PRIVACY POLICY

Laird International Corp. Privacy Policy

Last updated September 23, 2024.

PRIVACY CHOICES AND RIGHTS

Cookie Preference Center

When you first visit our Service, we ask you to tell us your Cookie preferences. To manage your Cookie preferences at any time (including to withdraw consent previously given), click here. In the Cookie Preference Center, you can view your current preferences, review categories of the type of cookies that we use, specific Cookie information, and manage your preferences. In addition, we have more detailed information in our Full Privacy Policy under “Information We Collect When You Use the Site”, “Sharing Of Information With Third Parties” and “Ads And Information About You” on how we collect and use your information on our Service.

Do Not Share/Sell my Personal Information

To submit a Do Not Share/Sell My Personal Information Request, please (i) turn off Targeting Cookies in the Cookie Preference Center, and (ii) also fill out our Consumer Rights Request Form located in section 7(h) (Notice of Right to Opt-Out) of our privacy policy. The Cookies Preference Center is only linkable to your device-based identifiers and not your account or other information you may have provided. Therefore, if you wish to fully opt-out of the selling/sharing of personal information through both device-based identifiers and through the personal information associated with your account, please complete both steps noted above.

Privacy Rights Requests Center

Exercising Your Rights: If you wish to exercise any of your privacy rights, please reach us in one (1) of the following ways:
• Contact Us here.
• Fill out our Consumer Rights Request Form.
• You may also set your cookie preferences.

Summary of state specific privacy rights can be found in Sections 7-13 of the Privacy Policy.

You may also authorize someone to exercise rights on your behalf.

If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. After you make a request to exercise these rights, you may receive an email requesting that you verify your identify. In order for us to verify your identify, you may be required to provide your name, loyalty or customer number, transaction history details, and/or any and all email addresses that you have used to interact with our brands. We will respond to your request only after your identity has been verified. Note that these rights are also subject to various exclusions and exceptions under applicable laws.

Last Updated: September 18, 2024

• INTRODUCTION
• 1. INFORMATION WE COLLECT
• 2. HOW WE USE THE INFORMATION WE COLLECT
• 3. SHARING OF INFORMATION WITH THIRD PARTIES
• 4. INFORMATION YOU DISCLOSE PUBLICLY
• 5. ADS AND INFORMATION ABOUT YOU
• 6. THIRD-PARTY CONTENT AND LINKS TO THIRD-PARTY SITES
• 7. CALIFORNIA PRIVACY RIGHTS
• 8. CALIFORNIA / DELAWARE DO NOT TRACK DISCLOSURES
• 9. NEVADA PRIVACY RIGHTS
• 10. VIRGINIA PRIVACY RIGHTS
• 11. COLORADO PRIVACY RIGHTS
• 12. CONNECTICUT PRIVACY RIGHTS
• 13. UTAH PRIVACY RIGHTS
• 14. TRANSFER OF INFORMATION TO AND FROM THE U.S.
• 15. CHILDREN'S PRIVACY
• 16. SECURITY
• 17. MODIFYING YOUR PREFERENCES
• 18. WHAT ABOUT CHANGES TO THE PRIVACY POLICY?
• EU AND EEA PRIVACY NOTICE
• CANADA PRIVACY NOTICE

INTRODUCTION

Welcome! You have arrived at a website, mobile app or other service provided by Laird International Corp. ("Company" or "we," "our" or "us"). This "Privacy Policy" governs your use of the Company's family of brand websites (including both mobile and online versions), including Laird’s (www.lairdinternational.com), Daily Sports USA (www.dailysportsUSA.com), Cutler Bags USA (www.cutlerbagsusa.com), Röhnisch Golf USA (www.röhnischgolfusa.com) and any interactive features, mobile applications, and/or other services that we make available through a site that posts a link to this Privacy Policy (each, a "Service"). This Privacy Policy also applies to personal data we may collect from you in our wholesale/retail stores (each, a "Store" or collectively, "Stores"), via phone calls with our Customer Service representatives, and Company sponsored events, including through official surveys and Promotion (defined below) entry forms, or in any other instance when you contact us.

