JWLGANG., JWLGANG (US), Inc., (“JWLGANG”, “we”, “us”, “our”) recognize the importance of your personal information. This Privacy Policy sets out how JWLGANG uses and protects information that it collects from its customers, visitors and users (collectively, the “Users”) through, or in association with, its website with a homepage located at www.JWLGANG.com (the “Site”), its products and services that may be offered from time to time via the Site, its related social media sites, or otherwise through Users’ interactions with JWLGANG (the Site, products, services, and social media pages, collectively, the “Services”), why it collects that information, how it uses that information, and to whom and in what capacity it shares that information. By accessing the Services, using features of the Services, and/or submitting information to JWLGANG, you are bound by all terms and conditions in the Terms of Use (the “Terms of Use”) and this Privacy Policy.
California residents, see our California Privacy Notice (the “California Privacy Notice”) for more information about certain legal rights.
INFORMATION WE COLLECT
Information you provide: When you register an account or complete a transaction through the Services, we collect some “Personal Information” (that is, any information that can be directly or indirectly associated with you), such as your name, title, email address, phone number, address, billing information and other similar information. You may also provide us with certain Personal Information of other people (e.g., if you are sending a gift to someone else).
Device Identifiers: When you access the Services by or through a device, we may access, collect, monitor and/or remotely store one or more “device identifiers”. Device identifiers allow us to uniquely identify your device and are used to enhance the Services (including sending updates and information from the Services). A device identifier may also be used in conjunction with other Personal Information.
Analytics: When you access our Services, we may collect information (either directly or using third party services) using logging and cookies which can sometimes be correlated with Personal Information. We use this information to monitor and analyze use and interest in the Services. See the section on “Service Providers” for more detail in this respect.
Log data: As with most website and technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Services, the purchases that you make, the products you view, browser type and settings, the date and time the Services were accessed, information about browser configuration and plugins, language preferences and cookie data.
Cookie Information: A cookie is a text file stored locally on a User’s device by the User’s web browser, which enables the browser to remember passwords, orders, preferences, and other information when visiting a website. We use cookies and similar technologies such as pixel tags and web beacons that help us collect certain usage data about you (such as your preferences and to process shopping cart items) (“Usage Data”), which may become Personal Information due to direct association with you. The Services may also include cookies and similar tracking technologies of third parties, which may collect information about you via the Services and across other sites and online services, including social media platforms. Our use of cookies and similar technologies such as pixel tags and web beacons is generally for operational purposes, website performance purposes, enhancing functionality of the Services and advertising. For more details about how we use these technologies, please see the section on “Service Providers” below.
USE OF INFORMATION
We generally use information that we collect for the purposes of fulfilling our contractual obligations to you, in furtherance of our legitimate interests in operating the Services and our business and/or where you have consented to such usage.
More specifically, JWLGANG uses Personal Information:
To provide, update, maintain and protect the Services and our business. This includes use of Personal Information to support delivery of the Services, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at your request. JWLGANG may use your email address or phone number to send you notices (including any notices required by law, in lieu of communication by postal mail). If you correspond with JWLGANG by email, we may retain the content of your email messages, your email address and our responses.
To personalize your experience and improve customer service. This includes Personal Information to understand your buying/shopping preferences so that we may be able to advertise other products that you might be interested, to notify you of items left as uncompleted transactions in your shopping cart, and related communications. Your information also helps us to more effectively respond to your customer service requests and support needs. Given this is related to direct marketing, we have a legitimate interest in collecting and using your email and information about your abandoned shopping cart to communicate with you about you uncompleted transaction.
As required by applicable law, legal process or regulation. JWLGANG may in certain instances be compelled by law to process your Personal Information to comply with a binding order. We will only do so to the extent reasonably required by that order.
To communicate with you by responding to your transactions, requests, comments and questions. If you contact JWLGANG, JWLGANG may use your Personal Information to respond.
