HALSTEAD PRIVACY Notice

Last Updated: February 20, 2024

 

This privacy policy (“Privacy Notice”) is intended to provide you with the specific details about how Halstead Bead, Inc. (“Halstead,” “we,” and “us”) collects and processes your personal and personally identifiable information through your use of the website and related services (“Website”). Halstead is a data processor and data controller of the information collected through the Website.

 

You understand and agree that Halstead may store and process your personal or personally identifiable information (defined below) on computers located outside of your current location, including, but not limited to, in the United States. By using the Website, you agree to the collection and processing of your Personal Information in a location other than your current location.

 

Before using the Website or providing information to us, please carefully review this Privacy Notice. By using or accessing the Website, you agree that we may collect and use your information in accordance with this Privacy Notice, as revised from time to time. If you have any questions or suggestions regarding our Privacy Notice, or if your personal information is not accurate or complete, please contact us at:

 

Halstead Bead, Inc.
6650 Inter-Cal Way
Prescott, AZ 86301
[email protected]

 

By providing Halstead with your personal or personally identifiable data and using the Website, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use the Website and please do not provide personal information to us.

 

Our Website may include links to websites or may include the use of analytics tools that are owned, operated, and maintained by third parties. We do not exercise control over the privacy practices such third-party websites or analytics tools, and you are encouraged to review the privacy practices of all such third-party websites or analytics tools disclosed within this Privacy Notice.

 

A. Text Request app consent

 

By using the live texting application on our website via the red chat bubble icon, you are granting consent to the third-party provider to have real-time access to your communications on the app.

 

B. Personal Information Collected

 

When you use the Website, we may collect personal or personally identifiable information from you (“PII”). PII may include any information capable of identifying an individual, but it does not include anonymized data.

 

We may collect and process the following categories of PII about you:

  • Communication Data. Communication data includes any communications that you may send to us through the Website, email, chat, text messages, telephone, and social media. We process this data to communicate with you, to record logs of our communications, and to store information to respond to legal claims, including lawful requests by public authorities, including to meet national security or law enforcement requirements. Halstead’s lawful ground for processing this communication data is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.
  • User Data. User data includes data about how you use the Website and any data that you post to or authorize through the Website. We collect and process this data to operate the Website and to ensure that timely and relevant content is provided to you, to secure the Website, and to maintain backups of the Website. Halstead’s lawful ground for processing this user data is its legitimate business interests in administering and offering the Website.
  • Technical Data. Technical data includes data about your use of the Website, such as your IP address, your login data, your phone number, your operating system, your geolocation, and your time zone. Halstead may collect this data from your use of the Website and from advertising IDs. Halstead processes this data to analyze your use of the Website, to administer and secure the Website, to provide location-relevant content, to deliver relevant content and advertisements, and to understand the effectiveness of Halstead’s advertisements. Halstead’s lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy.
  • Marketing Data. Marketing data includes data about your preferences in receiving information from and interacting with the Website, such as whether you would like to subscribe to the Halstead’s newsletters or receive text messages from Halstead. Halstead collects this data from your use of the Website. Halstead’s lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy.
  • Sensitive Data. Sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, or information about your health. Under California law, geolocation data is also considered sensitive personal information. Halstead does not collect or use sensitive data in the Website, but it may collect and use your geolocation for the purposes otherwise described in this Privacy Notice.

We may also request your consent to collect and process data you provide to us. You can always revoke your consent by changing your account settings or emailing us with your opt out request at: [email protected].

 

Halstead will only use your PII for the purpose for which it was collected. In the event that Halstead needs to use your PII for an unrelated new purpose, Halstead will provide you with notice of this new use and will explain the lawful ground for such processing or ask for your consent. Halstead may process your PII without your knowledge or consent where required or permitted by law.

 

Halstead does not use your PII to automatically make any decisions related to creditworthiness.

 

We collect PII from you through a variety of different means:

 

  • Direct Collection. We may collect PII from you when you purchase products from our Website, register a User Account or for other services, contact us through the Website, via live chat, social media, or otherwise, respond to a survey, participate in a contest, or when you opt-in to receive marketing emails, or mailings from us.

 

  • Third Party Tracking Tools. We use third party tracking tools, such as pixels, web beacons, and cookies, to automatically collect PII from you when you open, view, or click pages or links, emails, or advertisements. We disclose these third-party tracking tools below in this Privacy Notice in our disclosure of PII that we collect from third parties.

 

  • Business Partners and Service Providers. We may, from time to time, obtain PII from our business partners or service providers. When we obtain PII from our business partners and service providers, we ensure that all such business partners and service providers have obtained consent from you to transfer all such PII to us for its intended uses.

 

  • Social Media Networks and Other Platforms. We may obtain PII from you when you interact with our social media accounts or content posted on other third-party platforms, such as Facebook, X, or YouTube. For more information on how your PII may be disclosed by a particular social media network or platform, you are encouraged to review the privacy notices and policies of those platforms.