This Privacy Policy describes what personal data we collect about you, why we collect it, how we use it, and under what circumstances we may share it with third parties. This Privacy Policy also describes the choices you can make about how we use your information. To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use. You may modify communication preferences online in your account settings or by contacting a Customer Service representative (Contact Us).
In addition, please review the Service's Terms of Use, which is the contract that governs your use of the Service. By using our Service, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.

1. INFORMATION WE COLLECT

(a) Information You Provide to Us

We may ask you to provide us: (i) your first and last name, email address, home or other mailing address, telephone number, mobile number, credit and debit card numbers and date of birth or other information that could reasonably be used to identify you personally (hereinafter "personal data"); and/or (ii) demographic information, such as information like your gender or product preferences ("Demographic Information"). We may collect this information from you at various times and places, such as when you:

• Make a purchase through the Service;
• Submit account registration forms or otherwise save your information with us on our Service;
• Sign up or request to be placed on our mailing, SMS text and/or email marketing lists;
• Sign up for a loyalty program;
• Participate in a survey or Promotion;
• Contact us regarding a question or concern such as when you make inquiries concerning our merchandise or services;
• Participate in any location services we offer (e.g., to provide you with information about new Store openings near you and inform you of new products and promotions that may be of interest to you based on your location); or
• Submit an application for employment.

Your decision to provide us with information is voluntary, but if you choose not to provide any requested information you may not be able to take advantage of all of the Service’s features, including purchasing products or services from us.

(b) Information We Collect When You Use the Service

In addition to information that you choose to submit to us, we automatically receive and store certain information when you visit or interact with the Service ("Usage Information"). Usage Information is stored on and accessed from your personal computer, laptop, tablet, mobile phone or other device (a "Device") whenever you visit or interact with our Service. Usage Information includes:

• your IP address, UDID or other unique identifier ("Device Identifier"); A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
• your Device functionality (including browser, operating system, hardware, mobile network information);
• the areas within our Service that you visit and your activities there, including remembering you and your preferences;
• your Device location;
• your Device characteristics; and
• other Device data, including the time of day you visit our Service.

We use various methods and technologies to store or collect Usage Information ("Tracking Technologies"). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Service, include, without limitation, the following (and subsequent technology and methods later developed)

A cookie is a file placed on a Device to uniquely identify your browser and to store information on your Device. Our Service may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage. If you wish to control your preferences regarding certain cookies on our Service, you may do so in our Cookies Preference Center. In addition, regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some (but not all) instances can be blocked by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options. Please note that these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, visit www.adobe.com. Please understand that if you disable or remove any type of cookie, some parts of our Service may not function properly, and that when you revisit our Service your ability to limit cookies is subject to your browser settings and limitations.

Web Beacons.

A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Service's pages and messages. Web beacons may be used by us for a number of purposes, including to count visitors to the Service, to monitor how users navigate the Service, to count how many emails that were sent by us were actually opened or to count how many particular links were actually viewed.

Embedded Scripts.

An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on within our Service. The code is temporarily downloaded onto your Device from our web server or one of our third party service providers, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

ETag, or entity tag.

An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

Browser Fingerprinting.

Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other similar data, for purposes of identification.

Recognition Technologies.

Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We use the above Tracking Technologies (or ones we incorporate in the future):

• to allow you to use and access the Service;
• for the prevention of fraudulent activity and improved security functionality;
• to allow you to make use of shopping cart functionality;
• to assess the performance of the Service, as part of our analytic practices and to improve the content, products or services offered through the Service;
• to identify you when you visit or sign-in to our Service;
• to keep track of your specified preferences and to track your online activities over time and across third-party sites; and
• to deliver content, including ads, relevant to your interests on our Service and third party sites based on how you interact with our advertisements and/or content.

Our Service collects and uses information on your location to deliver you relevant content and advertising based on your location as part of the location-based services we offer. We use your location information to display our nearest Store location to you. You have the ability to turn location-based services on and off by adjusting the settings of your Internet browser or mobile device or by following the standard uninstall process and if applicable, removing all Company applications from your mobile device.

