First Quality Privacy Policy
LAST UPDATE: February 15, 2025
First Quality Enterprises, LLC, its affiliates, and its brands (collectively, “First Quality”, “we”, “our”, and “us”) respect your concerns about privacy and personal data protection and value our relationship with you. This Privacy Policy (the “Policy”) applies to personal information collected through the First Quality websites, online services, web pages, and other services that we offer on and offline and that post, or otherwise present, this Policy (all of the foregoing, collectively, the “Services”), whether those Services are accessed via computer, mobile device, or other device (collectively, “Device”).
For residents of California and other U.S. states that provide additional privacy rights, more information about the data we collect is available in our Notice at Collection and Supplemental Notice for Residents of California and Certain Other U.S. States, which is found below here.
For residents of US states that require separate notices about certain health information, our Health Information Privacy Policy is available here.
This Policy describes the types of personal information we collect through the Services and how that personal information may be used and with whom it may be shared. This Policy also describes how you can reach us to update your personal information, access and control the use of your personal information, or get answers to questions you may have about our privacy practices. Please read this Policy carefully, because by accessing and using our Services you are acknowledging that you understand and agree to the terms of this Policy.
First Quality’s affiliates and brands that this Privacy Policy may apply to are listed in the FIRST QUALITY AFFILIATES AND BRANDS section below.
Sections of this Policy:
1. CONSENT
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. RETENTION OF PERSONAL INFORMATION
10. FIRST QUALITY AFFILIATES AND BRANDS
11. CONTACT US
A. Consent to Data Collection and Processing
By continuing to use our Services you are signifying that you agree with and consent to the collection and processing of your personal information as described in this Policy. If you have questions about our personal information processing or our privacy practices, you can contact us using the information in the Contact Us section below.
B. Consent to International Data Transfers
Your personal information may be collected, processed, and stored by First Quality or its service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements in some of these countries, including the rights of authorities seeking to access your personal information, may not be equivalent to those in your country. By continuing to use our Services you signify that you agree with and consent to the transfer of your personal data to the United States and other countries where First Quality operates.
2. PERSONAL INFORMATION WE COLLECT
As you interact with First Quality, there may be opportunities for you to provide us with your information. Additionally, we may automatically collect certain information about you as further described below.
A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us. We may collect the following categories of personal information during these types of interactions:
· Account Creation. We may collect personal information when you create an account with us, such as name, personal contact information (e.g. name, home address, telephone number, email address, etc), business contact information (e.g., shipping information, company name, job title, business email address, business phone number, etc.), and login information (e.g., username, password, etc).
· Transactions, Purchases, and Financial Information. We may collect personal information and details associated with your purchases, including financial, background information (to the extent permitted by law) and payment information (e.g., banking and payment card information). Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details). We collect transaction history and details associated with you and your account.
· Your Communications with Us. We may collect personal information, such as email address, phone number, mailing address, or contents of your communications directed to us when you request information about our Services, register for our newsletters or customer programs, inquire about our products, submit issues related to the use of our products, request customer service or technical support, or otherwise communicate with us, including through any chat features or chatbots within our Services. Note that:
o Our chat features are enabled by our service providers who also receive this information and process it on our behalf including by using artificial intelligence that is used solely for our benefit. By using our chat features you agree to this collection and processing; and,
o Our phone lines may be recorded. By communicating with us on our phone lines you agree to the recording for quality control purposes.
· Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
· Consumer Forums. We may host consumer community forums to gather input and feedback about our products and services. If you chose to participate in these forums, we may collect information you provide about yourself, including demographic information and your preferences as a consumer. If you consent to participate in a consumer community forum, we may ask your permission to collect sensitive information about you including information about your racial background and health.
· Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). This may include information about your intended use of our products including your physical attributes (e.g. height, weight, body type) and information about your health. Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. You should not submit to First Quality any information that you do not want others to know. First Quality does not routinely monitor these areas of the Services, and you submit such information to First Quality for posting only at your own risk.
· Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we may be required to publicly share information of sweepstakes and contest winners.
· Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
· Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
· Providing Services to Us. We may collect business contact information, background information, and government identifiers to the extent permitted by law when you provide services to us.
· Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.
By submitting personal information to First Quality through our Services, you consent to First Quality’s collection, use and disclosure of such personal information in accordance with this Privacy Policy.
