INTRODUCTION

We take user privacy seriously and want you to be informed. This Privacy Policy, which is incorporated into our Terms of Service, outlines the privacy practices of Smithey Ironware Company, LLC (“Company,” “us,” “we,” or “our”) in connection with your (“you” or “your”) access to or use of our Website, store, and Products and services (collectively, the “Service”). By accessing or using our Service, you acknowledge that you have read, understood, and agree to be bound by our terms, including this Privacy Policy.

WHO ARE WE?

Our Company specializes in the production and sale of premium cast iron and carbon steel cookware and related Products and services (collectively, the “Products”). Our Website, located at www.smithey.com (the “Website”), serves as our e-storefront; however, our Products are sold in in brick and mortar retail stores across the United States.  Customers who purchase our Products in a retail store may use the Website or other electronic means, such as email, to communicate with us about their purchases and experiences.

 

Generally, we collect personal identifying information when you provide it to us, such as when you make a purchase or contact customer service through our Website. Like most Websites, we also collect routine device and other data from visitors, and we use such data to deliver advertisements that may be of interest to you. 

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy outlines how we collect, use, and disclose information of users, both online and offline. Please also see our separate Terms of Service, which incorporate by reference this Privacy Policy and which include definitions applicable to this Privacy Policy.

 

Unless otherwise expressly stated, this Privacy Policy does not apply to any third-party practices, Websites, or services, whether or not referenced in our Service. Each third party will have its own privacy practices and policies, which you should review before using them.

HOW DO WE COLLECT AND USE INFORMATION?

Generally, we collect personal information about you, such as your name and address, and details about your transaction when you make a purchase or contact us through the Website. Like many companies, we also collect internet and device information, such as from cookies and other automated technologies, when you browse our Website. These technologies are discussed in more detail below.

We collect all of this information for our business purposes, namely, to provide and improve our Products and services, such as our Website. Some of these business purposes are for compliance with applicable laws, such as responding to legal requests, enforcing this Privacy Policy and our rights, and protecting others and our Service. We may also use information for short-term, transient use for an interaction with you and to personalize your experience and communications. We use information for security purposes and to protect against harmful activity. Further, we may use information for debugging for functionality, auditing interactions, and internal research. Moreover, we may use information as otherwise instructed by you and with your consent.

In addition, we collect information for commercial purposes, meaning to market our goods and services. For example, we collect device and other data to better target advertisements and other content in an effort to create a more personally relevant experience.

We use information for the same reasons that we collect it. For example, we use information for business purposes, such as running our Website and sending you Products that you order, as well as commercial purposes, such as advertising to you after you leave our Website. We also use information for the reasons that we disclose it, as outlined below.

More specifically, we collect the following information for the referenced purposes.

 

Category	Examples of Data Collected	Collection Point	Purpose for Collection and Use
Identifiers	Contact Information, such as name, address, and email address.	We collect this information when you provide it, such as when you place an order on our Website or create an account.   We may also collect data from third parties where related to the Service, such as email addresses for potential customers or through social media login/sign-in.	We collect and use data for all business purposes, such as providing and improving our Products and services, responding to communications, and for security and auditing purposes.   We may also collect and use your contact information to market our offerings to you, such as through emails.
Commercial Data	Transactions, such as Products or services purchased or considered, or purchasing tendencies.   Financial, such as name, credit or debit card number, and other billing information when you submit payment for a purchase made on the Website; provided, however, that such information is only collected and used to complete your purchase and is not stored in our systems.   Inferences, such as creating a profile relating to consumer preferences and trends.	We collect this information when you provide it, such as when you place an order on our Website.   We may also collect information from third parties to help with responding to your requests, processing transactions, and improving offerings.	We collect and use data for all business purposes, such as providing and improving our Products and services, responding to communications, and for security and auditing purposes.   We may also use inference information to market offerings of interest to you.
Device Data	Internet and Network Data, such as browsing history, search history, and information regarding your interaction with an internet Website, application, or advertisement. See below for more information about cookies and other tracking technologies.   Geolocation, such as general location from an IP address or precise geolocation.	We collect this data through cookies and other automated technologies. For example, like many companies, we automatically gather information about your device, such as your IP address, browser type, and operating system. For more information on these practices, see below. We may also collect data when you sign up or log in through a third party like Apple, Google or Meta.	We collect and use data for all business purposes, such as providing and improving our Products and services and for security and auditing purposes.   We may also use device data to market offerings of interest to you.    Further, we may use geolocation data to provide increased functionality and show offers relevant to you.
Audio or Visual Data	Such as audio, electronic, or visual data.	We may collect this information if you provide it.	We collect and use data for business purposes, such as when you call our customer service line.
Other Personalized Data	Employment, such as professional or employment history.   Education, such as educational history.   Other Information, such as communications to us or responses to surveys or promotional offers.	We may collect this information if you provide it, such as if you apply for a job, send us a message, or participate in a survey or offer.	We collect and use data for business purposes, such as reviewing job applications and providing and improving the Service.   The Service does not intend to collect any other personal data not outlined to you.
Other Non-Personalized Data	Public information   Aggregate information   De-identified data   Pseudonymized data	We may collect this information at any time, from public, third party, and other sources.   For example, we may repost a public review that you posted about us or use aggregate data for our analytics.	We may collect and use this data for any business or commercial purposes. The information will either be public data or not identify individual users.