(d) Information We Collect from Third Parties

We may also receive information about you from your friends and other third parties that use the Service, and combine or link that information with information we have about you (for example, fulfillment of a wish list). Additionally, we supplement information we collect directly from you on our Service with outside records from third parties for purposes of enhancing our ability to market to you, serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from third parties with your personal data, the combined information, unless disclosed otherwise, will be treated as personal data under this Privacy Policy.

(e) Information We Collect When You Interact with Third-Party Sites

The Service may include functionality that allows certain kinds of interactions between the Service and your account on a third-party website or application (for example, the link to Facebook or Twitter). The use of this functionality may involve the third-party site providing information, including personal data such as first and last name, email address, mailing address, geographic location, search history, browser information, and other information to us. For example, we may provide links on the Service to facilitate sending a communication from the Service, or we may use third parties to facilitate emails, Tweets or Facebook, Instagram, or Pinterest postings. These third parties may retain any information used or provided in any such communications or activities and these third parties' practices are not subject to our Privacy Policy. We do not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you should review the applicable third-party privacy policies.

(f) Information You Provide About a Third Party

If you send someone else a communication from the Service, such as an invitation to a friend or if you purchase a gift for another person, the information you provide (e.g., names, email addresses, mobile number, etc.) will be used to facilitate the communication. You need to ensure that you have the recipient's permission to use his or her information for this purpose. Please be aware that when you use any send-to-a-friend functionality on our Service, your email address, mobile number, name or username and message may be included in the communication sent to your addressee(s).

2. HOW WE USE THE INFORMATION WE COLLECT

We use your personal data, Demographic Information and Usage Information for purposes of:

• Processing, tracking and completing purchase, return and similar transactions;
• Sending you marketing information about Company and other third parties we work with, including through direct mail offerings;
• Sending you email communications such as electronic newsletters about our products, services, events, loyalty programs and Promotions;
• Enabling you to participate in the Service's features such as surveys and Promotions;
• Improving the effectiveness of our Service, marketing endeavors and service offerings;
• Offering you location-based services (e.g., to provide you with information about new Store openings near you);
• Processing Service account registration, including, without limitation, loyalty program applications;
• Providing customer service, including responding to your inquiries regarding our merchandise or services;
• Notifying you of product recalls or providing other information concerning products you have purchased;
• Sending you information about orders you have made on the Service;
• Identifying your product and service preferences, providing personalized content and ads and informing you of new or additional products, services and Promotions that may be of interest to you;
• Helping us address problems with and improve our Service and our merchandise and services;
• Providing mobile marketing messages and other communications and messages;
• Protecting the security and integrity of the Service;
• Creating aggregated data and statistics (which does not identify you and which we freely use and share);
• Meeting applicable legal and regulatory requirements;
• For internal business purposes, including to conduct internal analytics to improve our products, services, and business operations;
• For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy; and
• Use of Information for Recruitment Purposes. Where you have provided us with personal data or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this personal data or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.

Please also note that this Privacy Policy is not intended to place any limits on what we do with aggregated, pseudonymized or anonymized data.

3. SHARING OF INFORMATION WITH THIRD PARTIES

We may share your information as follows:

(a) When You Request We Share With Third Parties.

You may be presented with an option to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their content on our Service. This may include using third-party tools such as Facebook, Twitter, Instagram, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services to Company.

We may use third-party service providers to perform certain services on behalf of us or the Service, such as: (i) to assist us in Service operations; (ii) to manage a database of customer information; (iii) hosting the Service; (iv) designing and/or operating the Service's features; (v) tracking the Service's activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and personal data, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including personal data, about you. For any third party we share your personal data with, we enter into contracts limiting their use of your personal data to their provision of services for us.

To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Company or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d) Affiliates and Business Transfer.

We may share your information with our parent, subsidiaries and affiliates. For a list of our affiliated brands, visit- www.lairdinternational.com, which currently includes Daily Sports (USA), Cutler Bags (USA) and Röhnisch Golf (USA). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service and/or our Stores; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.

(e) Sweepstakes, Contests and Promotions.