To send emails and other communications. JWLGANG may send you service, technical and other administrative emails, messages and other types of communications. JWLGANG may also contact you to inform you about changes in our products, and important notices, such as security and fraud notices.
To process transactions, including, billing, account management and other administrative matters. We will use your information to process transactions. This includes processing discount codes provided by our third-party brand ambassadors. We may need to contact you for invoicing, account management and similar reasons, and we use account data to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse and to otherwise monitor the Site for violations of our policies or applicable laws. To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities and/or attempts to harm our users.
For marketing purposes. JWLGANG may use the information we collect, including Personal Information, to market our products and services to new and existing customers, and to understand our audience. JWLGANG may also use your Personal Information to send you marketing messages and may provide such information to third parties to send you information about our products and services. If you don’t want to receive these messages, you can opt out by following the instructions in the message or by submitting your request through this form. This includes determining your level of engagement with email or promotional marketing materials that are sent to you, including whether you opened an email or promotional marketing materials and/or otherwise engaged with it.
To improve our Site. We continually strive to improve our Site offerings based on the information and feedback we receive from our users and visitors.
We also use Information as otherwise described in this Privacy Policy, permitted by law, or as we may notify you.
The legal basis for the associated processing of your Personal Information is Art. 6 (1)(f) GDPR (balancing of interests, based on our legitimate interest in constantly and profitably improving the content, functionality and attractiveness of the Site by analyzing your usage) as well as Art. 6 (1)(b) GDPR (performance of a contract) and Art. 6 (1) a) GDPR (your consent).
INFORMATION SHARING AND DISCLOSURE
JWLGANG may share, transfer and/or disclose your Personal Information to or with third parties to provide the services or products requested by you, and under the following circumstances:
• JWLGANG shares certain Personal Information with its shipping company, credit card processing company, payment service provider(s), email service provider(s) and other third parties necessary to fulfil an order placed through the Services. These third parties are contractually or otherwise legally prohibited from using your Personal Information for promotional purposes or from selling your Personal Information. These third parties include, but are not limited to, our brand ambassadors with whom your email addresses are shared so that they may track their commissions. These third-party service providers may have access to information about you if it is needed to perform their functions for us, but they are not authorized by us to use or disclose such information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence.
• JWLGANG may share Personal Information and other information we collect with our Service Providers and other third parties in connection with our marketing and business development efforts. Again, these third-party service providers may have access to information about you if it is needed to perform their functions for us, but they are not authorized by us to use or disclose such information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence
• JWLGANG shares certain information that is traditionally not considered Personal Information (such as device, analytics, and Usage Data) for purposes of better understanding the usage of the Services by Users and improving on that experience.
• JWLGANG reserves the right to disclose Personal Information: as permitted or required by law; when JWLGANG believes disclosure is necessary to protect our rights or to comply with a legal process; and/or in the event it is necessary to prevent, investigate or take action regarding unlawful, illegal or suspicious activities that violate the Terms of Use or this Privacy Policy.
• JWLGANG may share your Personal Information in response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request.
• JWLGANG may share your Personal Information third parties to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or violations of our policies or the law.
• JWLGANG may transfer Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by JWLGANG about JWLGANG’s Users is among the assets transferred.
All information voluntarily shared by you through forums, comments, or blog posts is publicly available and your username may be visible by other Users. JWLGANG is not responsible for any information you submit that can be read by other Users and can be used to send you unsolicited information by other Users.
JWLGANG may, from time to time, choose to post certain Personal Information about a User for promotional or Service-related purposes; prior to posting said information, JWLGANG will obtain the User’s consent via email.
RETENTION OF DATA
JWLGANG will retain your Personal Information for as long as is reasonable or appropriate for the purposes set out in this Privacy Policy. We will also retain and use your Personal Information to the extent necessary or reasonable to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
JWLGANG will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
EFFECTIVE DATE
This policy was last modified January 23, 2023
CONTACT INFORMATION
If you have any questions regarding this Privacy Policy, you can contact us at:
SUPPORT@JWLGANG.com