WHEN DO WE DISCLOSE INFORMATION?

As part of our business, we disclose information as follows and for the outlined purposes, which include business purposes to provide and improve the Service and comply with legal and contractual obligations, as well as commercial purposes, such as to market our business.

• Company Parties; Merger or Sale. We may share information with affiliated companies that are related to us under a common ownership where they comply with this Privacy Policy. Such disclosure is for our business purposes, including to provide and improve our offers. Further, we may share information as part of a sale, merger, acquisition, or other change in control or entity status, either in whole or in part. We reserve the right to transfer or assign your information as part of any such transaction or investigation.

• Service Providers and Contractors. We share information with service providers that allows us to provide and improve the Service. Service providers only use your information for a contracted-business purpose. Such disclosure is for our business purposes, in particular to provide you with the Service. We may likewise share information with “contractors” that are not service providers but to whom we disclose information for a business purpose. Such disclosure is for the business purpose of providing you with Products and services that you have requested or considered.

• Cookies/Device Data. For more information about our use of cookies and other technologies, see below. Such disclosure is for our business purposes, in particular to provide you with the Service, as well as commercial purposes, such as to market to consumers that may be interested in our Service or related offers. Company may also contract with third-party advertising companies to serve ads on our behalf. These companies may use cookies or other measures to collect non-identifier information.

• Legal Process and Protection. We may disclose information as necessary to comply with our legal obligations, such as to respond to government requests, law enforcement inquiries, legal processes, subpoenas, and court orders. We may disclose information when we believe it is necessary to investigate, prevent, or respond to illegal, fraudulent, or injurious actions or security incidents that may cause harm to us, the Service, or others. We may also disclose information in good faith where necessary to investigate or enforce a violation of this Privacy Policy, our terms, or any legal rights.

• Third Parties. We may disclose information to third parties that could choose to provide unrelated goods or services or for cross-context advertising purposes. Examples include selling an email list to another business or using customer email addresses to allow cross-context advertising for services related to our Service that may be of interest to you. Such disclosure facilitates our Service as well as marketing/commercial purposes.

• Consent. We may disclose information as requested or consented to by you. Such disclosure may be for any business or commercial purpose as described to you.

HOW DO WE USE COOKIES, PIXELS AND SIMILAR TECHNOLOGIES?

We may use cookies, pixels, gifs, web beacons, log files, and/or similar technologies to automatically collect certain information when you use the Service or interact with our digital media content, such as when you visit our Website. This allows us to track individual users, determine when content is accessed, and customize user experiences. For example, unless you have opted out of cookies or changed your cookie settings in your internet browser, your browser automatically sends us certain device, browser, internet connection, and general geolocation information and certain internet activity information. For instance, we may collect your mobile device identifier or MAC address, ISP carrier information, date and time you access the Service, the pages you visit, and whether you click on ads. You can change your cookie settings in your internet browser and use settings on your device to manage your privacy controls. For more information and ways to opt out, see https://www.allaboutcookies.org/, and learn how to disable these tools by opting-out of third-party cookies and mobile device ID practices.  

As part of our practices, we may use third-party advertising companies to display ads tailored to your individual interests based on your online activity and to provide ad-related services such as analytics and market research. Third parties, in turn, may use a cookie, web beacon, or other similar technology to collect information. To opt-out of cross-device linking, visit www.aboutads.info/choices or perform a global opt-out on each browser and device.

In particular, we may use Google cookies and tools, such as Google Analytics and in certain cases Google Maps, for analytics and advertising and to improve the user experience, and your information may be shared with Google; for more information, visit the Google Cookie Policy, Google Analytics Opt-Out Browser Add-On, or Ads Settings.

