Privacy Policy

Westlife Distribution, LLC and our subsidiaries and affiliates, including 686, (“Westlife”, “we”, “us” or “our”) take steps intended to meet privacy principles and requirements with respect to your personal information under applicable privacy legislation.

This policy describes:

·        How we collect, use, disclose, and protect the personal information of our customers and website users ("you").

·        The types of information we may collect from you or that you may provide when you visit the website 686.com (our "Website").

·        Our practices for collecting, using, maintaining, protecting, and disclosing that information.

For the purposes of this privacy policy, “personal information” means any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a person or household.

This policy applies to information we collect, use, or disclose about you:

·        On our online services including this Website and our social networks pages.

·        In email, text, and other electronic messages between you and this Website.

·        When you interact with our advertising on third-party websites and services if those advertising include links to this policy.

·        From our affiliates and third parties that may provide us with information about you.

Changes to our Privacy Policy

By using our website you acknowledge this Privacy Policy. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you of any material changes either through a pop-up notice, email or through other reasonable means. We encourage you to periodically review this privacy policy in order to keep apprised of any changes.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Information we collect about you

We collect and use several types of information from and about you, including:

·        Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information and any other identifier we may use to contact you ("personal information").

·        Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information.

·        Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.

·        Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

·        Payment information, including your credit card details, billing and shipping addresses, and order history.

·        Account information, including your user login information and password and your login details from a linked account used to login such as your Google, Facebook or Shopify login details.

How we collect information about you

We use different methods to collect your information, including through:

·        Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.

·        Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

·        From third parties. From time to time, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use such third-party information to better understand your interests by associating demographic information with the information you have provided.

Information you provide to us

The information we collect directly from you on or through our Website may include:

·        Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material, subscribing to our newsletter or requesting further services.

·        Records and copies of your correspondence (including email addresses), if you contact us.

·        Your responses to surveys that we might ask you to complete for research purposes.

·        Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

·        Your search queries on the Website.

You may also provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Submissions"). Your User Submissions are posted on and transmitted to others at your own risk.

SMS Communications

You may opt-in to receive SMS notifications from us in order to receive order updates and marketing information from us. SMS notifications will only be sent to you to fulfill the purpose for which you have shared your phone number with us. We only share your phone number with third party services like Klaviyo, who help us send SMS notifications to you. You may opt-in to our SMS delivery services by entering your phone number when prompted at check-out, or by sending a message to the phone number specified on our Website Terms of Use.

Information we collect through cookies and other automatic data collection technologies 

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·        Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.

·        Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

·        Estimate our audience size and usage patterns.

·        Store information about your preferences, allowing us to customize our Website according to your individual interests.

·        Speed up your searches.

·        Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

·        Cookies (or browser cookies) – A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

·        Flash Cookies – Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Your Privacy Choices.

·        Web Beacons – Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Westlife, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

·        Google Analytics – We also use Google Analytics to better understand who is using our Website and how people are using it. Google Analytics uses cookies to collect information such as Website pages visited, places where users click, time spent on each Website page, Internet Protocol address, type of operating system used and location. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information, and visit https://tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on. Google may track your activity over time and across websites.

How we use your information

In order to use certain features of our Website, we may request that you provide certain personal information. We use information that we collect about you or that you provide to us, including any personal information:

·        To present our Website and its contents to you.

·        To provide you with information, products, or services that you request from us.

·        To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.

·        To notify you about changes to our Website or any products or services we offer or provide through it.

·        To improve our Website, products or services, marketing, or customer relationships and experiences.

·        To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.

·        To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

We may also use your information to contact you about goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at privacy@686.com. For more information, see Your Privacy Choices section below.

Disclosure of your information

We may disclose personal information that we collect or you provide as described in this Privacy Policy with the following:

·        Advertisers and Advertising Networks – We may disclose personal information to advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others.

·        Third Party Marketing Partners – We may disclose personal information to third parties if you have not opted out of these disclosures. These third parties may use that personal information for commercial purposes and we require them to use your personal data in a manner that is consistent with this policy. For more information, see Your Privacy Choices

·        Service Providers – We may transfer personal information to outside agents or service providers (including affiliates acting in this capacity) that perform services on our behalf, such as data hosting and processing, marketing and information technology, and to complete transactions. These service providers are located in Canada and the United States, and your personal information may be collected, used, disclosed, stored and processed in the United States or Canada for the purposes described in this privacy policy.

