Privacy Policy

Use of Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for using information, including but not limited to in the last 12 months, include the following:

• Facilitate and improve your in-store and online shopping experience;
• Provide the products and services you request, process transactions and send you related information, including confirmations and receipts;
• Process your registration with our websites or mobile applications, including verifying that your email address(es) are active and valid;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, offers, promotions, rewards and events and provide news and information we think will be of interest to you (for information about how to manage these communications, please see the “Your Rights and Choices” section below.
• Manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages;
• Improve our websites or mobile applications or other Tourneau products and services;
• Personalize your online experience and provide advertisements, content or features that match your profile and interests;
• Monitor and analyze trends, usage and activities;
• Process and deliver contest, promotion and sweepstakes entries and rewards;
• Link or combine with information we get from others to help understand your needs and provide you with better service;
• Contact you regarding your use of our websites and mobile applications and, in our discretion, changes to our policies;
• Provide you with notices related to our websites, mobile applications, and other Tourneau products and services
• Conduct research, including focus groups and surveys, regarding our websites, mobile applications, and other Tourneau products and services;
• Preventing and addressing fraud, breach of policies or terms, and threats of harm;
• Carry out any other business or commercial purposes at your discretion or with your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

Consent to Transfer Information

We are based in the United States and the information we collect is governed by U.S. law. By accessing the Services from outside the U.S., please be aware that information collected through the Services may be transferred, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Services or otherwise providing information to us constitutes your consent to the processing, transfer to and from, usage, sharing, and storage of information in the U.S. and other jurisdictions as set out in this Privacy Policy.

Sharing of Information

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of entities to whom we disclose information, including in the last 12 months, are as follows:

• Service Providers. We share information with entities that process the information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law;
• Vendors. We share information with vendors, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Advertising and Analytics” section below;
• Partners. We share information with our partners for purposes of offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
• Public Forums. We share information you make public through the Services, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information that you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below;
• Security and Compelled Disclosure. We share information to comply with applicable law or other legal process, and where required, in response to lawful requests of public authorities, including to meet national security or law enforcement requirements. We also share information if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, life, health, security and safety of us, the Services, or anyone else;
• Affiliates. We may share information with our related entities including our parent and sister companies for internal business purposes. For example, we share information with our affiliates for customer support, marketing, and technical operations;
• Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, amalgamation or any other type of acquisition of all or any portion of Tourneau assets, financing, disposal, conveyance or transfer of all or a portion of our business to another business;
• Facilitating Requests. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Services.
• Consent. We share information with notice to you and your consent.

We may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

Sweepstakes, Contests, and Promotions

We may offer sweepstakes, contests, surveys and other promotions (each, a “Promotion”) that may require registration. If you voluntarily enter a Promotion, we share information as set out in the official rules that govern the Promotion as well as for the administration of such Promotion, such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. Tourneau may offer opportunities to enter a contest or sweepstakes or other feature that we offer jointly with a separate entity. As a result of your participation in such feature, your information may be shared with the other entity that is jointly offering the feature, which will be disclosed at the time your information is collected.

Advertising and Analytics

We use analytics services, such as Google Analytics, to help us understand how users access and use the Services. In addition we work with agencies, advertisers, ad networks, and other technology services to serve advertisements on our behalf about our products across the Internet. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Services (including website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your browsing of the websites and mobile applications across time and services for purposes of associating different devices you use and deliver advertising and content relevant to your interests on our websites and other websites (“Internet-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have browsed our Services or are identified in one or more of our databases (“Matched Ads”). This is done by uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Services, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of the Facebook Custom Audiences. Some technology services, such as LiveRamp, may provide us with their own data, which is then uploaded into another technology service for matching common factors between those datasets. This information is used for marketing purposes and to suggest to you relevant products offered by another retailer.

As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. This Privacy Policy does not cover any use of information that such separate entities themselves may have collected from you (e.g., type of browser, operating system, domain name, day and time of visit, page(s) visited) or the methods used by such separate entities to collect that information (e.g., cookies, web beacons and clear gifs). We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Services and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information We Collect Automatically” and “Your Rights and Choices” sections.

Social Media and Technology Integrations

We offer parts of our Services through websites, platforms and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Services. Some examples include:

• Links. Our Services include links that hyperlink to websites, platforms, and other services not operated or controlled by us.
• Brand Pages and Chatbots. We may offer our content through social media which may also provide you the opportunity to participate and post content publicly (such as through our brand page or via our chatbot on Facebook Messenger). Any information you provide to us when you engage our content (such as your username and profile picture) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Services on social media (e.g., by using a hashtag associated with Tourneau in a tweet or post), we may use your reference on or in connection with our Services.
• Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Services that allows you to “like” or “share” our website content on other websites or services; to log-in to our websites using your social media username and password; to transmit content to our websites from your account on social media; and to otherwise connect our websites on social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
• Voice-Activated Skills. We may offer skills through Alexa, Google Home, and other voice-activated platforms, and use the voice processing and other technologies discussed in the “Information We Collect Automatically” section above. Any information that you provide to us when you engage our skills is treated in accordance with this Privacy Policy.

Please note that when you interact with other entities, including when you leave our Services, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Data Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we implement and maintain reasonable physical, technical, and administrative procedures to safeguard and secure information collected. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of information about you.