We may also use the Meta Pixel and Meta cookies for the purposes stated above, and your information from the Meta Pixel and cookies may be shared with Meta. In particular, the Meta Pixel is a tracking tool that enables us to measure and optimize the effectiveness of our advertising campaigns and understand the actions taken by users on our website. The Meta Pixel collects data such as your IP address, browser information, device information, and other technical details, and this information is shared with Meta and our Company. For more information visit the Meta/Facebook Cookie Policy.

Please note that there are different types of cookies and related technologies, which may be placed by us or third parties, including:

• essential cookies that are required to display and provide the Service;
• preference cookies that are used to store preferences and improve user experiences;
• analytics cookies to determine how the Service is used and that often collect non-personalized information; and
• marketing cookies to deliver personalized and targeted advertisements that may be of interest to you and others.

These cookies are used for business purposes, for advertising to those that visit the Service, and commercial purposes for marketing to others.

DO WE SELL OR SHARE INFORMATION?

We only sell or share data as outlined in this Privacy Policy. Company does not sell its email lists or other data about its customers to third-parties. However, Company participates in targeted ads, also called interest-based or online behavioral advertising, which may include cross-context behavioral advertising; and we may also sell or share consumer data, including contact information (e.g., so that a provider may contact you about Products or services that you may be interested in) and other data (e.g., which may be used for retargeting ads or analytics). Under some privacy legislation, this may constitute “selling” or “sharing” of personal information, such as for business purposes (e.g., providing our Service) and commercial purposes (e.g., other marketing). To opt out of these practices, contact us as outlined below and see our Do Not Sell or Share My Personal Information link.

HOW DO WE PROTECT AND TRANSFER INFORMATION?

Consistent with others in our industry, we take efforts to employ technical, administrative, and physical security measures for personal information, taking into account reasonable security procedures and accessible technology. However, no system can be completely secure; and we cannot promise, and you should not expect, that your personal information will always remain secure. Your provision of personal information is at your own risk. The safety and security of your information also depends on you. Take steps to safeguard your passwords and other data and notify us as soon as possible if you believe your account security has been breached. 

If you are visiting the Service from a location outside of the United States, your connection will be through and to servers located in the United States, and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States. By using the Service, you authorize and specifically consent to the transfer of personal data to the United States and its storage and use as specified in this Privacy Policy.

HOW LONG DO WE RETAIN INFORMATION?

We retain personal information for the length of time necessary to fulfill the purposes outlined in this Privacy Policy, unless a different retention period is requested by you or required or permitted by law. For example, we will retain your personal information for as long as it is needed to provide you with the Service or fulfill a legal or contractual obligation. We may also aggregate, deidentify, or anonymize personal information as applicable for use in analytics, such as to analyze trends over periods of time without specifically identifying you.

We use the following criteria to determine how long we retain personal information: (a) our relationship with you, such as if there is an open contract or account or a pending transaction or request; (b) legal obligations to retain personal information for certain purposes, such as to maintain transaction records; and (c) other obligations or considerations relating to the retention of data, such as contract requirements, litigation holds, investigations, or statutes of limitation. 

WHAT ARE YOUR PRIVACY RIGHTS?

We value consumer privacy rights and strive to provide flexibility with how your personal data is used and shared. If you want to make a privacy request or have any questions, please contact us through our Contact Form or email Privacy@Smithey.com with your name and email address or other identifier used in connection with our Service so that we can verify your request. If an authorized agent is making a request on your behalf, the agent should provide its name and contact information, such as an email address, in addition to your information. There may be situations where we cannot grant your request; for example, if you make a request and we cannot verify your identity, or if you request deletion of data that we have a legal obligation to keep. Where we deny your request in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

Applicable privacy laws have different requirements and depend on various factors, such as where you live and how much revenue or data is at issue. Generally, we adhere to the following set of privacy rights to the extent applicable and subject to any limitations authorized by law. 

• Access. You can access and obtain your data and ask us for certain information, including: the categories of personal information collected and used; the categories of the sources of data; the business or commercial purposes for collecting, selling, or sharing data; the categories of third parties to whom data is disclosed; and the specific pieces of personal information collected. You also have a similar right to data portability (the ability to export, back up, and transfer data).

• Amend. You can amend, correct, or rectify your data if it is inaccurate.

• Delete. You can have your data deleted subject to certain legal limitations.

• Limit. You can limit the processing of your data, in particular any sensitive data, and limit use of any automated decision making, such as profiling. We will also respond to recognized global opt-out preference signals where we can verify the request. For more information, see below.