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Service, in the Stores or through one of our social media pages that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and likeness in advertising associated with the Promotion. If you choose to enter a Promotion, personal data may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winner's list.

(f) Online Marketing.

Where permitted by law, we may share your personal data related to your activities on our Service for purposes of retargeting our advertisements and other companies' direct marketing purposes.

(g) Use of Information For Recruitment Purposes.

In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may, in connection with your employment at Laird International or its Affiliates, ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.

4. INFORMATION YOU DISCLOSE PUBLICLY

(a) User Content and Public Information.

The Service may permit you to submit ideas, photographs, videos, audio recordings, questions, comments, suggestions or other content, including personal data (collectively, "User Content"), on blogs and message boards, product reviews and other public forums. You acknowledge and agree that we or others shall have the right to store, display, publish, distribute or otherwise use User Content online or offline in any media or format and may or may not attribute the User Content to you. Others may have access to this User Content and may have the ability to share it with third parties. Please note that Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Service or what others do with information you share with them on the Service.

(b) Name and Likeness.

For full terms and conditions regarding User Content you submit to us, please review our Terms of Use. In accordance with such Terms of Use, we may publish your name, voice, likeness and other personal data that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. By connecting with the Company brands through our social media pages or accounts, or by posting content using Company-created hashtags or other identifiers, you are providing your consent for Company to use any personal data or other content you submit or make available through such sites for marketing and promotional purposes, including, but not limited to, incorporation into our marketing materials, without further notice or compensation.

5. ADS AND INFORMATION ABOUT YOU

Data about your activities online is being collected on our Service for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party websites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the Privacy Policy provides details and explains how to exercise that choice.

You may see certain ads on our Service as well as on other third-party websites across the Internet because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services (e.g., apps) by collecting information through automated means, including through the use of the Tracking Technologies described elsewhere in this Privacy Policy, and they use this information to show you advertisements (including our ads) that are tailored to your individual interests. The information they collect includes information about your visits to our Service, such as the pages you have viewed. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your device and may set or change settings on your device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may act as web beacons, which enable third parties to carry out the previously described activities.

This collection and ad targeting takes place both on our Service and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts.

We may also use Tracking Technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a Google Ads cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Service. To learn more about how to opt out of Google’s use of the Google analytics cookies, visit, here. If you wish to control your preferences regarding certain cookies on our Service, you may do so in our Cookies Preference Center. To learn more about how to opt out of Google Ad’s use of cookies, visit the Google Ads opt-out page, here. In addition, if you wish to opt out of such sharing for purposes of targeted digital advertising, we encourage you to visit the Network Advertising Initiative or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements. Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings. You may also visit these websites for more information on how you can opt back in to the sharing of data. You may also click on the informational icon contained within each interest based ad. Opting out of advertising networks does not necessarily mean that you will not receive advertisements while using our Services or on other websites.

6. THIRD-PARTY CONTENT AND LINKS TO THIRD-PARTY SITES

The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you. In addition, when you are on the Service, you may be directed to other services that are operated and controlled by third parties. This Privacy Policy does not apply to the privacy practices of third parties and we are not responsible for the data collection and privacy practices employed by any of these third parties. For example, if you “click” on a link, the “click” may take you off the Service onto a different site or service. These other sites and services may independently collect data about you and may or may not have their own published privacy policies.

7. CALIFORNIA PRIVACY RIGHTS

This section applies to any California residents about whom we have collected personal data from any source, including through your use of our Service, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person. This section may only apply to non-California residents as may be consistent with applicable state law in your state of residence.
For the purposes of this section, except where a different definition is noted, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de identified or aggregated, or other information covered by certain sector-specific privacy laws. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

(a) What Personal Data Do We Collect?

