Privacy Policy
EFFECTIVE DATE: FEBRUARY 18th, 2023 Chrome Horse, LLC. ("Chrome Horse Society", "us", "we" or "our") is committed to respecting and protecting the privacy of our Users. We understand and acknowledge that our Users have a legitimate expectation of privacy, including an expectation that we will protect their identities and personal information from disclosure to third parties, and we are committed to upholding that expectation of privacy with very limited exceptions, as described below. "When the term "Users" is used in this Privacy Policy and related documents, it shall mean: (i) visitors and users of our website and our apps as defined below; and (ii) consignors to Chrome Horse Society ("Consignors") who are also subject to additional consignment terms pursuant to our Consignment Agreement ("Users", "you" or "your"). As used herein, the "Site" shall mean our website (www.ChromeHorseSociety.com.) In the Site, we provide Users with access to sales of consigned luxury items and other related services (the "Service" or "Chrome Horse Society Service"). This Privacy Policy covers personal information collected about our Users and is part of our overall Terms of Service ("TOS"). Included in this Privacy Policy is: (i) our Cookie Policy; (ii) an additional supplementary policy specifically for citizens of the European Union ("EU Privacy Policy"); and (iii) an additional supplementary policy specifically for residents of California ("CCPA Privacy Policy"). This Privacy Policy describes:
the information identifying you that we collect; how we use this information; the legal basis upon which we process it; with whom it is shared; and how it is stored.
This Privacy Policy also describes other important topics relating to your personal information and privacy. Please review this Privacy Policy to better understand our practices as they apply to your personal information. By using Chrome Horse Society Service or accessing the Site, you confirm that you have read and understood the entirety of this Privacy Policy and agree to be bound by it and the other documents referenced herein. Our Terms of Service (including Consignment Terms if you are a Consignor) apply to Chrome Horse Society Service and this Site. If you do not agree to them, then you should not continue to use Chrome Horse Society Service or the Site From time to time, we may modify this Privacy Policy at our sole discretion. If we make any updates or changes to this Privacy Policy, all modifications will be posted to this Site, and will be effective immediately upon our posting and, where appropriate, notified to you by post or email. By continuing to use Chrome Horse Society Service, or using the Site, after updates are posted and effective you are confirming that you have read and understood the latest version of the Privacy Policy. WHAT PERSONAL INFORMATION DO WE COLLECT? Identifiers. We collect personal information of all Users of Chrome Horse Society website, which includes identifiers such as:
your name; phone number; postal address; email address. Internet Protocol (IP) address;
Internet or other electronic network activity information including:
browser type; your Internet Service Provider (ISP); website referring/exit pages; platform type; date/time stamp; other information related to your use of the Site. We may receive some personal information about you from third parties such as public websites and social media platforms.
Commercial information
information about your use of Chrome Horse Society Service (including account related information such as payment information, purchase history,); customer services information; and customer relationship management and marketing information.
