Our Privacy Policy

SPLENDID PRIVACY POLICY

Last Updated: January 1, 2023

Splendid (“Splendid,” “We,” or “Us,”) has developed this Privacy Policy to notify you as to the information we collect about you, how we use it, who we share it with, how we protect it, and your rights relating to its use.

This Privacy Policy applies to information collected through:

Your use of our products and services;
Transacting via any other websites, mobile apps, or other online products and services that display or link to this Privacy Policy (collectively, "Online Environments");
Offline services, including our customer care center and door-to-door sales and delivery activities (collectively, "Offline Environments"); and
Information shared with us by other sources for our own internal purposes.

As discussed below, we have provided additional information about how we collect and share your personal information and your rights with respect to your personal information. You have the right to request a copy of the information we store about you, inquire as to how we use that information, who we share it with, request that we correct inaccuracies, request that we limit its use and sharing, or request its deletion when it is no longer subject to regulatory or compliance retention requirements. This Privacy Policy applies to both our online and offline activities.

If you have any questions or comments about this Privacy Policy or the ways in which Splendid uses the information it collects about you, please do not hesitate to contact us using the information provided in the “Contact Us" section of this Privacy Policy.

WHEN THIS PRIVACY POLICY DOES NOT APPLY

This Privacy Policy does not apply to:

Websites, mobile apps, or other products and services that have their own privacy policies;
Websites, mobile apps, or other products and services that do not display or link to this Privacy Policy

If you have any questions as to whether this Privacy Policy applies to you, please contact us using the information provided in the "Contact Us" section of this Privacy Policy.

1. INFORMATION WE COLLECT

All companies need to collect and share consumers’ personal information for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their websites and other assets, among other reasons.

“Personal Information” (or “PI”) means any information that identifies, relates to, describes, references, or is reasonably capable of being associated with you, your household, or a device. PI does not include publicly available information from government records, or deidentified or aggregated consumer information.

The types of Personal Information we collect, disclose, and sell depends on your relationship and interaction with us. Read the following sections of this Privacy Policy to learn about the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of third parties with whom we share the personal information, and if we sell the information, the categories of third parties to whom we sell it.

We may collect the following categories of PI. Not all categories may be collected about every individual:

Identifiers	Such as a real name, signature, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Commercial Information	Such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Financial Information	Such as bank account number, credit or debit card number, or other financial information.
Protected Characteristics	Such as age or gender.
Internet or other electronic network activity information	Such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
Geolocation data	Data indicating the physical real-world location of a person or device.
Inferences drawn from other personal information	To create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies).

We may collect the following categories of “Sensitive Personal Information” (or “SPI”). Not all categories may be collected about every individual:

Personal information that reveals a consumer's:
- social security, driver's license, state identification card, or passport number;
- account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; or
- precise geolocation.
Biometric information that may uniquely identify a consumer.
Personal information concerning a consumer's health.

2. WHO WE COLLECT INFORMATION FROM

We collect various categories of personal information from three classes of customers:

From customers who purchase products online we may collect commercial information, geolocation data, profiling inferences, and personal sensitive information including personal identifiers and financial information.
From customers who purchase products in retail stores we may collect commercial information, geolocation data, profiling inferences, internet or other electronic network activity information (via a 3rd party service), and personal sensitive information including personal identifiers and financial information.
From our website visitors we collect geolocation data; if you sign up for an account or email announcements, we may collect personal sensitive information including personal identifiers and financial information.

3. HOW WE COLLECT INFORMATION

We collect information from you in a variety of ways:

When you browse or purchase items online, from third party data processors
When you make a purchase in a retail store
When you make a purchase over the phone, from third party data processors
When you request information online
When you communicate with us, such as for customer service

4. HOW WE USE AND SHARE INFORMATION

We may use the information we collect to:

Manage and fulfill orders, deliver products, process payments, manage returns;
Respond to requests for information and services;
Improve our products and services;
Develop new products and services;
Develop co-branded partner relationships; and
Determine how to best protect the data of our company and our consumers.

If you make a purchase through our online or Offline Environments and authorize us to use your credit or debit card information, we will use this information to charge you as authorized. In these situations, we may also save your contact and payment information (using commonly accepted security measures) so that you can use them the next time you want to order something from us.

If you register or open an account with us, the information we collect may be used to maintain your account, provide you with access to some features of our Online Environments, or offer you the benefits and privileges that typically come along with account registration. This may include purchasing products or services, use of exclusive or personalized content or activities (such as message boards), and participation in special events and promotions (contests, sweepstakes, coupons, etc.).