 

  • Analytics Providers. We may also obtain PII from you through our use of third-party analytics providers, such as Google Analytics. See below for a complete list of analytics services we partner with. We may create user profiles based on PII obtained through our use of PII from third-party analytics providers to better understand your wants and needs as a customer. 

 

C. Collection of Personal Information from Third Parties

 

Halstead may collect data about you through cookies and other technologies. This helps Halstead understand how you use the Website and to understand any patterns that may be associated with your use of the Website. This aids Halstead in developing or improving its Website in response to your needs or wants.

 

Halstead may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the Website and are automatically deleted when you close your web browser. Persistent cookies are stored as a file on your computer or mobile device that remain on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the Website that created the cookie when you revisit it again. Halstead may use persistent cookies when it utilizes Google Analytics or other analytics providers, which is intended to track the origin and behavior of traffic to the Website. Halstead may use the following analytics providers, and you are directed to review their cookie policies:

 

Google Analytics - https://www.google.com/intl/en/policies/privacy/

Klaviyo - https://www.klaviyo.com/legal/privacy/privacy-notice

Mouseflow - https://mouseflow.com/legal/company/privacy-policy/

Pinterest - https://policy.pinterest.com/en

 

Halstead may also receive data from third parties including analytics providers or third-party advertising networks such as those owned by Google, Facebook, Amazon, or Apple.

 

D. Marketing Communications

 

As stated above, Halstead’s lawful ground for sending you marketing communications is either your consent or its legitimate business interests, such as to grow its business. Halstead may send you marketing communications if you have asked for information concerning its goods or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask Halstead to stop sending you marketing messages at any time by logging into the Website, navigating to the Account Dashboard, and adjusting your marketing preferences or by following the opt-out link in any marketing message sent to you. If you opt out of receiving marketing communications, your opt-out does not extend to PII collected based on other legal grounds.

 

When you use the Website, you may voluntarily opt-in to receiving text messages from Halstead. In the event we sent you marketing text messages at your request, you may opt-out of receiving marketing text messages by texting STOP in response to any text message received from Halstead. Halstead’s text messaging service is provided by a third party, Text Request, and you are directed to review Text Request’s privacy notice regarding its collection and use of PII.

 

E. Disclosure of Personal Information

 

Halstead may share your PII with the following parties when required by law or as needed to execute services:

  • Third-party service providers that provide Halstead with information technology or other administrative services;
  • Halstead’s accountants, auditors, insurers, or attorneys; and
  • Government bodies that require Halstead to report its processing activities.

Halstead may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.

 

Halstead requires all third parties that receive a transfer of PII from Halstead to maintain the same level of respect for the protection of PII as Halstead and Halstead only allows third parties to process your personal data for the specific purposes listed in this privacy policy.

 

F. Data Security

 

Halstead has put into place data security measures to protect your PII. Halstead allows access to your PII only by employees and service providers who have a need to know or access your PII on Halstead’s instructions. Halstead will notify you and any regulatory body of any breach of your PII or Halstead’s security measures if it is legally required to do so.

 

G. Retention of Data

 

Halstead will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for the purposes of satisfying any legal, accounting, or reporting requirements, including to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

H. Right of Access

 

Under the law, you may have a right to request access to your PII for correction, transfer, erasure, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact Halstead as disclosed in this Privacy Notice.

You do not need to pay a fee to access your PII or to exercise your rights. However, Halstead may charge a reasonable fee if your request is unreasonable or excessive.

 

To confirm your request, Halstead may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. Halstead will attempt to respond to all legitimate requests within thirty days.

 

I. Third Party Links

 

Halstead’s Websites may include links to third party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. Halstead does not control these third-party links and you are advised to review their respective privacy policies.

 

J. Responding to Do Not Track Signals

 

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI Services and DAA Services. Our Website is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

 

You can opt out of targeted advertising by using the links below: 

 

 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/ or by installing and ad blocking plugin for your web browser.

 

 

K. Rights of European Citizens

 

While Halstead is not certified under the EU-U.S. Data Privacy Framework (“DPF”), it  adheres to the DPF Principles, including the DPF’s Supplemental Principles, and complies with the Principles in handling all data from EU-citizens. We are subject to the enforcement powers of the United States Federal Trade Commission (“FTC”) in relation to its handling of user data.