Children's Privacy

The Services are intended for a general audience and are not targeted to children under the age of thirteen (13). We do not knowingly gather any personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at privacy@tourneau.com and we will remove the data to the extent required by applicable laws.

In California, we do not knowingly “sell” personal information of minors under 16 years old.

If you are a California resident under 18 years old and you are registered with the Services, you can ask us to remove content or information you have posted to any of the Services. Email us at privacy@tourneau.com with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed.

Your Right and Choices

A. Account Information

You may access, update, or remove certain information that you have provided to us at any time by logging into your account and navigating to the “My Account” page or by emailing us at customerservice@tourneau.com. We may require additional information from you to allow us to confirm your identity. Please also note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

B. Tracking Technology Choices

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you can use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Accordingly, unless and until the law is interpreted to require us to do so, Tourneau does not monitor or take action with respect to “Do Not Track” signals. To find out more about “Do Not Track,” you may wish to visit All About Do Not Track (DNT).
• App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app or website by uninstalling the app or by adjusting the device’s location services and/or Bluetooth settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

Please be aware that if you disable or remove tracking technologies some parts of the Services may not function correctly.

C. Communications.

• Communication from Our Partners. You can opt-out of having your information shared with our partners by sending an email to customerservice@tourneau.com and specifying that you do not want your information shared with our partners.
• Promotional Communications. You can opt-out of receiving promotional communications from us at any time by doing the following:
  • To opt out of direct mail (such as catalogs and post cards): Email us at customerservice@tourneau.com.
  • To opt out of promotional emails: Follow the instructions provided in those communications by clicking on the unsubscribe link, or email us at customerservice@tourneau.com with the word UNSUBSCRIBE in the subject field of the email. Please note that even if you opt out of receiving promotional communications, you cannot opt out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
  • If you sign up to receive SMS or MMS messages that may be offered on our websites, you may unsubscribe from any SMS or MMS messages received by replying “STOP” or by sending an email to customerservice@tourneau.com and specifying you want to opt out of text messages.
• Push Notifications. If you have opted-in to receive push notification on your device, you can opt out at any time by adjusting the permission in your device or uninstalling our app.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

D. Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics here and by Google Analytics for certain Display Advertising or the Google Display Network here.

Microsoft provides tools to allow you to opt out of the use of certain information collected by Microsoft Ads. Learn more here.

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt-out of receiving targeted ads. Most of these companies participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based ads. To learn more about the DAA AdChoices Program and how to opt-out, please visit: (i) for website targeted ads from DAA participants, click here; and (ii) for app targeted ads from DAA participants, click here. Bounce Exchange, Inc. (“BounceX” or “Bounce Exchange”) is a behavioral automation software and analytics company that help drive higher engagement from their website visitors. To learn more about opting out of Bounce Exchange, click here. Criteo helps brands, e-commerce sites and other advertisers promote their products and services. To learn more about opting out of Criteo, click here. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (NAI). The NAI has developed a tool that allows consumers to opt out of targeted advertising delivered by NAI members' ad networks. To learn more about opting out of targeted advertising or to use the tool, click here. Please be aware that, even if you are able to opt out of certain kinds of targeted advertising, you will continue to receive generic ads.

To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out.

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device setting and selecting “Limit Ad Tracking” (iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

Your Nevada Rights

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at nevadarights@tourneau.com.
 

Terms of Use

Additional Terms and conditions

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Tourneau, LLC.
Attn: Privacy Policy
663 Fifth Avenue
New York, NY 10022
Phone: 800.348.3332
customerservice@tourneau.com

Additional Disclosures for California Residents

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

A. California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

• Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account.
• Customer records, billing and shipping address, and credit or debit card information.
• Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
• Commercial information, including purchases and engagement with the Services.
• Internet activity, including your interactions with our Service.
• Audio or visual data, including pictures or vides you post on our Service.
• Geolocation data, including location enabled services such as WiFi and GPS.
• Employment and education data, including information you provide when you apply for a job with us.
• Inferences, including information about your interests, preferences and favorites.

For more information on information we collect, including the sources we receive information from, review the Collection of Information section. We collect and use these categories of personal information for the business purposes described in the Use of Information section, including to provide and manage our Services.

Tourneau does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the Analytics and Advertising section as a “sale,”, we will comply with applicable law as to such activity. Tourneau discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review the Sharing of Information section for more detail about the parties we have shared information with.

B. Right to Know and Delete

If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and
• The business or commercial purpose for collecting or selling the personal information.

You also have the right to request the specific pieces of personal information we have collected about you.

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our online form available here, call our toll free number at (800)348-3332, or email us at privacy@tourneau.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.

C. Do Not Sell My Personal Information.

To the extent Tourneau sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out by calling our toll-free number at (800) 348-3332, or emailing us at privacy@tourneau.com.

D. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

E. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

F. Financial Incentives.

Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.

G. Minors.

We do not knowingly sell information of minors under 16 who are residents of California without their affirmative authorization, or the affirmative authorization of their parent or guardian for minors under 13.

California residents who are under 18 years of age and registered to use the Services may request removal of any content posted by them on the Service. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Minor” request. We may require additional information from you to allow us to verify your identity as well as details about where the content is posted. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

G. Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the “Contact Us” section above and specify that you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.