USE OF PERSONAL INFORMATION WE COLLECT We, or third party service providers acting on our behalf, collect, use, and store the personal information we collect to:
allow you to access and use our Site; communicate with you (see Communicating With You section below); register users; process requests and orders (including membership registration); provide technical support; store information about your preferences; recognize you when you return to our Site; enable you to participate in our opinion polls, surveys, contests, or sweepstakes; administer our Site; ensure the security of our services and our Site; comply with any procedures, laws, and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so (subject to our making all reasonable efforts, consistent with applicable laws and regulations, to protect our Users’ identities and personal information from disclosure to third parties); and establish, exercise, or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
COMMUNICATING WITH YOU We will contact you (including by email or mail) with information about our products, services, and offers which either you request, or which we believe you may be interested in (including through newsletters if it is in our legitimate interests, for business development and marketing purposes, unless you have told us that you don’t want to receive these messages by sending us an email at info@ChromeHorseSociety.com, or unsubscribing within the promotion email itself. From time to time we will send you service-related emails, such as a welcome email when you register for the Site. ONLINE TRACKING Like most websites, we, our service providers, and our third-party partners may collect certain information about your interaction with our Site. This information may be stored in log files. Information stored in log files may include IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and other information. We collect this information through the use of cookies and other similar technologies. We use this information to analyze demographic and other trends, administer the site, track aggregate usage of the Site, and provide you with relevant advertising. Where we use cookies on our Site, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you will not be able to access all or parts of our Site or to use all the functionality provided through our Site. For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy. By continuing to use our Site and/or our services, you are agreeing to our use of cookies as described in our cookies policy. Your Privacy Choices, the legal basis on which we use your personal information and right to control our use of your personal information, are described below. SHARING OF PERSONAL INFORMATION THIRD PARTIES We may need to share your personal information with our contractors in the course of operating our business and providing products or services to you. These contractors include vendors and suppliers, including but not limited to payment processors, suppliers of technical and support services, logistics providers, and cloud service providers that provide us with technology, services, and/or content for the operation and maintenance of our Site or Service. We will also share your personal information with companies that assist us in our marketing, advertising and promotional activities, analytics, and search engine providers that assist us in the improvement and optimization of our Site. Access to your personal information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function. We require our contractors to keep the personal information they are provided with confidential and to comply with the terms of this Privacy Policy and applicable laws. We will not rent, sell, or share your personal information with third parties or third-party advertisers for their own marketing purposes without your consent except to provide you with a product or service you request or as described in this Privacy Policy. Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes. We may also disclose and use anonymized, aggregated reporting and statistics about users of our website and apps or our goods and services and from interactions with us and our brands on social media for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymized, aggregated reports or statistics will enable our users to be personally identified. RETENTION OF PERSONAL INFORMATION We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. In order to enforce the terms of this Privacy Policy, resolve disputes, or provide information to satisfy applicable governmental laws, regulations, investigations or proceedings, we may need to retain your personal information in our files. We will do so in compliance with applicable law. YOUR PRIVACY CHOICES UPDATES TO YOUR INFORMATION You can contact us at any time to update, change or delete personal information ChromeHorseSociety maintains about you by emailing us at info@ChromeHorseSociety.com CHOICE/OPT-OUT Users who no longer wish to receive our newsletters, alerts, or promotional communications may opt-out of receiving these communications at any time. ADDITIONAL INFORMATION THIRD PARTY WEBSITES This Site links to third party websites. Please be aware that we do not control these third-party websites or any of the content contained on those websites. They are solely responsible for handling all spirit-related ecommerce/sales. ACCESS BY AGE Our Site is not directed to anyone under the age of 21, and our Terms of Service prohibit anyone underage from using our Site or Service. We do not knowingly collect any information from anyone under the legal drinking age. SECURITY We take precautions to protect information that we collect from our Users. We protect the information entrusted to us by taking all reasonable precautions to safeguard the confidentiality of personal information, including through use of appropriate physical, technical, and administrative safeguards and measures. These protections include restricting access to personal information to employees who need the information to perform a specific job. Chrome Horse Society provides its employees training on its security and privacy practices. Technical safeguards and measures include use of encryption, passwords for access to our systems and use of anti-virus software. However, in the course of provision of your personal data to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, no information security safeguards can be guaranteed to be completely secure, so you should use caution whenever providing personal information online, electronically or otherwise. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it. Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. HOW TO CONTACT US If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at info@ChromeHorseSoiety.com If you are a California resident and if you wish to submit a request to exercise your consumer rights under the CCPA, you may also contact us via email at info@ChromeHorseSoiety.com COOKIE POLICY EFFECTIVE DATE: FEBRUARY 18th 2023 Our website uses cookies. This policy explains what cookies are, why we use them, and how you can manage their use. WHAT ARE COOKIES? Cookies are small text files which are sent to your browser when you visit our website. When you visit our website again, the cookie allows our website to recognize your browser. When you visit our website, cookies may also be sent to your browser by other websites that are used for advertisements on other sites you may visit. Cookies are useful because they help us make your website experience more enjoyable. They allow us to recognize your device (e.g. your laptop or mobile device) so that we can tailor your experience of our website. You can find out more about cookies at: https://www.epic.org/privacy/internet/cookies/. WHY DO WE USE COOKIES? Cookies do many different jobs on this website, such as letting you navigate between pages efficiently, remembering your preferences, remembering your username and password, enabling you to keep goods in your shopping basket, letting us analyze how well our website is performing, and improving your experience. They also help ensure that advertisements you see while you are on other websites are more relevant to you and your interests. WHAT TYPES OF COOKIES DO WE USE? We want you to understand the different types of cookies that we use on our website. Some of these cookies are essential to the operation of our website. Others are not essential but help to improve our website by collecting user information or try and improve your experience of our website by remembering your choices. Generally, our cookies perform up to four different functions: TYPE 1 – STRICTLY NECESSARY COOKIES – WHICH ENABLE SERVICES YOU HAVE SPECIFICALLY ASKED FOR We use several cookies which are essential to the operation of this website. For example, these types of cookies let us identify subscribers and ensure they can access the subscription-only areas of this website, enable our website to remember the goods that you add to your shopping cart, provide the necessary security your visit to our website requires, and help ensure the content of the pages you request load quickly. Without these cookies, services that you have asked for cannot be provided. TYPE 2 – PERFORMANCE COOKIES – WHICH COLLECT ANONYMOUS INFORMATION ABOUT THE WEB PAGES YOU VISIT These cookies collect information about how visitors use our website, for example, which pages our visitors go to most often, and if they get error messages on those pages. These performance cookies don't collect information that identifies you as an individual – all information they collect is aggregated and anonymous. The information gathered is only used to improve how our website works. We use Google Analytics on our website to help us analyze how our website is used. You can find out more about this popular website analytics tool here: http://www.google.com/analytics/index.html. Google Analytics uses performance cookies to track visitor interactions. For example, by using cookies Google can tell us which pages our users view, which are most popular, what time of day our website is visited, whether visitors have been to our website before, what website referred the visitor to our website, and other similar information. All this information is anonymized. Google takes the privacy and security of your Google Analytics data seriously and you can find out more about how it protects your data here:
These cookies allow our website to remember choices you make, such as, remembering your username, the region you are in, and changes you make to various other parts of our website which you can customize, such as your MySales page. The aim of these cookies is to provide you with a more personal experience so that you don't have to reset your preferences each time you visit us. TYPE 4 – TARGETING OR ADVERTISING COOKIES WHICH REMEMBER YOUR BROWSING HABITS TO TRY AND DISPLAY RELEVANT ADVERTISING WHEN YOU VISIT OTHER ONLINE SITES. These cookies track your browsing habits so that we can show you advertising which we hope is relevant to your interests. We believe it is useful to show you advertisements that are tailored to your interests. These advertising cookies use information about your web browsing activity to group you with other users who have similar interests and show you advertisements based upon those interests. For example, these cookies may remember that on our website you viewed pages relating to particular products. Based on that information, with our permission, third party advertisers can place cookies on your browser to enable them to show you those products while you visit other sites. These types of cookies are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaigns. WE MAY TRACK WHETHER YOU OPEN EMAILS THAT WE SEND Our emails may contain a web beacon to track who opens an email, when, and whether that user clicks on any of the links in the email. We may use this information to help us analyze which of our users are interested in particular topics. When you delete the email, the web beacon will be deleted. HOW TO MANAGE COOKIES ON OUR WEBSITE Cookies do lots of important jobs on our website and help to make your online experience more personal and more enjoyable. By using our website, you are deemed to consent to the use of cookies as described in this cookie policy. However, you can disable all our cookies if you choose. If you do so, you may find that significant parts of our website do not work at all, or do not work correctly. DISABLING COOKIES If you would like to disable targeting, advertising or cookies, which remember your browsing habits and try and display relevant advertising when you are online, you can visit http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to