PRIVACY POLICY / NOTICE AT COLLECTION

Thread Wallets Privacy Policy

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This privacy policy (“Privacy Policy”) is intended to act as a Notice at Collection (where required by applicable law) and describes how your personally identifiable information as defined under applicable law(s) (also known as “personal data” or “personal information” and hereinafter referred to as “PII”) is collected, used, and shared when you visit or make a purchase from www.threadwallets.com (the “Site”). By using this Site, you are consenting (where allowed by applicable law) to the practices described in this Privacy Policy.

 

WHAT PII DO WE COLLECT?

When you make a purchase or attempt to make a purchase through the Site, we may collect certain information from you, including your name, billing address, shipping address, payment information, email address, and phone number. We refer to this information as “Order Information”.

When you visit the Site, we may automatically collect certain PII about your device, including information about your web browser, IP address, time zone, and some of the cookies and/or related technologies that are installed on your device. Additionally, as you browse the Site, we may collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. More information about Device Information can be read below under the “Cookies” section.

When we talk about PII in this Privacy Policy, we are generally talking both about Order Information and Device Information. Thread Wallets does not process sensitive PII, as defined by applicable law(s).

HOW DO WE USE YOUR PII?

We or third parties we work with may use the Order Information and/or Device Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we may use this PII to:

• Communicate with you;
• Screen our orders for potential risk or fraud; and
• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We or third parties we work with may use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

We or third parties we work with may also use Device Information to help run online advertisements including retargeting ads or to identify your email address for marketing purposes. As discussed below in the “SHARING YOUR PII” section, you may have the right to opt-out of this. Additional details regarding these uses are also included in the “COOKIES” section below.

SHARING YOUR PII

We share your PII with third parties to help us use your PII, as described above. More specifically, we may share PII with third parties for reasons such as the following:

• To process orders and facilitate our services, including customer or warranty services;
• To better facilitate and improve our business functions, including the operation and security of the Site, data analytics, and/or data management and storage;
• For assistance with marketing purposes, communications, and/or product reviews;
• To any other third party with your prior consent to do so;
• If Thread Wallets is involved in a merger, acquisition, or sale of all or a portion of its assets, which change you will be notified of as necessary under applicable law(s); or
• As otherwise required by law.

For example, we use Shopify to power our online store--you can read more about how Shopify uses your PII here: https://www.shopify.com/legal/privacy. Shopify may use automated decision-making to conduct risk and fraud screening. We also use tools and technologies such as Google Analytics to help us understand how our customers use the Site (you can read more about how Google uses your PII at https://www.google.com/intl/en/policies/privacy/, and you can also opt-out of Google Analytics at https://tools.google.com/dlpage/gaoptout). Thread is not responsible for third-party sites or the PII they collect.

Some of the sharing we do may be through the use of cookies or related technologies, which are discussed in more detail below.

Finally, we may also share your PII to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, to investigate fraud, to protect your safety or the safety of others, or to otherwise protect our rights.

We do not sell PII for money. However, applicable law(s) may define the “sale” of personal data more broadly than as an exchange for money. Where that is the case, or if it is shared with a third party for cross context behavioral advertising or targeted advertising, you may have the right to opt out of the applicable sale and/or sharing of your information here: Do Not Sell or Share My Personal Information

COOKIES

We and/or third parties may collect Device Information using the following technologies or others similar to them:

• “Cookies” are data files that are placed on your device and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons”, “tags”, and “pixels” are electronic files that may be used to record information about how you browse the Site and/or interact with related advertising, whether you’ve opened applicable communications, etc.

These technologies and others like them are hereinafter collectively referred to as “cookies”. By using this Site you consent, where allowed by applicable law(s), to the use of cookies as set out herein.

While the exact cookies can change from time to time, the applicable categories of cookies we or those we work in connection with (collectively “we” or “us” for the purpose of this list) may use include cookies that:

• Are essential to the operation, functionality, legal compliance, and/or security of our Site;
• Facilitate our business functions, including order fulfillment and related services, data management, diagnostics, and/or analytics;
• Help to improve the performance and/or security of our Site;
• Allow us to communicate with you, including for product reviews, surveys, or to let you know a product is back in stock;
• Allow us to facilitate advertising, to provide you with advertising relevant to you, and/or to measure the efficacy of our advertising or communications;
• Remind us who you are and help us to better understand, track, and save your preferences and/or purchase history;
• Help us better understand your visits to the Site, including how you interact with the Site and/or what websites or search terms referred you to the Site; or
• Help us better understand how you access our Site, your general location, and/or to distinguish between different visitors to the Site.

As noted above, our Site is hosted by Shopify, and Shopify may choose to use its own cookies (as defined above) to collect data. We are not responsible for these cookies, but they may be viewed at https://www.shopify.com/legal/cookies.

As also described above, we may use your PII to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of some targeted advertising by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• Bing: https://advertise https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
• The Digital Advertising Alliance’s opt-out portal: http://optout.aboutads.info

We note that these and other third-party links included herein are not in Thread Wallets’ control. Thread is not responsible for third-party sites.

Again, you may also have the right to opt out of sharing for the purpose of cross context behavioral advertising or targeted advertising under applicable law, as set out above under the section titled “SHARING YOUR PII” or here: Do Not Sell or Share My Personal Information.

