Privacy Policy
Last Updated: June 28, 2022
Naadam, Inc.. (collectively with any of our subsidiaries and our family of brands and affiliates, “Naadam,” “we,” “us,” or “our”) has created this Privacy Policy to help you understand how Naadam collects, uses, processes, and shares your personal information, and to help you understand and exercise your privacy rights. Please see the “Contact Us” section below to determine which of our brands or entities you may be shopping with.
This Privacy Policy applies to personal information processed by us through our various family of brands and affiliates, including on any of our websites, mobile applications, and other online or offline offerings that post a link to this Privacy Policy. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.”
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
We may collect personal information that you provide to us.
Account Creation. We may collect personal information when you create an account, such as name, email address, username, phone number, gender, demographics information, etc.
We may collect personal information automatically when you use our Services.
Our uses of these Technologies fall into the following general categories:
Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. 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.
Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
We use your information to fulfil our contract with you and provide you with our Services, such as:
We use your information for various administrative purposes, such as:
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 may 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, you may contact us at any time as set forth in “Contact Us” below.
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.
We also use your personal information for other purposes as requested by you or as permitted by applicable law.
We disclose your personal information to third parties for a variety of business purposes, including to provide our 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.
The categories of third parties with whom we may share your personal information are described below.
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.
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.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
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.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.
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.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth in “Contact Us” below.
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.
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Naadam has collected about them, and whether Naadam disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
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Category of Personal Information Collected by Naadam |
Category of Third Parties Personal Information is Disclosed to for a Business Purpose |
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Identifiers. |
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Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
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Protected classification characteristics under California or federal law |
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Commercial information |
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Internet or other electronic network activity |
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Geolocation data |
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Sensory data |
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Professional or employment-related information |
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The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, Naadam does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
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 designate an authorized agent, please contact us as set forth below for additional instructions.
Verification. When you make a request, we will ask 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, which may include confirming the email address associated with any personal information we have about you.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.
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.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our Services without your consent, and you wish to review information collected from your child or have that information modified or deleted, 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.
Third-Party Services. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”). Any information disclosed to or otherwise collected by a Third-Party Service may be subject to the Third-Party Service’s privacy policy. We do not provide or control any aspect of the Third-Party Services and are not responsible for any compatibility issues, errors or bugs in the Services or Third-Party Services caused in whole or in part by the Third-Party Services or any update or upgrade thereto. We encourage our users to read the privacy policies of each Third-Party Service with which they interact. We do not endorse, screen or approve, and are not responsible for such Third-Party Services. Providing information to or interacting with Third-Party Services is at your own risk.
Supervisory Authority. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.
The following are a list of brands or affiliates of Naadam covered by this Privacy Policy: Naadam, Thakoon, Ivory Ella, Package Free and such other brands we may acquire or launch from time to time.
Naadam is the controller of the personal information that is processed under this Privacy Policy.
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Naadam, Inc.
183 Madison Avenue
Suite 700
New York, NY 10016
support@naadam.co
+1 929-238-9651