We may collect the following categories of personal data about you over the last twelve (12) months

• Identifiers, such as real name, alias, postal address unique personal identifier, online identifier, Internet Protocol address, email address, account number, and other similar identifiers. Additionally, for employees, we collect social security number; driver’s license number, passport number, and other similar identifiers;
• Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Information relating to Internet activity or other electronic network activity, including browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement;
• Geolocation data, which includes Global Positioning System (“GPS”) data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s) or vehicle(s);
• Audio, electronic, or visual information; which includes records of calls to or from our customer service centers; and/or video surveillance information;
• Professional or employment-related information, such as your employer, job, assets and income; and education information
• Information related to characteristics protected under California or federal law which includes gender; race and ethnicity; nationality; marital status; military service / veteran status; and/or date of birth; and
• Other personal data not listed above and described in California Civil Code § 1798.80(e) (e.g., signature, physical characteristics or description (such as body measurements for sizing recommendations), insurance policy number, bank account number, credit card number, debit card number, and other financial, medical, or health insurance information).
• Inferences about you, based on any of the above.
Please note that because of the overlapping nature of certain of the categories of personal data identified above, which are required by state law, some of the personal data we collect may be reasonably classified under multiple categories.
Sensitive personal information. Certain of the personal data that we collect, as described above, may constitute “sensitive personal information” under California law, including:
• Social security number; driver’s license number; passport number; and other state-issued identification card numbers;
• Precise geolocation;
• Racial and/or ethnic origin; and
• Health information.

The specific types of personal data we collect are further detailed in Section 1 of this Privacy Policy. Personal data does not include information excluded from the scope of California privacy law.

(b) What Do We Do With Your Personal Data?

We use the personal data we collect from you for the purposes outlined in Section 2 above. Other than as outlined in Section 5 with respect to our participation in behavioral ad networks to the extent this is considered the “sale” and/or “sharing” of personal data under applicable law, we do not sell your personal data for monetary or other valuable consideration.

We may use the categories of sensitive personal information identified in Section 7(a) above for the following purpose(s):

• Social security number; driver’s license number; passport number; and state-issued identification card number -- Collection for our employees and potential employees for employment-related purposes
• Precise geolocation -- Collection for our employees for employment-related purposes; to enable the “Find a Boutique” feature on your desktop or mobile device consistent with your preferences
• Racial and/or ethnic origin -- Collection for our employees and potential employees for employment-related purposes
• Health information -- Collection for our employees for employment-related purposes

We will not retain any personal data we collect about you for longer than is reasonably necessary for the disclosed purpose of using such personal data. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

We may collect personal data from the following categories of sources:

• Our customers, including via our websites, mobile applications, telephone, text message, postal mail, social media, forums, message boards, chatbot, or other means;
• Our affiliates, which includes Daily Sports (USA), Cutler Bags (USA), and Röhnisch Golf (USA) as well as our 3rd party sellers ;
• Through our service providers, which includes customer relationship management providers, analytics providers, website hosting providers, systems administrators, and communications delivery services;
• Non-affiliated companies with which we have a business relationship, which includes promotional and joint marketing partners;
• Other third parties, which includes other websites and mobile applications, online advertising partners, and other data suppliers;
• Things that other third parties may post publicly about you or otherwise provide to us; and
• Employees and job applicants.

(d) Who We Disclose Personal Data To

We may disclose your personal data to the categories of service providers and third parties as detailed below. This includes disclosure of your personal data to service providers for one or more business purposes. When we disclose personal data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not to use it for any purpose except performing the contract.

We “sell”/“share” your personal data with third parties as those terms are defined by California law, but only in the context of sharing your personal data with third party advertising platforms to facilitate targeted digital advertising. Specifically, as with many online companies, we partner with third parties, such as Facebook and Google, to manage our marketing of Laird International Corp and affiliates on other platforms, where such advertising is based on your past visits to our Service. These third party partners may use technologies, such as cookies and pixels, to gather information about your activities on the Service to deliver such advertising to you when you visit their platforms. Please also review our disclosures in Sections 1(b) and 5 of this Privacy Policy.

California law also requires that we state that we have no actual knowledge that we have sold/shared personal data of minors under 16 years of age.