Thread is not responsible for any PII collected by third parties’ cookies (as defined above) from sites other than Thread’s own. In addition, your browser may already contain cookies placed by third-party sites, including various social media platforms. Thread is not responsible for the PII such cookies may collect or what they may do with it.

YOUR PRIVACY RIGHTS

We strive to process your PII in accordance with applicable data privacy laws, many of which create a variety of privacy rights for covered consumers.  These rights may include the following:

 

PII We Collect

You may have the right to know what kinds of PII we collect and our business purposes for that collection. We make this information available to you herein, including in the “What PII Do We Collect?” section of the Privacy Policy. You also have the right to know how PII is obtained, how it is used, and our business purposes for that use. We also make this information available to you herein, including in the section titled “How Do We Use Your PII?”.

 

You may have the right to know if we share your PII with any third parties. We may share PII with our providers that perform services on our behalf. In addition, we may share PII with third parties for other notified purposes, as permitted by applicable law. For example, we share your personal data with your consent or to complete any transaction or provide any product you have requested or authorized. For more information on how we share your PII, refer to the “Sharing Your PII” section of the Privacy Policy.

 

Rights to PII

You may have the right to request access to certain information about our collection and use of your PII over the past 12 months (or as otherwise set out by applicable law). Once we receive and confirm your verifiable consumer request (discussed more below), we may disclose to you:

• The categories of PII we collected about you;
• The categories of sources for the PII we collected about you;
• Our business or commercial purpose for collecting that PII;
• The categories of third parties with whom we share that PII; and
• The specific pieces of PII we collected about you.

You may have the right to request that we delete any of your PII that we collected from you and retained. Once we receive and confirm your verifiable consumer request (discussed more below), we may delete your PII from our records, unless we need the PII for exceptions provided under applicable law, such as to:

• Provide a good or service requested by you;
• Provide a good or service reasonably anticipated within the context of our ongoing business relationship with you;
• Detect security incidents or malicious or illegal activity;
• Debug or repair existing intended functionality;
• Exercise, or allow you to exercise, free speech or another legal right:
• Enable internal uses that are reasonably aligned with your expectations based on your business relationship with us;
• Engage in certain scientific research;
• Comply with a legal obligation; or
• Use the PII internally in a lawful manner compatible with the context in which you provided the PII to us.

You may also have the right to have your PII rectified or corrected (if inaccurate), the right to restrict use of your PII (including to limit use and disclosure of sensitive personal data where applicable), the right to opt out of certain processing, including the sale and/or sharing of your information as discussed in the section on “Sharing Your PII” above, and the right to opt out of automated decision-making and profiling.

 

Non-Discrimination and Financial Incentives

You may have the right to non-discrimination for exercise of your data privacy rights. We will not discriminate against you for exercising any of your data privacy rights. Unless permitted by applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Applicable law may permit businesses to provide differing levels of quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s PII.

Applicable law may allow businesses to offer consumers financial incentives for sharing PII. For example, a business may be able to offer a rewards program or provide a premium service to consumers as compensation for their PII. Where we offer such programs, your participation is optional, your participation is subject to any applicable terms, and you may withdraw at any time.

Requests to Exercise Your Rights

You (or your authorized agent) may request to exercise the foregoing rights, where applicable, by submitting a request to us by calling, writing or emailing us at:

Thread Wallets
125 W 500 S

Provo, Utah US 84601

contact@threadwallets.com

Once a request is received, your identity will need to be verified. This may be done, for example, by asking you to confirm information that you have already provided to us. This information will be used to verify your identity and process your request. We will confirm request received by email to the account provided.

Where applicable, you may only be able to make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PII or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot substantively respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm the PII relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use PII provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We will endeavor to respond to a verifiable consumer request within 45 days of its receipt, or as otherwise required by applicable law. If we require more time, then we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Where applicable, any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your PII that is readily useable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If a request of yours is denied or if you feel that your PII has not been handled appropriately according to applicable law(s), you may be able to appeal that decision. To do so, please include “APPEAL” in the subject or attention line of your written communication. For more information, contact us as set out above.

 

California Online Privacy Protection Act Notice

Some web browsers incorporate a “Do Not Track” or similar feature (such as Global Privacy Control signals, see https://globalprivacycontrol.org) that signals to websites that you visit that you do not want to have your online activity tracked. Our Site works to recognize Global Privacy Control signals where required to do so by applicable law(s).

 

Please note that third parties outside of Thread Wallets’ control may collect PII about your online activities over time and across different websites when you visit our Site or other online websites and services. Thread is not responsible for third-party sites or cookies, nor for the PII they collect.

 

CHILDREN’S PRIVACY

Our services are not directed to or intended for use by minors. Consistent with the requirements of applicable law, if we learn that we have received any information directly from a minor without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use our services and subsequently will delete that information.

DATA RETENTION

We generally retain your PII for as long as is reasonably necessary to fulfill the purposes for which it was collected, including the fulfillment of orders, marketing, and/or our own internal analytics, statistical purposes, and other functions.

CHANGES

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. This Privacy Policy is effective as of Feb. 1, 2023.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at contact@threadwallets.com or by mail using the details provided below:

Thread Wallets
241 W Center St. Provo Utah US 84601

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