We also use the information we collect for other business purposes. These include:

Sending you advertisements, notices, and other information regarding our products and services, including notifying you about special promotions, subject to your agreement;
Responding to your inquiries or support requests;
Inviting you to participate in surveys regarding our products or services;
Determining your eligibility for, and to register you in, our contests and other promotions, fulfill and deliver prizes, and contact you regarding such contests or other promotions;
Furnishing and maintaining our Online Environments; and
Securing our networks and Online Environments.

We may also use the information we collect to offer you customized content by:

Recognizing new or past visitors to our Online Environments;
Remembering your personal preferences;
Showing you more relevant and meaningful advertisements;
Better understanding the interests of our consumers and visitors to our Online Environments; and
Conducting research and analyzing the use of our Online Environments, products, services, and advertisements.

Some of our applications and mobile-optimized Online Environments may have location-based features. To deliver these features, we may access and use location data provided by your mobile device. For example, we may offer shopping features that allow you to get information about local merchants. Location information will be collected solely to deliver the requested feature and will not be further retained or stored by us.

See the purposes for the use and collection of each category of personal information listed below.

For everyday business purposes such as to process your requests, inquiries, or other communications with us, we may use:

Identifiers such as a name, address, unique personal identifier, etc.
Commercial information including property records and purchasing history

To process and manage your purchases, transactions, and payments with us, we may use:

Identifiers such as a name, address, unique personal identifier, etc.
Financial information such as bank account number, credit or debit card number, etc.
Commercial information including property records and purchasing history
Geolocation data

For auditing related to current interactions with you including counting ad impressions and unique visitors to our website, we may use:

Network Activity Data

To detect security incidents and other fraudulent activity, we may use:

Identifiers such as a name, address, unique personal identifier, etc.
Commercial information including property records and purchasing history
Network Activity Data
Inferences drawn from any of the above to create a consumer profile

To monitor and improve our website functionality, we may use:

Geolocation data
Network Activity Data

To personalize your website experience, we may use:

Commercial information including property records and purchasing history
Geolocation data
Network Activity Data
Inferences drawn from any of the above to create a consumer profile

To help maintain the safety, security, and integrity of our website, products and services, data bases and other technology assets, and business, we may use:

Identifiers such as a name, address, unique personal identifier, etc.
Network Activity Data

To respond to law enforcement requests and as required by applicable law, court order, or government regulation, we may use:

Identifiers such as a name, address, unique personal identifier, etc.

For marketing purposes to deliver content and product and service offerings, including targeted offers and ads, we may use all of the data points listed above.

5. OUR RELATIONSHIP WITH THIRD PARTIES

The Personal Information collected/stored as described above is transferred to third party service providers of Splendid for the purposes described above only.

We use third parties to improve our ability to identify visitors to our website. As part of this service, we may make available identifiers to these third parties including our visitors’ IP addresses, cookies, and hashed versions of email addresses captured from your visit. We, and third parties, use this data to obtain more information about our visitors and reach out to them through other channels, such as direct mail. You have the right to opt-out of this activity. To opt-out, please use fill out our contact us form or email us at customercare@splendid.com.

TECHNICAL INFORMATION COLLECTED AUTOMATICALLY

As described above, we may collect Geolocation Data and Network Activity Data about your visits to our Online Environments without you actively submitting such information. This information can make your use of our Online Environments easier and more meaningful by allowing us to provide better service, customize our Online Environments based on your consumer preferences, compile statistics, provide you with more relevant advertisements, analyze trends, and otherwise administer and improve our Online Environments. For more information, refer to our Cookie Policy here.

We may combine the information we collect through one or more of our Online Environments with information we collect through other Online Environments. We may also combine information collected through our Online Environments with information collected through our Offline Environments, as well as with information provided by our partners. We use this consolidated information to help us improve our Online Environments, products, and services; to communicate information to you; to enhance our marketing and research activities; and to engage in any other uses described in the "HOW WE USE AND SHARE INFORMATION" section above.

INFORMATION PROVIDED BY OUR PARTNERS

As described above, from time to time Splendid works with third parties who provide us with advertising services or facilitate promotional activities. Splendid requires that such partners maintain their own privacy policies and assert their compliance with data privacy regulations. Information you provide in response to such advertisements or promotions (such as your name, address, contact information, or product interests) will be shared with us by these third parties.

OTHER IMPORTANT INFORMATION ABOUT OUR RELATIONSHIP WITH THIRD PARTIES

Links to Other Sites – We may feature links to websites that we believe you might find useful and informative. Please be aware, however, that we do not endorse or recommend these sites’ content, products, or services, and we are not responsible for the privacy practices or other aspects of these other sites. We encourage you to be aware of and read the Privacy Policy of each site you visit. Remember, this Privacy Policy applies solely to information collected or used by Splendid.

