Last updated December 23, 2020
PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we 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 all of this automatically-collected information as “Device Information”.
We collect Device Information as follows:
- Billing information associated with the debit/credit card you use to make an online purchase direct from our site. If you make a payment through our service, your credit/debit card number will be stored by Stripe. For more information on Stripe’s data storage and privacy terms, please read their terms of service here and privacy policies here.
- Shipping, contact and Personal Information required for orders placed through this website will be handled and stored by Shopify and/or Slingshot.
- Information automatically collected when visiting our website, which may include:
- Cookies, third-party tracking technologies and server logs;
- Identifiers such as an anonymized session identifier;
- Your geographic location. We used this data to provide you with location-based services, such as advertising and personalized content. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings;
- Website traffic volume, frequency of visits, and type and time of transactions you initiate through the website;
- Your Internet Protocol (IP) address;
- the type and settings of the device, operating system, and browser used to access the Site; and
- websites you visit before and after using the Site;
We may use third party-vendors, identified below, to help deliver you content and process your payments.
Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number). We refer to this information as “Order Information”.
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information and provide you with the Services, as described above.
Pushkin Industries, Inc. uses the following data processors with respect to the Personal Information collected:
- We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.
Each of the foregoing is referred to as a “Data Processor.”
USE OF INFORMATION COLLECTED
Pushkin Industries, Inc. may collect and may make use of Personal Information to assist in the operation of our website and to ensure delivery of the services you’ve paid for or requested.
We use the Order 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 use this Order Information 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 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).
At times, we may find it necessary to use Personal Information as a means to keep you informed of other possible products and/or services that may be available to you from the Site and/or www.pushkin.fm; support the tracking and recovery of the services you purchase; respond to questions, comments or other requests and provide you with technical support; and notify you of technical updates or changes to our policies. Pushkin Industries, Inc. may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future services that may be offered.
Pushkin Industries, Inc. does not now, nor will it in the future, sell, rent or lease any of our customer lists and/or names to any third parties.
Pushkin Industries, Inc. may disclose your Personal Information, without prior notice to you, only if required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:
- Remain in conformance with any decrees, laws and/or statutes or in an effort to comply with any process which may be served upon Pushkin Industries, Inc. and/or our website;
- Maintain, safeguard and/or preserve all the rights and/or property of Pushkin Industries, Inc.; and
- Perform under demanding conditions in an effort to safeguard the personal safety of users of the Site and/or the general public.
We may share or disclose non-personal, generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. Pushkin Industries, Inc. will only provide those third parties with the information that they need to deliver services to Pushkin Industries, Inc and on Pushkin Industries, Inc’s behalf.
As described above, we use your Personal Information 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.
You can opt out of targeted advertising by using the links below:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal here.
HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information, username, password, transaction information and data stored on our website. Sensitive and private data exchange between the website and its users happens over an SSL secured communication channel and is encrypted and protected with digital signatures. If you have any questions about the security of Personal Information collected by Pushkin Industries, Inc., please contact: firstname.lastname@example.org.
Pushkin Industries, Inc. shall endeavor to use commercially reasonable efforts to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of the user’s Personal Information under our control. However, no method of transmission over the Internet or via a mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect information about you, we cannot guarantee absolute security.
CHILDREN UNDER AGE OF 13
Pushkin Industries, Inc. does not knowingly collect Personal Information from children under the age of thirteen (13) without verifiable parental consent. If it is determined that such information has been inadvertently collected on anyone under the age of thirteen (13), please contact us (see “Contact Information” below) and we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission to use this website.
UNSUBSCRIBE OR OPT-OUT
- To control cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
- Please note that if you choose to block cookies, doing so may impair the service or prevent certain elements of it from functioning.
“DO NOT TRACK” SIGNALS
Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. This service does not alter its practices when it receives a “Do Not Track” from a visitor’s browser.
LINKS TO OTHER WEB SITES
DATA RETENTION AND ACCOUNT TERMINATION
You can update or correct Personal Information (e.g., your name, email address and state) by accessing your account. You can also access or rectify your information by reaching out to us at email@example.com. You can delete your information by sending an email to firstname.lastname@example.org with your first name, last name, and the respective email addresses you would like for us to delete.