·        Payment Processing – When you place an order on our Website we will share our payment information with payment processors such as Shop Pay, Paypal, Google Pay and Venmo. These payment processors will use and process your payment information according to their own privacy policies.

·        Business Transactions – We may use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of Westlife or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of Westlife or our business or assets may use and disclose your personal information for similar purposes as those described in this privacy policy.

·        Legal – We may disclose personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian, American and foreign laws applicable to us or our service providers).

We may also disclose your personal information:

·        To our subsidiaries and affiliates.

·        To fulfill the purpose for which you provide it.

·        For any other purpose disclosed by us when you provide the information.

·        If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Westlife, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may disclose aggregated information about our users and information that does not identify any individual, without restriction.

Shopify

Our Website is hosted on Shopify, which collects and processes your Personal Information to provide and improve the Website. Information you submit on the Website may be transmitted to and shared with Shopify. . To learn more about how Shopify uses your personal information and any rights you may have, you can visit the Shopify Consumer Privacy Policy. Depending on where you live, you may exercise certain rights with respect to your personal information here Shopify Privacy Portal Link.

Transferring your personal information

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian, United States or European laws. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian, United States and European privacy legislation.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

Third Party Links

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Data security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

Children under the age of 16

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the  interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please visit our Do Not Sell or Share My Personal Information link in the footer of this website.

Notice to California and Texas Residents – Your Privacy Choices

You may have certain rights and choices regarding our processing of your personal information. Residents in California and Texas are entitled to the following consumer rights:

·        The right to know and the right to access – You have the right to request for copies of your personal data. The first copy will be provided to you for free, however, we may charge you a small fee for any additional copies.

·        The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

·        The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

·        The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

·        The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

·        The right to withdraw consent – You have the right to withdraw your consent at any time should the processing of your data be based on consent. We may, however, continue processing your personal data if another legal ground for processing your data is available.

·        The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

·        The right to opt-out of a “sale” – You have the right to opt-out of certain data sharing practices. This right is limited to information we “sell” to third parties as described below.

California residents have the right to limit the use and disclosure of their sensitive personal information to only those purposes necessary to provide requested services or as otherwise permitted by law. Please note that we only use sensitive personal information, such as your government issued ID, to verify your identity when you opt into special discount programs on our Website.

We will not restrict or deny you access to our products and services because of choices and requests you make in connection with your personal data. Please note, certain choices may affect our ability to deliver our services or products. For example, if you ask us to delete your information, we will not be able to send you promotions or offers for our products.

Exercising Your Rights

To access or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. As permitted by applicable law, any request you submit to us is subject to an identification and residency verification process (“Data Subject Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information. You may submit a Data Subject Request by clicking here: Data Subject Request.

Only you, or someone legally authorized to act on your behalf (an “Authorized Agent”), may make a request to know or delete related to your personal data. We require Authorized Agents to provide written authorization confirming they may submit a request on your behalf. You may only submit a request to know twice within a 12-month period. We endeavor to substantively respond to a Data Subject Request within forty-five (45) days of its receipt unless we require an extension. If we reasonably require an extension, we will inform you of the reason and extension period. We may deny a request from an agent that does not submit proof you authorized them to act on your behalf.

Once we receive your request and confirm your identity, we will review your request. We may deny your deletion request if retaining the information is proper and necessary or if an exception allowing us to retain the information applies.

We do not charge a fee to process or respond to your Data Subject 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 we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@686.com.

Note to Texas Residents: In the event we deny your data rights request, Texas residents may appeal our decision by emailing us or calling us at the information provided above. You will receive confirmation of the action being taken regarding your appeal within 60 days of receipt of your appeal.

Opt-Out Requests: We may disclose or “sell/share” your personal information to third parties. “Sell” in this case does not mean providing data in exchange for money—we don’t do that. “Sell” instead means the disclosure of data, including device data and contact information, to a third party that might use that data for its own purposes, such as for personalized advertising.

You may submit a request to opt-out of these sales of by clicking the Do Not Sell or Share My Personal Information link in the footer of this website. You may also submit a request to opt-out by contacting our Privacy Officer (see Contact information below for contact details) or by email at privacy@686.com.

Notice of Financial Incentive

We may offer discounts, rewards, or other benefits in exchange for your enrollment in marketing programs or provision of personal information. Participation is voluntary, and you may withdraw at any time. The value of your personal information is reasonably related to the value of the offer provided. For details about specific programs, please refer to the terms presented at the time of enrollment.

