PRIVACY NOTICE
This privacy notice describes how Penney Design Group, LLC (doing business as Penney Design Group, PDG) (“PDG”, “we”, “us” or “our”), collects, stores, uses, and /or shares (“processes”) your information when you use our services (“Services”). This includes visiting our website at http://www.penneydesigngroup.com or engaging with us through sales, marketing, or events.
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns, please contact us.
SUMMARY OF KEY POINTS
This summary highlights key points from our privacy notice. For more details, please refer to the full sections below.
What personal information do we process? We may process personal information based on your interactions with PDG and our Services, your choices, and the products and features you use.
Do we process any sensitive personal information? We may process sensitive personal information, when necessary, with your consent, or as permitted by law.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information for various purposes with your consent, and only when we have a valid legal reason to do so.
When and with whom do we share personal information? We may share information in specific situations and with specific third parties.
How do we keep your information safe? We employ organizational and technical security measures. However, no internet transmission or storage technology is 100% secure, so absolute security cannot be guaranteed.
What are your rights? Depending on your geographical location, applicable privacy laws may grant you certain rights regarding your personal information.
How do I exercise my rights? The easiest way is to contact us. We will act on requests in accordance with applicable data protection laws.
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
We collect personal information you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The specific information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. This may include:
- Names
- Phone numbers
- Email addresses
Sensitive information
- We may process sensitive information, such as student data, when necessary, with your consent, or as otherwise permitted by applicable law.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
When you visit, use, or navigate our Services, we automatically collect certain information such as your Internet Protocol (IP) address and/or browser and device characteristics. This information does not review your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This data is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The automatically collected information includes:
- Device Data: Information about your computer, phone, tablet, or other device you use to access the Services. This may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data: Information about your device’s location, which can be either precise or imprecise. The amount of information we collect depends on the type and settings of the device you use. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the services.
HOW DO WE PROCESS YOUR INFORMATION?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
Specific reasons for processing your personal information include:
- To respond to user inquiries/offer support to users: To address your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you: To provide details about our products and services, changes to our terms and policies, and other similar information.
- To send you marketing and promotional communications: We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
- To evaluate and improve our Services, products, marketing, and your experience: To identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
- To identify usage trends: To understand how our Services are being used so we can improve them.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
We process your personal information only when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
- For investigations and fraud detection and prevention.
- For business transactions provided certain conditions are met.
- If it is contained in a witness statement and the collection is necessary to assess, process or settle an insurance claim.
- For identifying injured, ill, or deceased persons and communicating with next of kin.
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
- If it is reasonable to expect collection and use without consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigation a breach of an agreement or a contravention of the laws of Canada or a province.
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artist, or literary purposes
- If the information is publicly available and is specified by the regulations
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may share information in specific situations and with specific third parties. These situations include:
- Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs: We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to their website. We obtain and store on your device (“cache”) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
Yes, we may use cookies and other tracking technologies (like web beacons and pixels) to collect and store your information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
COOKIE NOTICE
This Cookie Notice explains how Penney Design Group (“PDG,” “we,” “us,” or “our”) uses cookies and similar technologies to recognize you when you visit our website at https://www.penneydesigngroup.com. It explains what these technologies are and why we use them, as well as your rights to control our use of them.
What are cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner (in this case, PDG) are called “first-party cookies.” Cookies set by parties other than the website owner are called “third-party cookies.” Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.
Why do we use cookies? We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our website to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us to track and target the interests of our users to enhance the experience on our website. Third parties serve cookies through our website for analytics and other purposes.
What types of cookies do we use?
- Essential cookies: These cookies are strictly necessary to provide you with services available through our website and to use some of its features, such as access to secure areas.
- Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our website but are non-essential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.
- Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our website is being used or how effective our marketing campaigns are, or to help us customize our website for you.
- Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
How can I control cookies? You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by setting or amending your web browser controls. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
HOW LONG DO WE KEEP YOUR INFORMATION?
We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
No purpose in this notice will require us keeping your personal information for longer than 2 years.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet of information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. These may include the right:
- To request access and obtain a copy of your personal information.
- To request rectification or erasure.
- To restrict the processing of your personal information.
- If applicable, to data portability.
- In certain circumstances, you may also have the right to object to the processing of your personal information.
You can make such a request by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have questions or comments about your privacy rights, you may email us at info@penneydesigngroup.com.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a No-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have a data about your online Browse activities monitored and collected.
At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
DO CALIFORNIA RESIDENT HAVE SPECIFIC PRIVACY RIGHTS?
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California “Shine The Light Law (Civil Code Section 1798.83): This law permits our users who are California Residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure that data is not publicly displayed on the Services, but please ne ware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
- Every individual who is in the State of California for other than a temporary or transitory purpose and
- Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.” If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
- Identifiers: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account names.
- Personal information categories listed in the California Customer Records statute: Name, contact information, education, employment, employment history, and financial information.
- Geolocation data: Device location.
We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels.
- Participation in customer surveys or contests.
- Facilitation in the delivery of Services and to respond to your inquiries.
More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at info@penneydesigngroup.com, by visiting http://www.penneydesigngroup.com/contact, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
Penney Design Group, LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding (12) months. Penney Design Group, LLC will not sell personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete: You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know: Depending on the circumstances, you have a right to know:
- Whether we collect and use your personal information.
- The categories of personal information that we collect.
- The purposes for which the collected personal information is used.
- Whether we sell your personal information to third parties.
- The categories of personal information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
- The business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights: We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about to whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on our behalf.
- You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at info@penneydesigngroup.com, by visiting https://www.penneydesigngroup.com/contact, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
DO WE MAKE UPDATES TO THIS NOTICE?
Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changed or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about your privacy rights, you may email us at info@penneydesigngroup.com or by post to:
Penney Design Group, LLC
8120 Woodmont Avenue, Suite 750
Bethesda, MD 20814
United States
Please visit https://www.penneydesigngroup.com/contact