Please note that we have the right to reject deletion requests that are unduly burdensome or repetitive or that cannot be honored in light of legal obligations or ongoing disputes, or where retention is necessary to enforce our agreements or protect our or another party’s rights, property, safety, or security. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the service or to comply with legal obligations. The time-period for which we keep information varies according to the information’s use. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need. Please also note that even after you have deleted your account and/or information, other content associated with your use of the service may still be accessible and viewable in accordance with applicable law and our Terms of Service.
LOCATION OF DATA AND TRANSFERS OF INFORMATION
The Site is owned and operated by Pushkin Industries, Inc along with Shopify and Slingshot, which are located in the United States. If you are located outside of the United States, please note that personal data may be processed to and/or accessed in the United States.
If you are a European resident, you have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the Contact Information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
Pushkin Industries, Inc. endeavors to comply with European privacy laws such as the General Data Protection Regulation (GDPR). Pushkin Industries, Inc may act, depending on the circumstances, as a “Controller” of personal data (as defined in the GDPR). We act as the Controller of information that we automatically collect when you use the service.
EEA users have the right to request access to personal data, as well as to seek to update, delete or correct their personal data. Contact us for additional access and assistance.
YOUR CALIFORNIA PRIVACY RIGHTS
We recognize the need to provide further privacy protections with respect to personal data we may collect from California residents. For California residents, we will employ different data practices as necessary to comply with applicable law. For additional information about our practices regarding personal data and privacy-related choices specific to California residents, please read our Privacy Notice for California Residents below.
ACCEPTANCE OF TERMS
HOW TO CONTACT US
Pushkin Industries, Inc.
5-9 Union Square West
New York, NY 10003
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: December 23, 2020
INFORMATION WE COLLECT
Our websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Consumer Information”). In particular the Site has or will collect the following categories of Consumer Information from its consumers:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, address, telephone number.
D. Commercial information.
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
Please note that Consumer Information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
- Consumer Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Please note that some Consumer Information may be collected from you in connection with your purchase of or registration for our products and services on third-party websites. For example, forms related to registrations and purchases, which capture certain Consumer Information, may be hosted by our fulfilment partners. Such Consumer Information is then shared with Pushkin Industries, Inc. and used in accordance with “Use of Personal Information” below.
YOUR RIGHTS AND CHOICES.
The CCPA provides California residents with specific rights regarding their Consumer Information. This section describes such rights and explains how to exercise them.
- Access to Specific Information and Data Portability Rights. You have the right to request that Pushkin Industries, Inc. disclose certain information to you about our collection and use of your Consumer Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights” below), we will disclose to you:
- The categories of Consumer Information we collected about you.
- The categories of sources for the Consumer Information we collected about you.
- Our business or commercial purpose for collecting that Consumer Information.
- The categories of third parties with whom we share that Consumer Information.
- The specific pieces of Consumer Information we collected about you (also called a data portability request).
- If we sold or disclosed your Consumer Information for a business purpose, two separate lists disclosing:
- sales, identifying the Consumer Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Consumer Information categories that each category of recipient obtained.
- Deletion Request Rights. You have the right to request that Pushkin Industries, Inc. delete any of your Consumer Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights” below), we will delete (and direct our service providers to delete) your Consumer Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Consumer Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 332-203-2550
- Emailing us at email@example.com
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Consumer Information. You may also make a verifiable consumer request on behalf of your minor child. You may only 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 Consumer Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Consumer Information if we cannot verify your identity or authority to make the request and confirm the Consumer Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Consumer Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. 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. For data portability requests, we will select a format to provide your Consumer Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 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.
- Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
In the event that Pushkin Industries, Inc. does provide a CCPA-permitted financial incentive program that results in different prices, rates or quality levels, such program will reasonably relate to your Consumer Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents who use our websites to request certain information regarding our disclosure of Consumer Information to third parties for their direct marketing purposes. To make such a request, please contact us via the contact information listed in “Contact Information” below.
CHANGES TO OUR PRIVACY NOTICE
Pushkin Industries, Inc. reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our websites and update the notice’s effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.
Postal Address: 5-9 Union Square West, New York, NY 10003