B. Personal Information Collected Automatically
We may collect personal information automatically when you use our Services.
- Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
- Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also sometimes called a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
· Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
· Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
· Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
· Advertising- or Targeting-Related. We may use first party or third-party Technologies, including cross-device tracking, to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties. Some of the advertising Technologies we use include:
o Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
o Meta Pixel. We may use a Meta Pixel on certain of the Websites, including EarthandEdenbrand.com, which allows us to display our posted Meta ads only to a target group of Meta users (e.g., users who have shown an interest in our products or have other similar factors). By using a “visitor action pixel,” Meta allows user behavior to be tracked after the user has clicked on a Facebook ad. In this way, Meta Pixel enables us to understand the effectiveness of our Meta ads for statistical and market research purposes. Please refer to Meta’s data policy at https://www.facebook.com/about/privacy/update for more information. You can disable this function by going to https://www.facebook.com/settings tab/ads while logged into your Facebook account.
o DoubleClick. For more information about Google’s use of your personal information, please visit Google’s privacy policy. To learn more about how to control Google’s use of your information for ads, please click here.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:
o Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
· Integrated Accounts and Social Media Information. We may implement applications or “widgets” from third party providers (e.g., Facebook, Twitter, Instagram, LinkedIn, etc.) that allow interaction, integration or content sharing with third party services. These widgets or applications may be visible on a page you visit on our Services or may require log-in through the third-party provider’s service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third-party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third-party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third-party policies to understand these practices.
C. Personal Information Collected from Other Sources
Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations, where permitted by law. For example: if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings; or, if your care provider sends us your information so that we can provide our products or Services or resolve issues with our products.
3. HOW WE USE YOUR PERSONAL INFORMATION
In addition to how we describe our uses of your personal information below, we may also use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a business account, (2) submit your name and e-mail address to receive product updates and marketing information, or (3) or engage with our interactive features such as calling our customer service centers or using our chat features such as our eNurse or eNanny chat features.
We also use information from or about you to:
A. Provide Our Services
We use your information to fulfil our contract with you and provide you with our Services, such as:
· Fulfilling your orders and requests for information, Services, or products;
· Managing your information and accounts;
· Providing access to certain areas, functionalities, and features of our Services, including verifying your identity where required to use our Services or communicate with you;
· Answering requests for customer service, technical support, trouble-shooting, and other support services (e.g., responding to your questions or complaints);
· Communicating with you about your account, activities on our Services, and policy changes;
· Processing your financial information and other payment methods for products or Services purchased;
· Processing applications if you apply for a job we post on our Services; and
· Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
· Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
· Providing direct marketing materials, including advertisements and newsletters, and customized experiences when using our Services, including on our websites;
· Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
· Measuring interest and engagement in our Services;
· Short-term, transient use, such as contextual customization of ads;
· Improving, upgrading, or enhancing our Services;
· Developing new products and services;
· Ensuring internal quality control and safety;
· Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
· Debugging to identify and repair errors with our Services;
· Accounting and auditing relating to interactions, transactions, and other compliance activities;
· Sharing personal information with third parties as needed to provide the Services;
· Carrying out uses identified in our agreements with you, including our applicable Terms of Use;
· Enforcing our agreements and policies; and
· Carrying out activities that are required to comply with our legal obligations, including in connection with a merger, divestiture, acquisition, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
We may use your information for other legitimate business purposes as permitted by law.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, text messages, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
E. Other Purposes
We also use your personal information for other purposes as requested by you or as permitted by applicable law.
De-identified and
Aggregated Information. We may use personal information to create
de-identified and/or aggregated information, such as demographic information,
information about the device from which you access our Services, or other
analyses we create. When we process data in de-identified form, we will not
re-identify such data unless we process any resulting personal information in
accordance with this Privacy Policy and applicable law.
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We disclose your personal information to third parties for a variety of business purposes, including to provide our products and Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
- Disclosures to Provide our Services
The categories of third parties with whom we may share your personal information are described below.
· Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our products and Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, interactive features such as chat and our consumer community forums, and similar services.
· Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
· Affiliates and Brands. Where permitted by law, we may share your personal information with our company affiliates and brands for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
· Other Users or Third Parties You Share or Interact With. As described above in “Personal Information We Collect,” our Services may allow you to share personal information or interact with other users and third parties (including individuals and third parties who do not use our Services and the general public).
· Advertising Partners. Through our Services, we may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “cross-context behavioral advertising,” “targeted advertising,” or “personalized advertising.”
· APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
We may also share your information with third parties as appropriate and permitted by law. The privacy choices you may have about your personal information are determined by applicable law and are described in Section 5 “Your Privacy Rights and Choices” below.
- Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
A. Your Privacy Choices. The privacy choices you may have about your personal information are determined by the laws applicable to you and your information. Depending on the applicable law, you may have the rights described below.
· Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
· Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
· Phone calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
· “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals transmitted by web browsers; however, we do respond to the Global Privacy Control, which you can learn more about here.
· Cookies and Personalized Advertising. You can control our use of certain cookies and Technologies in the following ways:
o Website Cookie Controls. When you first visit our website, you may be presented with a banner that informs you about the categories of cookies and other tracking technologies (“Technologies”) used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Where applicable, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be used for targeted advertising. Please note that cookies are browser and device specific. Your request to opt-out or reject the use of these Technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices. Where available, you can do so by clicking on the cookie icon that appears when you return to our Services or the “Your Privacy Choices” link at any time to manage your preferences.
o Browser and Device Controls. You may also stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. These tools are generally available in the help section of browsers. You can also use the quick links, based on the browser type that you are using: Internet Explorer, Google Chrome, Firefox, and Safari. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
o Global Privacy Control. You may exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). You can learn more about the Global Privacy Control here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request.
o Ad Industry Opt-outs. In addition, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
B. Your Privacy Rights. In accordance with applicable law, you may have the right to:
· Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
· Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
· Request Deletion of your personal information;
· Request Restriction of or Object to our processing of your personal information where the processing of your personal information: (i) is based on our legitimate interest for direct marketing purposes; (ii) involves processing or sharing of your sensitive personal information for certain non-essential purposes, or in contexts that require your consent; and (iii) for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
· Opt-out of Sale, Sharing for Cross-Contextual Advertising, or Targeted Advertising involving your personal information. Although we do not “sell” your personal information as the term “sale” is typically understood, we may share your information with analytics providers and advertising networks in order to understand how visitors use our websites and serve you ads on and off our websites. You may opt-out of this “sharing” and “targeting advertising” by adjusting your privacy choices. When you first visit our website, you will be presented with a banner that informs you about the categories of cookies and other tracking Technologies used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Where applicable, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be used for targeted advertising. Please note that cookies are browser and device specific. Your request to opt-out or reject the use of these Technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices. Where available, you can do so by clicking on the cookie icon that appears when you return to our Services or the “Your Privacy Choices” link at any time to manage your preferences. You may also stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. You can also use the quick links, based on the browser type that you are using: Internet Explorer, Google Chrome, Firefox, and Safari. However, if you adjust your preferences, our website may not work properly. Please note that cookie-based opt-outs are not always effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. You may also exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request. You can learn more about the Global Privacy Control here. In addition, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Advertising Alliance; and,
· Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below, submit the form found at our request portal, or as otherwise instructed in the additional privacy notices provided at the time we collect your personal information, including in notices about cookies and tracking technologies on our websites. We will process such requests in accordance with applicable laws.
6. SECURITY OF YOUR INFORMATION
First Quality has implemented security measures designed to protect personal information provided by you against unauthorized access and use. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
7. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.
The Services are not directed to children under 13 (or other age as required by local law), and we request that these individuals not provide personal information through this Services. We do not knowingly collect personal information from children. Protecting children’s privacy online is very important to us. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.
A. Third Party Services
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any Services or web property that is available through this Services or to which this Services contains a link. The availability of, or inclusion of a link to, any such Services or property on this Services does not imply endorsement of it by us or by our affiliates.
B. Accuracy
It is your responsibility to provide First Quality with accurate personal information. Except as otherwise set forth in this Policy, First Quality shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, First Quality shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.