Social Media Plugins – Our Online Environments may use social media plugins (for example, the Facebook "Like" button or "Share to Twitter" button) to enable you to easily share information with others. When you visit our Online Environments, the operator of the social plugin can place a cookie on your device, enabling that operator to recognize individuals who have previously visited our Online Environments. Please view our Cookie Policy for more information about removing cookies. If you are logged into the social media website (for example, Facebook, Twitter) while browsing on our Online Environments, the social plugins allow that social media website to receive information that you have visited our Online Environments. The social plugins also allow the social media website to share information about your activities on our Online Environments with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your "Likes" and comments on our Online Environments to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our Online Environments. We do not control any of the content from the social media plugins. For more information about social plugins from other social media websites, you should refer to those sites’ privacy and data sharing policies.

Below is a chart showing the types of Personal Information that may have been disclosed in the previous 12 months:

Categories of Third Parties to whom the Personal Information may be Disclosed

Categories of Personal Information Disclosed

Advertising companies (like ad servers, advertising agencies, technology vendors, providers of sponsored content, and others)

Sensitive Personal Information:

Demographic information

Device and online identifiers and related information

Financial information

Individual preferences and characteristics

Internet, application, and network activity

Personal identifiers

Other Personal Information:

Purchase history information

Location information

Other entities in the Delta Galil USA Inc. family of companies

Sensitive Personal Information:

Demographic information

Device and online identifiers and related information

Financial information

Individual preferences and characteristics

Internet, application, and network activity

Personal identifiers

Other Personal Information:

Purchase history information

Location information

6. RIGHTS AND CHOICES YOU HAVE ABOUT YOUR INFORMATION

You have rights with respect to your PI. If you have any inquiries regarding the personal information we collect, you may contact us using the information provided at the bottom of this Privacy Policy.

You also have the following rights with respect to your Personal Information:

Right to Notice. Before or at the time we collect Personal Information from you, you have the right to receive notice of the Personal Information to be collected and the purposes for which we use it. This Privacy Policy is intended to satisfy this requirement.
Right to Know. You also have the right to request that we disclose to you the personal information, and categories of personal information we have collected about you in the 12 months preceding your request, along with (i) the categories of sources from which that personal information was collected, (ii) the purposes for collecting or selling that personal information, (iii) the categories of third parties with whom we shared that personal information, and (iv) the categories of third parties to whom we sold or transferred that personal information.

Right to Deletion. You have the right to request that we and our third-party data processors delete the Personal Information we collect from you. However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the Personal Information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.
Right to Limit the Use of Personal Information. We may use your personal information for:

Everyday business purposes such as to process your requests, inquiries, or other communications with us
To process and manage your purchases, transactions, and payments with us
Auditing related to current interactions with you including counting ad impressions and unique visitors to our website
To detect security incidents and other fraudulent activity
To monitor and improve our website functionality
To personalize your website experience
For marketing purposes to deliver content and product and service offerings, including targeted offers and ads
To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business
To respond to law enforcement requests and as required by applicable law, court order, or government regulation

However, you may request that we limit the use of your personal information to only fulfill specific necessary purposes; e.g., to provide the ordered goods. However, we reserve the right to use your personal information for any ethical or legal concerns; e.g., to respond to law enforcement requests.

Right to Correct Inaccuracies. You have the right to request that we update your personal information to correct any inaccuracies.
Right to Opt Out of Automated Decision Making. We sometimes use your data to engage in automated decision making in order to provide a more personalized experience. You have the right to request that we do not use your data for this reason.
Right to Opt Out of the Sale or Sharing of Personal Information. We may share personal information within our Delta Galil USA Inc. family of companies and with certain third parties, in a way that may be considered a “sale” under California law even if we don’t receive money in exchange for the information. For purposes of California law, we may share with these parties all categories of personal information identified in this Policy. We do not knowingly sell the personal information of minors under 13 years of age. If you are a California resident, you have a right to opt-out of the sale of your personal information.
Right to Non-Discrimination. You will not receive discriminatory treatment by us relating to the exercise of your privacy rights.

You can exercise any of your rights by using the information in the Contact Us section below.

VERIFICATION

We value the security and confidentiality of your Personal Information. Therefore, if you exercise your right to notice, right of access, right to deletion, right to limit the use of personal information, right to correct inaccuracies, right to opt out of automated decision-making, or your right to opt out of the sale or sharing of personal information, we may need to first verify your identity to make sure that you are the person about whom we have collected Personal Information. We verify every request carefully, and the level of proof required will depend on the sensitivity and value of the requested Personal Information.

You may also authorize someone else to submit these requests on your behalf (an “Authorized Agent”). To designate an Authorized Agent, you must provide us with a notarized copy of a power of attorney, or ask the Authorized Agent to provide us with a copy of your written permission and a scanned copy of their own government-issued ID.