Data retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To decide how long to keep personal data, we consider things like:

·        The amount, nature, and sensitivity of the data.

·        The potential risk of harm from unauthorized use or disclosure of the data.

·        The purposes for which we obtained the data.

·        Whether we can achieve those purposes through other means.

·        Applicable legal, accounting, or reporting requirements.

For example, personal identifiers and commercial information are retained for as long as you have an account with Westlife. Sensitive personal information is retained only as long as it is needed for verification and fraud prevention.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Privacy Choices

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, submit a request through our Do Not Sell or Share My Personal Information link in the footer of this website. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

We strive to provide you with choices regarding the personal information you provide to use. Please review the following mechanisms that allow you control over the personal information you share with us:

·        Opt-Out Signals – You can easily submit an opt-out signal on our Website by clicking the “Do Not sell or Share My Personal Information” link. You may also use opt-out preference signals such as the Global Privacy Control (GPC) to automatically opt-out of the sale/sharing of your personal information when you visit our Website.

·        Promotional Correspondence – If you have opted into to receive marketing and promotional communications from 686, you can unsubscribe from marketing emails by clicking the ‘unsubscribe button’ within the email or adjusting your user preferences in your account profile. To stop receiving SMS messages simply text ‘STOP’ to the number from which you receive such messages.

Summary of Data Disclosed to Third Parties

Below we have included a list of the categories of personal information we have collected and disclosed for a business purpose in the preceding twelve (12) months. These categories are defined under Cal. Civ. Code 1798.140(v)(1):

Category	Examples of Data	Recipient (by Category)	Who We Share  This Data With for Targeted Ads
A: Personal Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Service Providers, Payment Processors	Advertising Networks; social networks; other parties with your permission
B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, telephone number, passport number, driver’s license or state identification card number.	Service Providers	Advertising Networks; social networks; other parties with your permission
C: 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), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Not shared or collected	N/A
D: Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Service Providers,	Advertising Networks; social networks; other parties with your permission
E: Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Not shared or collected	N/A
F: Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Service Providers, Data Analytics Providers	Advertising Networks; social networks; other parties with your permission
G: Geolocation Data	Physical location or movements.	Not shared or collected	N/A
H: Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	Not shared or collected	N/A
I: Professional or employment-related information	Current or past job history or performance evaluations.	Not shared or collected	N/A
J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial Information, or student disciplinary records.	Not shared or collected	N/A
K: Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Service Providers and Advertising Networks
Sensitive Personal Information	Government-issued identifies such as Social Security Numbers, driver’s license numbers or state IDs	686 provides certain communities, such as first responders, with exclusive discounts. We use ‘ID.me’ to verify your identity and prevent fraud -  we do not use or share such information for any other reason. Please note using ID.me is completely optional.	N/A

California’s Shine the Light Law

California Civil Code Section 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of the information you provide through the website to third parties for their direct marketing purposes. To make such a request, please contact us at the information provided below.

Contact information

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at privacy@686.com or:

Privacy Officer
Westlife Distribution, LLC
227 E. Compton Blvd
Gardena, CA 90248 USA
or contact us by phone: 310-818-2300

Residents of the European Economic Area and United Kingdom

The following section applies to residents of the European Economic Area (EEA) and the United Kingdom (UK). If you are a resident of the EEA or UK you have the following data protection rights you have certain rights provided to you by the GDPR and UK GDPR, respectively, including:

·        The right to access, correct, update or request deletion of your personal information.

·        The right to object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

·        The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. Alternatively, you can indicate your marketing preferences for email, phone and postal marketing during registration or at any time by contacting us using the contact details provided below.

·        The right, if we have collected and processed your personal information with your consent, to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You may exercise these rights free of charge. Residents of the EEA and UK may submit a request to withdraw consent, delete their personal information or to access a copy of their personal information by clicking here. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.  A list of data protection authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en Please note that Westlife does not use automatic decision making systems for any decisions with legal effects or any similarly significant effects.

Legal Grounds for Processing Your Personal Information

We process your personal information under the following legal basis:

·        Performance of Contract. We need it to provide you with the products and services you request from us, to operate the services, provide customer support and personalized features and to protect the safety and security of the services;

·        Legitimate Interests. It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;

·        Consent. When you give us consent to do so for a specific purpose; or

·        Compliance with a Legal Obligation. We need to process your data to comply with a legal obligation.