Privacy Policy

CSWW, INC., dba North 40 Outfitters, and its affiliates (“North 40 Outfitters,” “we,” “our” or “us”) are committed to respecting your privacy. This Privacy Policy (this “Privacy Policy”) applies to information (including personal information) that we collect (1) via any of our websites (including without limitation north40.com, smithandrogue.com, swatefishing.com, north40flyshop.com and flyproject.us), mobile applications, e-mails, applications, products or services (including any we make available via third-party platforms or websites, including social media platforms), including when you use, access, download, install or otherwise interact with any of the foregoing, (2) when you interact with us, including customer services or in our stores, (3) when you participate in our promotions, loyalty programs, customer research or surveys ((1) – (3), collectively, “Services”), or (4) from third parties.

Please read this Privacy Policy carefully, as it will tell you:

what information we collect about you and your use of our Services;
how we collect, use, share and protect your information;
the choices you have regarding your information;
and other policies and procedures regarding our handling of your information.

By accessing, using or otherwise interacting with any of our Services, you agree that you fully understand and consent to this Privacy Policy and all other terms relevant to your use of any of our Services, including our Terms of Use (available at https://north40.com/terms-of-use), which incorporates and governs this Privacy Policy.

INFORMATION WE COLLECT

We may collect the following categories of your personal information:

identifiers, such as your name, e-mail address and phone number;
online activity information, such as your browsing history, reviews and comments you post on our websites, social media posts on our pages or about our products and services, and Internet Protocol (“IP”) address;
transaction information, such as account logins, records of interactions with our employees, reviews and comments you submit to us, and purchase histories;
demographics, such as your age, gender and income level;
payment information, such as payment card numbers collected by our third-party payment processors;
location information that you provide or that we collect via your device, subject to your settings;
inferences regarding preferences or other characteristics;
and audiovisual information, such as CCTV.

We collect such information from a variety of sources, including:

From You: We collect information that you voluntarily provide, including information that we request to support your use of the Services and information that you provide in any postings, messages, comments or forums within the Services. If you send an e-mail to us, we will collect your e-mail address and all of the e-mail’s content, including attachments. If you purchase a product or service through the Services, our third-party payment processors will collect the billing and financial information they need to process your charges, which may include your postal address, e-mail address and financial information. We use CCTV in our stores for security, crime prevention and investigative purposes. Please note that this Privacy Policy does not protect business ideas or concepts you send to us. If you want to keep business ideas or concepts private, please do not send them to us.

From Your Device: We may collect information about the devices you use to access the Services, including mobile network information and information about the device’s interaction with our Services, hardware model, operating system and version, IP address and other unique device identifiers, and information about how you use our Services, including your language, access times and browser types. We may use cookies, web beacons, pixels and other similar technologies to collect such information.

From Cookies and Similar Technologies: We collect certain information automatically when you access the online Services. The information we collect includes log information, which your Internet browser automatically sends whenever you visit a website on the Internet. Our servers automatically record this log information, which may include your Internet request, IP address, browser type, browser language, and the date and time of your request. We and certain third parties deploy web cookies (both first-party and third-party) and similar technologies on our Services, such as pixel tags and beacons (collectively, “Cookies”), that may uniquely identify your browser. Cookies help us and third parties learn about how you use the Services, keep track of your interests and preferences, recognize you as a return visitor to our online Services, deliver content specific to your interests, identify when you open emails we send, and improve the functionality of our Services. Some third parties may use Cookies on our online Services to learn about your activities over time and across various websites. Cookies can collect “clickstream” data, which reflects your activities on online Services. You can configure your browser to alert you when a site is attempting to send you a web Cookie. You can decline the collection of certain web Cookies in most browsers. If you set your browser to decline web Cookies, some features of the Services may not work properly. Consult your browser’s “Help” function for more information. To learn more about Cookies, visit http://allaboutcookies.org/.

We and third parties may use information collected via Cookies to deliver advertisements on our online Services and other websites about goods and services that may be of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies for these purposes, or about how to control the advertisements you see, please visit http://optout.networkadvertising.org or http://www.aboutads.info/. Please note that if you opt out of targeted advertising, you may still see other non-targeted advertisements on our Services and across the web.

