1.1 Personal Information. “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. The following are categories (with non-exhaustive examples) of personal information we may collect about you and for each category the purpose for which it may be used:
|A. Individual Identifiers and Demographic Information||
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
|B. Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||
|C. Internet or Network Activity||Browsing history, search history, information on an individual’s interaction with a website, application, or advertisement, cookies, clear pixels, web server logs, web beacons, flash cookies, and other device identifiers.||
|D. Inferences Drawn from Personal Information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.||
1.2 Exclusions of Personal Information. Personal information does not include:
- Publicly Available Data. Publicly available information from government records.
- Deidentified or Aggregate Information. “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which Stio has implemented technical safeguards and business processes that prohibit reidentification of the individual “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.
1.3 Sources of Personal Information. We obtain the categories of personal information listed above from the following categories of sources:
- Personal Information You Provide. Stio collects personal information when users voluntarily submit it to us. For example, we may collect or receive information from you when you create an Account, submit your Content or Product comments, use or access Service or Content, or otherwise interact with us or other users of the Site. Additionally, Stio may collect personal information when you interact with Stio offline, such as in a Stio store or at a Stio event.
- Automatically Collected Personal Information. In addition to personal information that we may receive directly from you, Stio indirectly collects other information from you automatically through the Site. For example, we receive personal information from you when you visit and navigate our Site on any device. We may also collect personal information about you over time and across different websites, apps, and devices when you access the Site. Third parties also collect personal information this way on our Site. Stio collects some personal information automatically using cookies or other online tracking
- Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, Stio may receive personal information about you from other third party sources. We receive personal information from our business partners, social media sites, or companies that provide personal information to supplement what we already know about users, such as marketing co-ops, and website optimization consultants. For example, if you log into your Account through sign-in services (e.g., Facebook Connect), you provide Stio with permission to access certain information about you from that social networking site, such as your Facebook user ID, user profile, friends list, and profile picture. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
- To conduct research and analysis.
- To monitor the usage and performance of the Site, and to determine aggregate information about our users and usage patterns.
- To customize Content and Services that may be of interest to our users.
- To provide you with information about our Products.
- To facilitate Orders, product transactions, and process payments.
- To send users materials, updates, and information regarding the Site.
- To send you information about special events and promotions that we offer.
- To provide maintenance, support, and customer service for the Site.
- To contact users for information verification purposes.
- We may also participate in behavioral-based advertising. This means that a third party may use technology, such as a cookie or a web beacon, to identify you on the Site so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on the Site, or on other web sites.
- Related Companies. Stio may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with Stio).
- Partner Offerings. We may market to you on behalf of third parties that would like to send you information about their products and services. For example, Stio may offer a promotion in conjunction with a co-sponsor that may have special offers or services that might be of interest to our users. We may also extend special offers to you from the co-sponsor that may be of interest to you.
- Service Providers. Stio may disclose personal information to service providers for the purposes of operating our business; delivering, improving, and customizing our Content, Services, or Products; sending marketing communications, mail, or our catalog; payment processing; and for other legitimate purposes permitted by applicable law. For example, Stio contracts with payment processing providers which may process sales and Orders that users make through the Site. Stio contracts with service providers that collect information through our Site using cookies. These service providers may combine such cookie information with information from other sources to determine if you would be interested in receiving marketing communications, mail, or our catalog. Additionally, Stio participates in marketing cooperatives. As part of our participation in these marketing cooperatives, we may disclose your name and postal address (but not your email address or payment card information) so that other select reputable companies can mail you information about their products that may interest you. Personal information handled by service providers is subject to their terms and privacy policies. Please review the service provider’s terms and privacy policies to better understand how they manage your personal information.
- Legal Compliance. There may also be instances when Stio may disclose your personal information without providing you with a choice in order to protect the legal rights of Stio, other affiliated companies or their employees, agents, and contractors; to honor a request that you have made through the Site; to protect the safety and security of other users; to protect against fraud or for risk management purposes; or to comply with the law or legal process.
- M&A Transactions. If Stio sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Stio may transfer your personal information to a third party as part of that transaction.
- Social Networking. The Site may offer you the ability to share your personal information through a social networking site (e.g., Facebook, Twitter, LinkedIn), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. By making personal information available on the Site, you “opt in” to allow Stio to provide such personal information to a social networking site without your further consent. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
- Users may recommend other users to join the Site or use the Service by providing their contact information or selecting friends from a social networking site. Users may also provide information about other users of the Site or Services such as reviews of the Services or Products that he or she received or reference information.
5. RETENTION. Stio will retain your personal information as needed to fulfill the purposes for which it was collected, or until you withdraw your consent. Stio will retain and use your personal information as necessary to comply with Stio’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.
- Access to Your Personal Information. If you would like to know whether Stio has collected personal information about you, please send us the activities and services that you participated in on the Site that requested personal information. After reviewing the relevant databases, Stio will confirm whether Stio has collected such information about you and provide a list of your personal information that we have on file.
- Changes to Your Personal Information. If your personal information is incorrect, you may correct the personal information by modifying such information in your Account or sending a written request for correction to Stio's Privacy Agent at the address below. Your request must include: (a) all of the incorrect personal information that you wish to change, (b) the corrected personal information, and (c) your signature authorizing such changes. Stio will then correct the personal information in our database and send a written confirmation to you.
- Deletion of Your Personal Information. You may request that we delete your personal information by contacting us contacting us as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law.
- Marketing Communications. If you wish to stop receiving email marketing communications from Stio, please contact us at the address listed below or use the “unsubscribe” link at the bottom of any email marketing communication. If you opt out, we may still send you non-promotional communications, such as those about your Account or to facilitate Orders you have made.
- Direct Mailers. If you wish to stop receiving direct mail or our catalogs, please contact us at the address listed below.
- Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time Stio does not modify your experience based upon whether such a signal is broadcast.
7. INTERNATIONAL DATA TRANSFERS. Stio is a global company with business processes, management structures, and technical systems that cross borders. The personal information that we collect from you may be transferred to, and stored at, a destination outside of the country in which it was originally collected. This may include transfers outside of United States. It may also be processed by personnel working outside of the United States who work for us or for one of our providers. Such personnel may be engaged in, among other things, the fulfilment of your Order, the processing of your payment details and the provision of Services or Content. By submitting your personal information, you agree to this transfer, storing, or processing.
8. RESIDENTS OF CALIFORNIA.
The following applies to residents of California.
- Notice to California Residents. Stio must disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the preceding twelve months, we have disclosed the following categories of personal information in the manner described.
|Category||Personal Information is Disclosed for a Business Purpose||Personal Information is Disclosed for Valuable Consideration|
|A. Individual Identifiers and Demographic Information||Yes||Yes|
8.2 Right to Opt Out of Disclosure of Personal Information for Valuable Consideration. You have the right to direct us to not sell your personal information at any time. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized agent) may submit a request by contacting us as described below. Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us as described below. You do not need to create an Account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
8.3 Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Stio are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to us at the address listed below in the Section titled “Communications” below.
- No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
- What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
- No Discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing Services will be provided at that time.
- Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s identification information, and the authorized agent’s identification information.
Attention: Stio Privacy Agent
PO Box 1188
Jackson, WY 83001
If Stio needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.
Effective as of January 29, 2020.