In the last twelve (12) months, we have disclosed (or “shared”) the following categories of personal data to advertising partners for cross-context behavioral advertising purposes:

• Identifiers
• Internet or other electronic network activity information
• Geolocation

(e) Your Privacy Rights

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal data:

• Right to Know and Access. You may have the right to request what personal data we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal data we collect, or a report disclosing the specific pieces of personal data we collect.
• Right to Delete. You have the right to request the deletion of your personal data that is collected or maintained by us.
• Right to Opt-Out of Sale/Sharing of my Personal Information. You have the right to request to be opted out from any sales/sharing of your personal data by us, as those terms are defined under California law. This opt-out will not change your preferences with respect to the receipt of marketing and other communications from the Company. Information about how to exercise these rights is set forth in Section 7(h) (“Notice of Right to Opt-Out”) below.
• Right to Correct. You have the right to request the correction of your inaccurate personal data.
• Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. As disclosed elsewhere in this Section, we currently only use your sensitive personal information for the necessary purposes described above.
• Right to Non-Discrimination. You have the right not to be denied goods or services, charged different prices or rates for goods or services, or receive a differing level of quality of goods or services as a result of exercising the above rights.
• Right to request information regarding third party direct marketing. We may from time to time elect to share certain information about you collected by us on the Service with third parties for those third parties’ direct marketing purposes. California Civil Code Section 1798.83 permits California residents who have supplied personal data, as defined in the statute, to us, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of personal data to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal data shared and the names and addresses of all third parties that received personal data for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2022 will receive information about 2021 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please submit a written request to the following address (limit one request per year): Laird International Corp, 2300 NW 30th Place, Pompano Beach, FL (Attn: California Privacy Rights Notice). You must include your full name, email address, and postal address in your request.

(f) Exercising Your Rights

If you are a California resident and wish to seek to exercise any of the rights in Section (e) above (other than your right to request information regarding third party direct marketing which must follow the process set forth in the last bullet above), please reach us in one (1) of the following ways:

• Contact Us here
• Fill out our Consumer Rights Request Form.
• To Opt Out of the Sale/Sharing of Personal Information, in addition to submitting a Consumer Rights Request Form, you will also need to visit our Cookie Preference Center and opt out of Targeting cookies. See section 7(h) of this Privacy Policy for more information.
• If you are a California resident and would like to submit a rights request in your capacity as a current employee or potential employee, please email us at customerservice@lairdinternational.com.

You may also authorize someone to exercise the above rights on your behalf. If you should use an authorized agent to exercise the above rights, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. We do not collect personal information about minors. We do not collect household-level data. If we receive a request submitted by all members of a household, we will individually respond to each request.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests, which requires to you provide, at a minimum, your first and last name and email address that is connected to your online account. After you make a request to exercise these rights, you may receive an email requesting that you verify your identify. In order for us to verify your identify, you may be required or asked to provide additional information such as your name, loyalty or customer number, transaction history details, and/or any and all email addresses that you have used to interact with our brands. We will respond to your request only after your identity has been verified. Note that these rights are also subject to various exclusions and exceptions under applicable laws. Please note that in some instances, we may offer coupons or discount codes to users who subscribe to our email list or SMS text marketing program.

(g) Notice of Financial Incentives

Company may offer discounts on products and services – including those offered by Company, its affiliates, or its third party business partners – by joining our rewards program, email subscription lists, or other promotions. The availability of these promotions to you at any given time will vary. If and when we offer such programs, we may ask for your personal data (such as your name and email address) as a prerequisite to your participation in the program.
The programs that may be available to you are:

• Loyalty Program. When you join our Loyalty Program, we may present you with special offers in the form of free or discounted products or services, or via sweepstakes, contests, or giveaways. Many of these offers may be redeemable with rewards points, which are earned through various purchases and activities on our Service. In order to participate in this program, you must sign up for the Loyalty Program and provide your personal data.
• Email newsletter. When you subscribe to the email newsletters, we may offer you special offers in the form of free or discounted products and announcements of sweepstakes, contests, and giveaways. In order to participate in the email newsletter, you must provide a valid email address.
• You may join these programs by visiting our Service. You may also withdraw from these programs at any time by contacting Customer Service here

The value we place on the personal data that we collect in connection with these programs is calculated by determining the approximate additional spending per promotion participant, compared to individuals for whom we do not have email addresses, shopping history and preferences, or other collected information.

