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Effective Date: January 1, 2023

This Tribal Sportswear, a division of Haggar Canada Co. (“Tribal,” “Company,” “us,” “we,” or “our”) California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”). This Notice supplements Tribal’s other privacy policies and notices, including our Privacy Policy. In the event of a conflict between any other Tribal policy, statement, or notice and this Notice, this Notice will prevail as to California consumers and their rights under the CCPA.

This Notice does not apply to job applicants or current and former employees/contractors. If you are a California employee, current or former employee/contractor, or job applicant, a separate privacy notice will be provided to you in the course of your interaction with us in that capacity. If you have any questions, please contact us as provided below.

Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.

1. HOW AND WHY WE COLLECT, USE, AND DISCLOSE PERSONAL INFORMATION

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated, and the CCPA exempts certain additional categories of information from its purview, such as information subject to other laws and regulations. This Notice applies only to information governed by the CCPA.

We may collect, use, and disclose Personal Information for business purposes consistent with applicable laws as identified below. Where we disclose applicable Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.

Category of Personal Information

Purposes for Collection, Use, and/or Disclosure

 

Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose

Identifiers, including real name, alias, account name, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers

• To maintain your accounts with us

• To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback

• To send you marketing materials and advertisements

• To recognize you when you use our services

• To show you relevant ads while you browse the internet or use social media

• To allow you to participate in promotions, sweepstakes, contests, and rewards programs

• Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes

• To detect and prevent fraud against you and/or us

• Service providers

• Affiliates

• Data analytics providers

Personal information described in Cal. Civ. Code § 1798.80(e), including name, address, telephone number, and payment information

Some Personal Information included in this category may overlap with other categories

• To maintain your accounts with us

• To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback

• To send you marketing materials and advertisements

• To recognize you when you use our services

• To show you relevant ads while you browse the internet or use social media

• To allow you to participate in promotions, sweepstakes, contests, and rewards programs

• Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes

• To detect and prevent fraud against you and/or us

• Service providers

• Affiliates

• Data analytics providers

Characteristics of protected classifications under California or federal law, including age and date of birth, or languages spoken.

• To send you relevant marketing materials and advertisements

• To tailor our communications to you

• To improve our services, and our products, marketing and advertising

• Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes

• Service providers

• Affiliates

• Data analytics providers

Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

• To maintain your accounts with us

• To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback

• To send you marketing materials and advertisements

• To recognize you when you use our services

• To show you relevant ads while you browse the internet or use social media

• To allow you to participate in promotions, sweepstakes, contests, and rewards programs

• Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes

• To detect and prevent fraud against you and/or us

• Service providers

• Affiliates

• Data analytics providers

Internet or other electronic network activity information , including Internet or other similar activity, browsing history, search history, information on a consumer's interaction with a website, application logs, device data and registration, social media account information or advertisement

• To allow you to participate in the features we offer

• To provide you with appropriate products and recommendations

• To help you find relevant products more quickly

• To tailor our communications to you

• To provide customer service and support

• To send you relevant coupons

• To allow you to participate in promotions, sweepstakes, contests, and rewards programs

• To improve our services, and our products, marketing and advertising

• Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes

• To detect and prevent fraud against you and/or us

• Service providers

• Affiliates

• Data analytics providers

Geolocation data

• To recognize you when you use our services

• To show you relevant ads while you browse the internet or use social media

• To allow you to participate in promotions, sweepstakes, contests, and rewards programs

• Auditing, research and analysis, to maintain and improve our services, and for any other

• To detect and prevent fraud against you and/or us

 

• Service providers

• Affiliates

• Data analytics providers

Audio, electronic, visual, thermal, olfactory, or similar information, including audio recordings of customer care calls, video, or similar information

• To provide you with customer service

• To improve our products and services

• Service providers

• Affiliates

• Data analytics providers

Inferences used to create a profile

• To provide you with appropriate products and recommendations

• To improve our services, and our products, marketing and advertising

• To provide you with a better website or app experience

• Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes

• To detect and prevent fraud against you and/or us

 

• Service providers

• Affiliates

• Data analytics providers

Other Information, such as information that does not directly fit within one of the categories defined by the CCPA, including the contents of communications you send to us by phone, email, text, online chat, etc.

• To communicate with you about our products and services, your orders, and to provide customer service and support

• To improve our websites, apps, products, and marketing

• To allow you to participate in our promotions, sweepstakes, contests, and loyalty programs

• To detect and prevent fraud against you and/or us

• Service providers

• Affiliates

• Data analytics providers


Disclosing Your Personal Information


We may disclose each of the categories of Personal Information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Personal Information was collected including, but not limited to:

  • Auditing related to ads;
  • Helping to ensure security and integrity;
  • Debugging, repairing, and improving functionality;
  • Short-term, transient use;
  • Performing services on our behalf;
  • Providing advertising and marketing services, as applicable;
  • Internal research for technological development; and
  • Verifying quality and/or safety.

In addition to the other purposes for collection, use, and disclosure of Personal Information described in this Notice, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.

Sources of Personal Information

We may collect Personal Information from the following sources:

  • Directly from you.For example, when you sign up to receive information from us, when you place an order, or any other time you submit Personal Information to us voluntarily.
  • Automatically when you use our website. For example, we may collect your usage history when you use our website.
  • Other parties. For example, we may receive Personal Information from service providers or retail partners who provide us with IT services, advertising services, or help facilitate our sales.
  • Affiliates. We may receive Personal Information from our affiliates.
  • Social media services. For example, we may collect publicly availability information about you when you interact with us on Instagram, Facebook, or Twitter.