turn off these cookies you will still see advertising on the internet, but it may not be tailored to your interests. It does not mean that you won't be served any advertisements while you are online. While many companies involved in using targeting, advertising or cookies and serving online behavioral advertising appear at the above link, not all do. Therefore, even if you choose to turn off cookies used by all the companies listed, you may still receive some targeting, advertising or cookies and some tailored advertisements from other companies. You can also manage this type of cookie in the privacy settings on the web browser you are using. Please see below for more information. DISABLING OTHER COOKIES You can disable and/or delete all types of cookies by using your browser settings. Cookies are generally easy to disable and/or delete but how you do so varies from browser to browser. The "help" function within your browser should tell you how to do it. The best way may be to close your browser and then search for "cookie folder" or "cookie manager" or simply "cookie". FURTHER INFORMATION If you have any questions relating to this Cookie Policy, please contact us using the information in the HOW TO CONTACT US section above. EU PRIVACY POLICY EFFECTIVE DATE: FEBRUARY 18th 2023 This European Union Privacy Policy ("EU Privacy Policy") is a supplement to the Privacy Policy and Cookie Policy of Chrome Horse,LLC. ("Chrome Horse Society", "us", "we" or "our") and applies solely to Users who are citizens of the European Union. When the term "Users" is used in this EU Privacy Policy, it shall apply only to those who are citizens of the European Union and are consumer(s), visitors and users of our website; Defined terms as used herein shall have the same meaning as defined terms in the General Data Protection Regulation (GDPR). LEGAL BASIS FOR USE OF YOUR PERSONAL INFORMATION In order to comply with European data privacy laws we are required and have considered the legal basis for using your personal information as set out in this EU Privacy Policy, which are as follows:
our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our Site which you accept by browsing our Site and/or to comply with our contract to provide Chrome Horse Society); or our use of your personal information as is necessary to complying with our legal obligations; where none of the above apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Site). Our legitimate interests are to:
run, grow and develop our business; operate our Site; carry out marketing, market research and business development; provide goods and services to our customers and consignors, make and receive payment, provide customer services and to know the identity of the customer that we are providing services to; and place, track and ensure fulfillment of orders with our vendors.
RIGHTS IF YOU ARE A CITIZEN OF THE EUROPEAN UNION If you are a citizen of the European Union, then you have certain rights in relation to your personal information which are set out below. If you would like further information in relation to these or would like to exercise any of them, please contact us by using the contact information in the HOW TO CONTACT US section at any time. You have the right to request that we:
provide access to any personal information we hold about you; update any of your personal information which is out of date or incorrect; delete any personal information which we are holding about you; restrict the way that we process your personal information; stop processing your personal information for direct-marketing purposes; provide your personal information to a third party provider of services; provide you with a copy of any personal information which we hold about you; or consider any valid objections which you have to our use of your personal information.
We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make. CCPA PRIVACY POLICY EFFECTIVE DATE: FEBRUARY 28th 2023 This California Consumer Privacy Act Privacy Policy ("CCPA Privacy Policy") is a supplement to the Privacy Policy and Cookie Policy of Chrome Horse,LLC. ("Chrome Horse Society", "us", "we" or "our") and applies solely to Users who are residents of the State of California (as defined in Section 17014 of Title 18 of the California Code of Regulations). When the term "Users" is used in this CCPA Privacy Policy, it shall apply only to those who are residents of the State of California and are consumer(s), visitors and users of our website. Defined terms as used herein shall have the same meaning as defined terms in the CCPA. WHAT PERSONAL INFORMATION DO WE COLLECT? We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). The CCPA sets forth certain categories of information under Cal. Civil Code §1798.140 (o)(1) and we have listed all of those categories below. For each category, we have provided information as to whether or not we have collected personal information under those categories within the last twelve (12) months: A. Identifiers We collect personal information of Users of Chrome Horse Society website and our apps, which fall within the category of Identifiers and which include personal information such as: 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. B. Personal information categories listed in Cal. Civ. Code § 1798.80(e) (the California Customer Records Statute) We collect personal information of Users which may include personal information such as: A name, signature, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Please note that some personal information included in this category may overlap with other categories listed herein. C. Characteristics of protected classifications under California or federal law We collect personal information such as 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) if voluntarily provided by a job applicant as a result of a job application process or voluntarily submitted as part of employment or Human Resources process. D. Commercial Information This includes information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Included in this category is:
Information about Chrome Horse Society including:
information about your use of Chrome Horse Society (including account related information such as payment information, purchase history); customer services information; and customer relationship management and marketing information.