C. Compliance with Local Laws.
This Policy is meant to guide First Quality with respect to personal information collected from or about you at this Services. While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to First Quality (“Local Laws”) may require standards which are stricter than this Policy and, in such event, First Quality will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. All the information you provide may be transferred or accessed by entities around the world as described in this Policy. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Services or by providing consent to us (where required by law), you specifically acknowledge and consent to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection, than in your country. Irrespective of which country your personal data is transferred, we would only share your personal data under a ‘need to know’ basis. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual and/or other lawful means.
D. Updates to this Privacy Policy
We may change this Policy. Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Services. Your use of this Services following these changes means that you accept the revised Policy.
E. Compliance
If you believe that your personal information has been processed or disclosed in violation of this Policy, First Quality encourages you to raise any concerns using the contact information provided in the “Contact Us” section below. First Quality will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.
F. Your Right to Complain
If you have a complaint as to our use of your information, you may file a complaint with us, any a governmental agency with proper jurisdiction, and/or a judicial body.
A complaint may be submitted directly to First Quality by utilizing one of the contact methods described in the “Contact Us” section of this policy below.
10. FIRST QUALITY AFFILIATES AND BRANDS
First Quality’s affiliates may include the following entities:
First Quality Consumer Products, LLC
First Quality Tissue, LLC
First Quality Tissue SE, LLC
FQP&P, LLC
First Quality Baby Products, LLC
First Quality Retail Services, LLC
First Quality Absorbent Hygienic, LLC
My Friendly Neighbor, LLC
First Quality’s brands may include:
Earth and Eden
Prevail
Fempro
Cuties
Panda Bath Tissue
Plenty Paper Towels
11. CONTACT US
If you have any questions about this Policy, please contact First Quality directly.
Our contact information is as follows:
By U.S. Mail at:
First Quality Enterprises,
Inc.
80 Cuttermill Rd., Suite
500
Great Neck, NY 11021
Attention: Business Practices Department
By Telephone at:
833-590-1218 (Monday to Friday, 8am – 5pm EST)
By Email at:
By Webform at:
To exercise your rights as described herein, you may submit a verifiable consumer request to us (as described above) by either contacting us by mail, phone, email or by submitting the webform found at our request portal.
12. NOTICE AT COLLECTION AND SUPPLEMENTAL NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES INCLUDING CALIFORNIA
This Notice at Collection and Supplemental Notice is for residents of U.S. states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including, but not limited to, California, Connecticut, Colorado, Nevada, Virginia, and Utah (collectively, “Applicable State Laws”). The following table describes the categories of personal information First Quality has collected and whether we disclosed that personal information for a business purpose (e.g., to a service provider).
|
Category of Personal Information Collected by First Quality |
Category of Third Parties To Whom Personal Information is Disclosed for a Business Purpose |
|
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
· Service providers · Business partners · Affiliates and Our Brands · Other users or third parties you share or interact with · Advertising networks · Internet service providers · Data analytics providers · Government entities when required by law
|
|
Personal information categories A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories. |
· Service providers · Business partners · Affiliates and Our Brands · Other users or third parties you share or interact with · Advertising networks · Internet service providers · Data analytics providers · Government entities when required by law |
|
Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions). |
· Service providers · Business partners · Affiliates and Our Brands · Internet service providers |
|
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
· Service providers · Business partners · Affiliates and Our Brands · Advertising networks · Internet service providers · Data analytics providers |
|
Internet or other electronic network activity Information from cookies and Technologies such as: Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement. |
· Service providers · Business partners · Affiliates and Our Brands · Advertising networks · Internet service providers · Data analytics providers |
|
Geolocation data Location based on IP address only. |
· Service providers · Business partners · Affiliates and Our Brands · Advertising networks · Internet service providers · Data analytics providers |
|
Professional or employment-related information Current or past job history or performance evaluations. |
· Service providers · Business partners Affiliates and Our Brands |
|
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
· Service providers · Business partners · Affiliates and Brands · Advertising networks · Internet service providers · Data analytics providers |
|
Sensitive personal information Racial or ethnic origin, religious or philosophical beliefs, union membership, and health information. |
· Service providers · Affiliates and Brands · Internet service providers · Data analytics providers
|
Sources of Personal Information We Collect
As more fully described in the section titled Personal Information We Collect, the sources from which we collect personal information include directly from you when you interact with us, automatically from you when you use our sites and services (for example through cookies and other online technologies), from third parties (for example, if you purchase our products from a third-party seller, if you access our services through a third-party application, such as an app store, a third-party login service, or a social networking site, then we may collect personal information about you from that third-party seller or application), and through referrals from others.