 

If you are a European citizen, you are entitled to certain rights regarding the protection of your Personally Identifiable Information and Personal Data, which are subject to limitations set forth in the EU GDPR and its applicable case law. These rights are:

 

  • The right to access and correct the information that we process about you;
  • The right to transfer all or a part of the information collected about you to another data controller, where it is technically feasible;
  • The right to the erasure of data concerning you, subject to our rights of retention under the law;
  • The right to object to the processing of Personally Identifiable Information and Personal Data where you dispute the accuracy of the data, the processing is not lawful, we no longer need the information for the purposes of processing, or you have raised an objection for personal reasons;
  • The right to revoke your consent to data processing;
  • The right to object to the processing of your Personally Identifiable Information and Personal Data for marketing purposes;
  • The right to object to the processing of Personally Identifiable Information and Personal Data for direct marketing or for personal reasons that arise from your particular situation; and
  • The right to file a complaint with a data protection authority.

 

To exercise these rights, you may either opt out of receiving communications from us by unsubscribing to its e-mails or by sending an e-mail to [email protected]. You do not need to pay a fee to exercise these rights, however, we reserve the right to charge a reasonable fee if your request is unreasonable or excessive. To confirm your request, we may need to request specific information from you as a security measure to ensure that personal data is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

 

For further information regarding your privacy rights as a citizen of the EU, please visit the U.S. Department of Commerce’s Services at https://www.commerce.gov/ and the DPF overview webpage at https://www.dataprivacyframework.gov/s/program-overview.

 

You can find a list of DPF certified organizations here: https://www.dataprivacyframework.gov/s/

 

Beyond filing a complaint directly with Halstead using the mechanisms described above, you may also file a complaint with a third-party, neutral arbitrator who will provide appropriate recourse free of charge. If you are looking for an alternative dispute settlement provider, please visit https://www.jamsadr.com/eu-us-data-privacy-framework. JAMS is a US-based arbitration service provider. You are not required to use JAMS to arbitrate a dispute with Halstead.

 

As a citizen of the EU you may, under certain conditions, invoke binding arbitration against Halstead, and we may be held liable in cases of onward data transfers to third parties as described more fully in DPF overview page linked above. We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

L. California Consumer Privacy Act

The following rules apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, B, D, E, and F) as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Notice:

Category

Examples

Collected

A. Identifiers

Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

YES

B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))

Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.

YES

C. Characteristics of protected classifications under State or federal law

Religious affiliation, ethnicity, etc.

NO

D. Commercial

Records of products or services purchased.

YES

E. Biometric Data

Fingerprints or footprints.

NO

F. Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a Services, application, or advertisement.

YES

G. Geolocation data

Physical location or movements.

YES

H. Audio, electronic, visual, thermal, olfactory, or similar information

N/A

NO

I. Professional or employment-related information

N/A

NO

J. Educational information

N/A

NO

We obtain the categories of PII marked “YES” in the above table directly from California residents when they complete forms through our Website or provide it to us as a part of a transaction or inquiry concerning our Website. We also obtain these categories of PII indirectly from California residents while observing their actions on our Website and from third parties or service providers that they have authorized to receive and share PII.

California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you.

California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information.” By selecting this link or icon, you “Opt Out,” which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.

To submit a request for a list of the categories of personal information collected from you or to request that Halstead delete your personal information, please email us at [email protected] or call us at 1-800-528-0535. You may also send a letter to us at:

 

Halstead Bead, Inc.

AATN: Privacy Officer
6650 Inter-Cal Way
Prescott, AZ 86301

 

To verify your request, we may request certain information from you to confirm that you are a Halstead user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to us to disclose or delete your personal information. To do so, you must provide us with proof that the individual or business has been appointed as your agent, such as by providing a signed power of attorney form and provide accurate responses to any information requested by Halstead that may be necessary to confirm that you are a Halstead user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by Halstead for their exercise of these rights conferred under California law.

 

M. Colorado Residents

 

Halstead does not conduct business in Colorado, control or process the personal data of 100,000 or more consumers during a calendar year, or derive revenue or receive a discount on the price of goods or services from the sale of personal data.

 

N. Connecticut Residents

 

During the preceding calendar year, Halstead did not control or process the personal data of at least 100,000 consumers or derive more than 25% of our gross revenue from the sale of personal data.

 

O. Nevada Residents

 

If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may send us an email to [email protected]. with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.

 

P. Virginia Residents

 

Halstead does not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of its gross revenue from the sale of personal data. For these reasons, the Virginia Consumer Data Protection Act (VCDPA) does not apply to our collection and use of PII.     

 

Q. Childrens’ Online Privacy Protection Act Compliance

 

We comply with the requirements of COPPA (Childrens’ Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age, and our products and services are to individuals 13 years of age or older. If you believe that we have collected PII from someone under the age of 13, you are directed to notify us immediately at [email protected].

 

 

R. Notification of Changes

 

Whenever Halstead changes its Privacy Notice, we will post those changes to this Privacy Notice and other places that we deem appropriate. Your use of the Halstead Website following these changes indicates your consent to the practices described in the revised Privacy Notice.

 

S. Contact Us

 

If you have any questions about this Privacy Notice or the manner by which we collect or use Personal Information about you, email us at [email protected].