• Opt-Out. You have the right to opt-out of certain data practices. For example, you can unsubscribe from marketing communications by following the opt-out instructions in each message or by contacting us as outlined in this Privacy Policy (please note that we may still send non-marketing messages, and that consent to receiving marketing communications is not mandatory to use the Service). You may also opt out of the “sale” or “sharing” or your personal information to the extent applicable. Please see our Do Not Sell or Share My Personal Information link. You may opt out of the use of automated decision-making technology, if applicable. We will also respond to recognized global opt-out preference signals where we can verify the request. For more information, see below.

• Complaints. You have the right to make certain complaints, including for privacy concerns. We value your feedback and seek the opportunity to work with you on any issues. You have the right to no discrimination for asserting your privacy rights.

• Specific State Laws. Several states have enacted privacy laws that may apply to you, depending on the circumstances. For example, the California Consumer Privacy Act (“CCPA”), updated by the California Privacy Rights Act (“CPRA”), governs certain California-related conduct. Under California’s “Shine the Light” law, California residents may also request certain information regarding Company sharing personal information with third parties for their direct marketing purposes. Further, if you are a California resident under the age of 18, California Business & Professions Code Section 22581 permits you to request and obtain removal of content you have publicly posted. Please note that such a request does not ensure complete or comprehensive removal of public content.

• European Laws. Generally, residents of the European Economic Area (“EEA”) have the right to access your own information that we hold; to ask that your information be corrected, updated, or erased; and the right to object to, or request that we restrict, certain processing of your information. Our legal basis for collecting and using your personal data is your consent, the fulfillment of our obligations pursuant to the contract created between you and Company, or where the collection and use is in our legitimate interests and does not violate your data protection interests or fundamental rights. You may withdraw your consent to our collection and use of your personal data. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information used in reliance on lawful processing grounds other than consent.
• Other Laws. If certain other privacy laws apply to you that provide you with additional rights, please contact us to make a request, as we strive to comply with all privacy rights.

DO WE COLLECT INFORMATION ABOUT CHILDREN?

 No, we do not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected such information, we will delete it from our database. We have no such information to use or to disclose to third parties or to otherwise report, including under the Children’s Online Privacy Protection Act (“COPPA”). We do not have actual knowledge of selling or sharing the personal information of consumers under the age of 16.

HOW DO WE USE OR DISCLOSE SENSITIVE INFORMATION?

We do not generally use or disclose “sensitive” personal information, nor do we use sensitive information for purposes other than those specified in the CPRA, which provides for the following uses without additional disclosures where the information is reasonably necessary and proportionate to the use: (a) to perform certain services, such as verifying information or for analytics; (b) to verify or maintain the quality or safety of our Service; (c) to perform services or provide goods reasonably expected; (d) for short-term use where there is no disclosure or profiling; and (e) to resist malicious, fraudulent, or illegal actions or to ensure physical safety.

DO WE OFFER FINANCIAL INCENTIVES FOR YOUR DATA?

We may offer incentives related to the collection, retention, or sharing of information that may be deemed a “financial incentive” or “price or service difference.” For example, we may provide you with a coupon code in exchange for your email address and agreement to be added to our email list. If you opt in to such an offering pursuant to the terms described at the time of signup, we may collect information such as name and email address, commercial information and preferences, internet or other network activity, and device information. Any difference in price or rate, such as a discount, will be reasonably related to the value of the data. If you want to withdraw from the offering, follow the unsubscribe options in the communication at issue or contact us.

DO WE RESPOND TO DNT SIGNALS OR GPC?

No, our Service does not currently respond to DNT, short for Do Not Track, requests. DNT is a feature that, when enabled, sends a signal to Websites to request that your browsing not be tracked. 

"GPC” is short for Global Privacy Control settings in your browser or extension. We recognize GPC signals. This means that if your browser has GPC enabled, our Website will automatically recognize your GPC signal and opt you out of the sale of your personal information, if any. For more information about GPC, please click here: https://globalprivacycontrol.org/.

HOW DO WE UPDATE THIS PRIVACY POLICY?

We will update this Privacy Policy when our privacy practices change or as otherwise required or permitted by law. Each time you use the Service, the current version of this Privacy Policy will apply. Unless we receive your express consent, any revised Privacy Policy will apply only to information collected after the effective date of the revised Privacy Policy.

HOW CAN YOU CONTACT US?

Please contact us with any questions or concerns! We can be reached at:

Smithey Ironware Company, LLC

1465 Pipefitter St.

North Charleston, SC 29405

United States

privacy@smithey.com

Contact Us

Last Updated: August 15, 2023