We use Remarketing with Google Analytics, Google Display Network Impression Reporting, certain Integrated Services and Google Analytics Demographics and Interest Reporting. For more information and to opt out of these specific services, please visit here.

From Social Media Platforms and Other Third Parties: We may obtain information about you or your use of the Services from our advertisers, social media platforms (such as your posts that mention us), web hosting providers, analytics providers, other consumers (for example: when other customers buy you a gift, they may provide us with your name, e-mail address and other personal information), and other third parties. The information we obtain from such third parties may depend on your account/privacy settings with those third parties and the third parties’ respective privacy policies.

HOW WE USE AND DISCLOSE YOUR INFORMATION

We and our partners and authorized service providers may use your information in several ways, including:

to furnish you with requested products or services;
to secure, maintain and communicate regarding your transactions or accounts;
to verify identity or enforce age restrictions;
to send you communications regarding products, services, upcoming events, advertising, special offers or promotions from us or our partners;
to learn about your interests and those of other consumers;
to process your payments;
to assist us and our partners in marketing and advertising our products and services and those of other businesses;
to administer promotions that we may offer;
to learn about how you interact with and use the Services, including by linking your activity across the devices you may use;
to improve the content and functionality of our Services;
to customize the content of communications and advertisements you receive from us and our partners and authorized service providers;
to report incidents regarding the health or safety of our customers or employees;
as required by law, such as to comply with a subpoena or similar legal process, or to exercise or defend our legal rights;
and when we believe in good faith that use or disclosure is necessary to protect our rights or the rights of you or others, investigate fraud, infringement or misuse, protect your safety or the safety of others, or respond to a government request.

We may disclose information in the following circumstances:

With your consent: We may share or disclose your information if you authorize us to do so.

With service providers: Our service providers perform a variety of services for us, such as transmitting e-mails, storing or analyzing data, providing or managing content, and delivering ads or marketing communications. We may share your information with such service providers on the condition that the service providers use your information only on our behalf, pursuant to our instructions and consistent with this Privacy Policy.

To comply with legal requirements and to protect you, us, and others: Notwithstanding anything to the contrary in this Privacy Policy, we may retain and disclose your information at our discretion if we believe in good faith that such retention and disclosure is necessary to: (1) comply with relevant laws or to respond to legal process served on us; (2) protect our rights or property, you, or third parties; or (3) ensure the security of our Services, systems and customers and of third parties.

For advertising and marketing: We may share personal information with trusted partners that may use the information to advertise products and services that may be of interest to you.

For operational purposes: We may share personal information with our professional advisers, payment processors, and other third parties that support our business operations.

If the information has been aggregated, de-identified or otherwise does not identify you personally: We may share or disclose information that has been aggregated or de-identified or otherwise does not identify you or information that you choose to make public, such as your public user profile information. This Privacy Policy does not limit our use or disclosure of de-identified information (i.e., information from which your name and any other personally identifying information has been removed) in any way.

To our affiliated companies and partners: We may share your information with our affiliated companies and joint venture partners as needed to provide the Services to you or achieve other purposes for which we collect information, but we contractually require those companies and partners to use your information consistent with the terms of this Privacy Policy.

In connection with a business transfer: If we are involved in a merger, acquisition by another company, bankruptcy, reorganization or sale of all or a portion of our assets, your information may be sold or transferred as part of that transaction. You acknowledge that the new entity may continue to process your information as set forth in this Privacy Policy.

OUR SECURITY MEASURES

We want your information to remain secure, so we use safeguards to protect against the loss, misuse and alteration of any of your information under our control. However, you should be aware that there is always some risk that an unauthorized third party could intercept an Internet transmission or that someone will find a way to thwart our security systems.

YOUR PRIVACY CHOICES

You are responsible for maintaining and updating the information in your user account to keep it current. You may correct or update certain information that you have provided via our online Services at any time by updating your user account. You may also request deletion of your user account by sending an e-mail through our contact form.
All information that we collect via our Services is stored in servers that are operated and maintained by us or our service providers for a term of at least four (4) years. You should be aware that it is not technologically practical to delete all information that we collect. The need to back-up our systems to protect information from inadvertent loss means that a copy of information about you may exist in a non-erasable form that will be difficult or impossible for us to locate. Nevertheless, upon receiving your request, we will delete all of your personal information stored in the databases we actively use for our Services. In addition, after receiving your request for removal, we will use commercially reasonable efforts not to disclose any such personal information stored in a non-erasable form, except as permitted under this Privacy Policy.