Tracking Technologies

We may use tracking technologies, such as cookies, including tracking technologies managed by vendors or external parties. Tracking technologies can generally be categorized as follows:

  • Necessary or essential. These tracking technologies are used for core functionality, for example for security and to enforce your privacy preferences. Without these cookies, some functionality on our websites and apps may fail.
  • Functional or analytics. These tracking technologies help to improve our websites and apps by allowing us to understand how they are used and how they perform. We may also use location-aware technologies for purposes such as verifying your location and delivering or restricting content based on your location.
  • Advertising. These tracking technologies help personalize ads that are shown to you on our websites and apps. If enabled, these tracking technologies will allow other parties to engage in advertising based on your use of online services.

We may use Google Analytics or other providers for analytics services. We may also implement Google Analytics Advertising Features such as remarketing with analytics and interest-based ads. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to, e.g., deliver advertisements, measure your interests, and/or personalize content. For more information on how Google Analytics uses data collected through our services, visit http://www.google.com/policies/privacy/partners. To opt out of Google Analytics cookies, visit https://tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-Out Browser Add-On.

How Long We Keep Your Personal Information

We will store your Personal Information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the Personal Information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider 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 process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records or take appropriate steps to properly anonymize, deidentify, or aggregate it, where legally applicable.

Sharing and Selling Personal Information

The chart below shows the categories of Personal Information we have sold or shared with third parties for cross-context behavioural advertising. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.

Sales and Sharing of Personal Information

Category of Personal Information

Sold?

 

Share for Cross-Context Behavioural Advertising?

Categories of Third Parties Which the Information Was Sold or Shared

Purposes for Selling or Sharing

Identifiers, for example, IP address, name, email .... etc.

No

Yes

Advertising partners

Marketing providers

To provide you with personalized advertising

To identify products you may be interested in

Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To submit a request, please use our Consumer Rights Request forms linked below, or call 1-833-8-TRIBAL. Please note that if you submit a request to know, request to delete or request to correct, you will be asked to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

1. The categories of Personal Information we have collected about you, including:

  • a. The categories of sources from which the Personal Information was collected;
  • b. Our business purposes for collecting, selling, or sharing Personal Information;
  • c. The categories of recipients to which we disclose Personal Information;
  • d. The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
  • e. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.

2. The specific pieces of Personal Information we have collected about you.

To submit a Right to Know request, please use our webform, available here.

Right to Delete Your Personal Information.You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions. To submit a Right to Delete request, please use our webform, available here.

Right to Correct Inaccurate Information.. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information. To submit a Right to Correct request, please use our webform, available here.

Right to Opt Out of Sales and Sharing of Personal Information.. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To submit a Right to Opt Out request, please use our webform, available here.

Right to Limit Use and Disclosure of Sensitive Personal Information.. We do not collect, use, or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Non-Discrimination for the Exercise of Your Privacy Rights.If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

2. NOTICE OF FINANCIAL INCENTIVE

Tribal operates promotional programs that offer financial incentives, including the Email Sign Up Rewards Program (“Email Sign Up Rewards”). A financial incentive notice covering these programs follows below. We may add or change programs and/or their terms by posting notice on the program descriptions, so check them regularly.

Program

Incentive Offered

 

Material Terms

How to Opt In

Email Sign Up and Rewards

Consumers earn 15% off their first purchase

Email Sign Up Rewards are available to consumers who are sixteen (16) years of age or older, and discounts are redeemable only at shoptribalfashion.com or participating retailers.

Tribal collects Personal Information to facilitate its operations and provide you with Email Sign Up Rewards benefits including:

 Identifiers, such as name and email.

 Protected classification characteristics under California or federal law, such as age.

 Commercial Information, such as records of products or services purchased, obtained, or considered and coupon or Email Sign Up rewards usage.

 Internet Activity Information, such as browsing history, search history, and information regarding your interaction with our website.

 Geolocation data, your location inferred from your IP address.

 Sensory Data, such as audio recordings of customer care calls, video, or similar information, as applicable.

Participating in the Email Sign Up benefit is entirely optional but is subject to additional Terms and Conditions. You may opt in by providing your email address on our website here at the link available from time to time at our home page, shoptribalfashion.com.


Value of Consumer Data

The financial incentive we offer to adult consumers through the programs identified above is reasonably related to the value of the adult consumer’s data. Tribal has made a good faith estimate of the value of adult consumers’ data based on relevant expenses related to the collection and retention of adult consumers’ Personal Information as part of the Email Sign Up Rewards program.

Withdrawing from our Financial Incentive Programs

California consumers may make a personal information deletion request under the CCPA. The consumer will then be sent an email requesting that they confirm that they want to delete their respective program data. You may, however, terminate program participation at any time, as explained in each respective program’s terms or by calling us at 1-833-8-TRIBAL. Upon a termination request, some program data associated with the terminated account may be retained for record keeping, tax reporting, and other legally permissible purposes. You can opt-out of non-program marketing emails or delete your Personal Information from our active marketing lists and retain your program account and benefits.

3. CALIFORNIA “SHINE THE LIGHT”

We do not share personal information with third parties for those third parties’ own direct marketing purposes. Californians may request information about our compliance with this law by sending us mail at Tribal Sportswear, Attn: General Counsel, 1507 LBJ Freeway, Suite 100, Farmers Branch, TX 75234.

4. HOW TO CONTACT US

For more information on your California privacy rights, please contact us by phone at 1-833-8-TRIBAL, online at https://www.shoptribalfashion.com/us_en/contact-us, or by mail at Tribal Sportswear, Attn: General Counsel, 1507 LBJ Freeway, Suite 100, Farmers Branch, TX 75234.