Purposes for which We May Use the Information We Collect
The business purposes for which we collect personal information are described in more detail in the section titled, How We Use Your Personal Information, and include:
· To provide our Services to you;
· For our Administrative purposes (including security, fraud detection and protection, and improve our Services);
· To process your requests, orders, and transactions (including provide customer service to you);
· To Advertise and Market our products and Services to you;
· With your consent; and,
· To comply with law and enforce our rights and the rights of others.
Our full Privacy Policy can be accessed here.
“Sales” of Personal Information, including under California’s CCPA and Opting Out of Targeted Advertising.
For purposes of Applicable State Laws, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 18 years of age as the term “sell” is commonly understood. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising and targeted advertising. To the extent that such sharing is considered a “sale” or “sharing” or disclosing for targeted advertising under California or other Applicable State Law, you may limit such sharing by:
- Exercising Your Privacy Choices and Rights by following the instructions found above in the section titled, Your Privacy Choices and Rights > Your Privacy Choices > Cookies and Personalized Advertising found here
- Opting-Out. Clicking on the “Your Privacy Choices” website link where available.
- Request Form. Completing our online request form at our request portal.
- Contact Us. Contacting us as set forth in “Contact Us” above.
When you first visit our website, you will be presented with a banner that informs you about the categories of cookies and other tracking technologies used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Where applicable, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be used for targeted advertising. Please note that cookies are browser and device specific. Your request to opt-out or reject the use of these technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices. Where available, you can do so by clicking on the cookie icon that appears when you return to our Services or the “Your Privacy Choices” link at any time to manage your preferences. You may also stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. You can also use the quick links, based on the browser type that you are using: Internet Explorer, Google Chrome, Firefox, and Safari. However, if you adjust your preferences, our website may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. You may also exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request. You can learn more about the Global Privacy Control here. In addition, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Advertising Alliance.
The categories of data we share for cross contextual advertising and targeted advertising include:
· Online Identifiers such as IP address, marketing id, device identifiers and characteristics,
·
Internet or other Electronic Network Activity, such as Browsing and Usage
Information; and,
· Inferences about individual preferences, characteristics, and behaviors
Each of these categories may have been shared with advertising networks and data analytics providers for the purpose of providing targeted advertising and marketing.
Retention of Personal Information.
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.
Processing Sensitive Information.
Under applicable laws, you may have the right to limit the processing of sensitive personal information for certain purposes such as profiling or inferring characteristics about you. We do not process sensitive personal information for such purposes unless you’ve consented to such processing. If you would like to limit this processing, you can make a request by contacting us using the information at “Contact Us” above.
Additional Privacy Rights for Residents of Certain States Including California.
You have the privacy rights described in the section Your Privacy Rights and Choices, you may also have the following rights.
Non-Discrimination. Residents of certain states have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by applicable law.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” above for additional instructions.
Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services. If we cannot verify your identity or authority to make a request, we may not be able to fulfill your request.
Once you have provided the required information to us, we will confirm your identity by conducting an electronic search of our internal systems to ensure the information provided by you in your request matches what we have in our systems.
To verify your identity, we may ask that you provide the following information when you submit your request:
· Your name
· Your home address and, if different, shipping address
· Your state of primary residence
· Your home phone number
· Your email address
· Means of purchase (e.g., directly from us or through a third party website, such as Amazon, etc.)
· Date of most recent transaction and description of items purchased
Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.
We will respond to your request within forty-five (45) days or within the time provided for under Applicable Law. However, in certain circumstances, we may require additional time to process your request, as permitted by applicable law. We will advise you within forty-five (45) days after receiving your request if such an extension is necessary and why it is needed. If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.
We do not charge a fee to process or respond to your 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. We will not discriminate against you for exercising your privacy rights.
Appeal. You may have the right to appeal our decision or response to your request. To exercise your right to appeal, you can submit an appeal request using the same method used to submit your original request, including by contacting us as set forth in “Contact Us” above.
De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with Applicable Law or in accordance with our Privacy Policy.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in “Contact Us” above.