You have the choice to opt out of receiving marketing emails from us. You may opt out by e-mailing us at support@north40.com or by following the directions in those communications to “unsubscribe.” Please note that it may take a few days (but no longer than [10] business days) to update our systems, and during this period you may still receive our marketing communications. However, if you choose to opt out of future communications, we reserve the right to contact you regarding your account status, technical support, changes to account terms, and any other matter that might affect our Services.

Notwithstanding anything to the contrary herein, we reserve the right to maintain copies of information about you, including personal information, for as long as we deem it necessary for business purposes, subject to applicable law.

LINKS TO THIRD-PARTY SERVICES AND CONTENT; ADVERTISEMENTS

For your convenience, we may feature links to third-party websites, mobile applications, applications, promotions, loyalty programs, products, services or other content that we believe you might find useful and informative. In addition, our online Services may contain third-party advertisements. Please be aware that we do not endorse or recommend the content, products or services of any third parties, and we are not responsible for the privacy practices or content of any of the foregoing. We encourage you to be aware of and read all applicable privacy policies and other terms of use before accessing or using any of the foregoing.

SPECIAL NOTICE REGARDING CHILDREN UNDER 13

We recognize the sensitivity of information concerning children under the age of 13 and therefore provide this special notice. We are committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act (“COPPA”). Our Services are not directed to children under the age of 13, and we will not knowingly collect, maintain or disclose any information from a child under 13 except in limited circumstances allowed by COPPA and other applicable laws. If you are under the age of 13 you may use our online Services only with the consent and under the supervision of a parent or guardian. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her information without your consent, you may request that we discontinue use of such information. To request such discontinuation and the removal of your child’s information, please send an e-mail to support@north40.com. We encourage parents and guardians to spend time online with their children to become familiar with our Services and the Internet generally. Please note that our online Services may contain links to third-party content providers that collect information from children under the age of 13. We have no control over such third parties and are not responsible for their privacy practices or the content of their websites, applications, products or services.

OTHER INFORMATION

Do Not Track
We will not disable tracking technology that may be active on the Services in response to any “do not track” signals or requests or other similar mechanisms.

California Privacy Rights
California residents have a right to obtain information about the disclosures of personal information that we may make to third parties for their own marketing purposes. If you are a California resident, you may make such a request by e-mailing us at support@north40.com.

User Accounts and User Reviews
We urge you to take steps to keep your user account log-in credentials and other account information safe by memorizing your password and by keeping it in a safe place and logging out of your account and closing your Internet browser before leaving your computer.

User reviews you provide will be available to the general public over the Internet. Please do not provide user reviews you do not want disclosed to the general public and used without limitation.

Consent to Processing in the United States and Elsewhere
Our Services are owned and operated by North 40 Outfitters in the United States, but the information you provide may be accessible to our affiliates and contractors in other countries. Furthermore, if you are using our Services from a country other than the United States, your communication with us will necessarily result in the transfer of information across international boundaries. The level of legal protection for personal information is not equivalent in all countries; however, we will take the security measures described in this Privacy Policy in an effort to keep your information secure. By using any of our Services, you consent to the collection, storage and processing of your information in the United States, Canada and in any country to which we may transfer your information in the course of our business operations. Privacy protections in those countries may not be the same as in your home jurisdiction.

Changes to this Privacy Policy
We will collect and use your information only in the manner described in the version of this Privacy Policy that is in effect when such information is collected. However, we may revise this Privacy Policy periodically by updating this posting (though we reserve the right to separately contact you regarding material changes to this Privacy Policy). When this Privacy Policy is revised, we will also revise the “effective date” set forth at the bottom of this page. Your use of any Service after any such update or contact constitutes acceptance of the revised Privacy Policy.

Contact Information
If you would like to contact us regarding this Privacy Policy, please see our contact information at https://north40.com/contact-us.

Effective Date: August 7, 2020