites and online services. The global standard DNT technology is not yet finalized, and not all browsers support DNT. Therefore, we do not recognize DNT signals and do not respond to them.

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time, and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide by and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website.

If you have any questions or concerns about this Policy, please contact us via privacy@hunterbellnyc.com if you want to report any data security violations to us, please contact us at the following address, or email.

Hunter Bell Inc.

Attn: Privacy

5433 Westheimer Road, Suite 200

Houston, TX 77056

USA

privacy@hunterbellnyc.com. 

By submitting Personal Information through our Site or Services, you acknowledge that we handle your Personal Information under the terms of this Policy, and you understand that our collection, use, and disclosure of your Personal Information is as set out in this Policy. This Policy also sets out your rights regarding your Personal Information.