- Biometric Information We do not collect biometric information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. F. Internet or other electronic network activity information including:
browser type; your Internet Service Provider (ISP); website referring/exit pages; platform type; date/time stamp; other information related to your use of the Site.
THE BUSINESS OR COMMERCIAL PURPOSES FOR THE PERSONAL INFORMATION WE COLLECT We may disclose your personal information to a third party for business or commercial purposes. When we disclose personal information for a business purpose, we enter into a written contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except for providing the services set forth in the contract. Accordingly, we may use or disclose the following personal information business or commercial purposes:
allow you to access and use our Site; communicate with you (see the Communicating With You section in our Privacy Policy); register users; process requests and orders (including membership registration); provide technical support; store information about your preferences; recognize you when you return to our Site; enable you to participate in our opinion polls, surveys, contests, or sweepstakes; administer our Site; ensure the security of our services and our Site; comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
CATEGORIES OF PERSONAL INFORMATION SHARED FOR BUSINESS OR COMMERCIAL PURPOSES In the preceding twelve (12) months, we have disclosed the following categories of personal information for business or commercial purposes: Category A: Identifiers Category B: California Customer Records personal information categories Category C: Protected Characteristics Classifications under California or federal law Category D: Commercial Information Category F: Internet or other electronic networking activity information Category I: Professional or employment-related information Category K: Inferences drawn from an of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions and behavior We disclose your personal information for a business purpose to the following categories of third parties:
Service providers. Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information. YOUR PRIVACY RIGHTS AND CHOICES If you are a consumer as defined in the California Consumer Privacy Act (CCPA), i.e., a resident of California as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in relation to your personal information under the CCPA. Under the CCPA, you have the following rights:
Right to Request Information Collected. If we collect personal information about you, you have the right to request that we disclose to you the following upon our receipt of a verifiable consumer request from you: The categories of personal information we have collected about you The categories of sources from which the personal information about you is collected The business or commercial purpose for collecting or selling personal information The categories of third parties with whom we share personal information and The specific pieces of personal information we have collected about you
Right to Request Information Collected and Shared for a Business Purpose. If we collect personal information about you that is disclosed for a business purpose, you have the right to request that we disclose to you: The categories of personal information that we have collected about you The categories of personal information we disclosed about you for a business purpose
Right Not to Be Discriminated Against. You have the right to not be discriminated against by a business because you exercised any of the consumer's rights under the CCPA, including, but not limited to, by: Denying goods or services to you Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties Providing a different level or quality of goods or services to you or Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Right to Request Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to: Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. Debug products to identify and repair errors that impair existing intended functionality. Exercise our right to free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. Comply with a legal obligation. Otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided it.
Right to Request Access and Data Portability. Upon receipt of a verifiable request from you to access your personal information we shall promptly take steps to disclose and deliver, free of charge to you, the personal information in accordance with Cal. Civil Code §1798.100 (d). The personal information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit this information to another entity without hindrance. We may provide personal information to you, but we are not required to provide personal information to you more than twice in a 12-month period.
CONTACT INFORMATION If you are a California resident and if you wish to submit a request to exercise your consumer rights under the CCPA or if you have questions regarding this policy, you may contact us by email at info@ChromeHorseSociety.com. ADDITIONAL CALIFORNIA PRIVACY RIGHTS California's "Shine The Light" law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. Chrome Horse Society does not distribute your personal information to outside parties for their direct marketing without your consent, except as provided for in this Privacy Policy.
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