YOUR OPTIONS

In addition to your rights, you may always limit the amount and type of information that we collect from you by choosing not to enter or provide that information. To the extent that information is required in order to deliver products and services to you (e.g. delivery address), such a decision may impact our ability to provide you with those products and services. Some of the products and services offered through our online and Offline Environments may ask whether you wish to opt into or out of our contact lists for offers, promotions, and additional products and services that may be of interest to you.

Emails – You can opt out of marketing emails we may send to you by following the "unsubscribe" instructions provided in such emails. If you opt out of our marketing emails, we may still send you transactional and relationship emails, such as emails about your orders and account.

Texts – You may be sent text messages relating to our product deliveries or promotional opportunities. You may opt out of these texts by replying to the text with the word “STOP.”

Tracking tools – You may also be provided with preference questions or preference boxes allowing you to indicate that you do not want our Online Environments to use tracking technologies, such as cookies, to "remember" the information collected on return visits, such as user IDs or mailing addresses; however, the tracking technologies used to collect unidentifiable information generally do not provide you with the ability to opt out of the tracking technologies. In addition, you may be able to control the use of tracking tools and limit retargeting activities as follows:

The help function of your internet browser may contain instructions on how to manage cookies, including an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. For more information about how Splendid uses cookies, see our Cookie Policy.

Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. We do our best to respond to these signals and to respect your choice to opt out of tracking tools we may use.

Geolocation data – You may prevent your mobile device or internet browser from sharing location data by adjusting your mobile device or browser settings.

7. SECURITY AND RETENTION

HOW WE SECURE YOUR INFORMATION

We have instituted physical, technical, and procedural safeguards to store and maintain information we collect in a secure environment. You may also be required to use a password to access certain pages on our Online Environments where certain types of your information can be changed or deleted. It is therefore important for you to protect against unauthorized access to your password and to your device. You take full responsibility for maintaining the complexity and confidentiality of your password. While we have implemented safeguards, you should be aware that Internet security technology rapidly changes. We cannot guarantee that the safeguards we employ today can protect your information from the threats of tomorrow. You should also be aware that despite our efforts, factors beyond our control may result in disclosure of information. Accordingly, we are not able to guarantee that your information will be secure under all circumstances. We retain Personal Information collected through the online and offline services as long as necessary to provide the services, products and information you request or as permitted by applicable law.

RETENTION

Your personal information is stored for the length of time necessary for the legitimate business purposes disclosed in this Privacy Policy. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Service, or take other actions permitted by law. If your account is terminated or suspended, we may also maintain some information to prevent re-registration.

MESSAGE BOARDS AND DISCUSSION FORUMS

Some of our Online Environments may allow you to share comments or other information. Any information that you may disclose through message boards, discussion forums, blogs, or on other public areas on our Online Environments becomes public information.

OUR POLICY ON CHILDREN’S INFORMATION

We do not knowingly collect or use any information from children (we define "children" as minors younger than 13 (thirteen) years of age) on our online or Offline Environments. We do not knowingly allow children to order our products or services, communicate with us, or use any of our Online Environments. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

INTERNATIONAL TRANSFERS

Our online and Offline Environments are designed for and targeted to audiences in the United States (“U.S.”) and are governed by and operated in accordance with the laws of the U.S. While users from countries other than the U.S. may access our online and Offline Environments, we make no representation that such environments are operated in accordance with the laws or regulations of, or governed by, other nations.

Please be aware that by accessing our online and Offline Environments, or providing us with information, you understand and agree that:

Information collected from you may be transferred to and stored on servers located in the U.S.;
To the extent you are a resident of a country other than the U.S., you consent to the transfer of such information to the U.S. for our use in accordance with this Privacy Policy; and
This Privacy Policy, and the collection and use of information pursuant to this Privacy Policy, shall be governed by and construed in accordance with the laws of the state of New York without giving effect to any principles of conflicts of law, with all actions or proceedings arising in connection with this policy to be tried and litigated only in the state courts or federal courts located in New York County, New York.

8. ACCESSIBILITY

If need assistance to review or access this Privacy Policy due to a disability, you may:

Open the accessibility menu by clicking on the accessibility icon in the bottom left corner of the webpage or by typing CTRL+U; or
Contact us via the options defined in the “Contact Us” section below to request access to this Policy in an alternative format.

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this Privacy Policy without prior notice to reflect technological advancements, legal and regulatory changes, and good business practices. If we change our privacy practices, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth at the top of this Privacy Policy.

10. CONTACT US

If you have any questions, complaints or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your data rights under California law (or any applicable data law in any other state), please do not hesitate to contact us by:

Clicking on the "Contact Us" link on the online environment you are visiting;
Emailing our Customer Care Center at customercare@splendid.com; or
Calling our Customer Care Center at 1-855-303-8820.