(h) Notice of Right to Opt-Out

The Company “sells”/”shares” personal data, as those terms are defined under California law, only to the extent it shares personal data with third parties for purposes of cross-context behavioral advertising, as that term is defined under California law.

If you wish to opt-out of this “selling”/”sharing” of the limited personal data that is gathered when you visit our Service for purposes of cross-context behavioral advertising, please take both of the following steps in order to fully effectuate your request:

• Submit a “Do Not Sell/Share My Personal Information” Request by filling out our Consumer Rights Request Form found here. (This will stop the sharing of personal information linked to your email address by removing your personal information from any exports we send to our advertising and similar service providers, to the extent such exports constitute selling/sharing, but does not stop data selling/sharing of personal information that is linked through cookies or other device-based identifiers); and
• Visit our Cookie Center, which you may access by navigating to our homepage and clicking on “Your Privacy Choices” or by clicking here, and opt out of Targeting Cookies on each device you use to access our website. (This action will remove you from data sharing via cookies and other device-based identifiers, but only on the device you used to set the preferences.)
Opt-Out Preferences Signal. If you are utilizing an Opt-Out Preferences Signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt-out as described above, such signals will be identified and processed as an opt-out request. However, if you wish to fully opt-out of the selling/sharing of personal information that is linked to your email address, please complete your request through Consumer Rights Request Form.

8. CALIFORNIA / DELAWARE DO NOT TRACK DISCLOSURES

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

9. NEVADA PRIVACY RIGHTS

Company reserves the right to sell personal data to third parties either now or in the future. Nevada S.B.220 allows Nevada residents to opt-out of the sale of their personal data. If you are a Nevada resident we want you to know that you have choices and can opt-out of Company selling your personal information after the date you opt-out by filling out the Consumer Rights Request Form found here. This may prevent or restrict your use of the Service now or in the future.

10. VIRGINIA PRIVACY RIGHTS

This section applies to any Virginia residents about whom we collect personal data from any source, including through the use of the Service, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”). This section does not apply to data processed or maintained for individuals applying to, employed by, or acting as agents or independent contractors of the Company within the context of those roles.

For purposes of this section, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information.

For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

(a) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Sections 1 and 7(a) of this Privacy Policy.
We may collect certain personal data described above which constitutes “sensitive data” as defined under Virginia law with your consent including:

• Precise geolocation (to enable the “Find My Store” feature on your mobile device consistent with your preferences)
You may consent to processing your “sensitive data” as described above by affirmatively expressing your consent in our “Find My Store” feature on our website or your mobile device.

(b) What We Do With Your Personal Data

We may collect or use personal data from you for the purposes identified in Sections 2 and 7(b) of this Privacy Policy.
To the extent we collect sensitive personal data as identified in Section 10(a) above, it is used for purposes of enabling the “Find a Boutique” feature on your desktop or mobile device consistent with your preferences.

We may share any of the categories of personal data identified above with our service providers receiving information to perform services for us on our behalf.

We do not “sell” your personal data for monetary consideration as that term is defined under Virginia law.
We do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 7(h) above.

(d) Your Privacy Rights

If you are a Virginia resident, subject to applicable law, you have the following rights under Virginia law with respect to your personal data:

• Right to Know and Access. You have the right to request what personal data we collect, which may include requests to obtain a copy of such data in a portable and readily usable format, in certain circumstances.
• Right to Correct. You have the right to request the correction of any of your personal data that you believe to be inaccurate.
• Right to Delete. You have the right to request the deletion of your personal data that is collected and maintained by us.
• Right to Opt-Out. You have the right to opt-out of our processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal data for profiling in this manner.
• Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
• Right to Provide Affirmative Consent. We cannot process your sensitive data or use your personal data for certain purposes without your affirmative consent.

If we have collected personal data on your minor child, you may exercise the above rights on behalf of your minor child. Please note that our Services are for a general audience, and we do not knowingly collect any personal data from children younger than the age of thirteen (13).

The above rights are subject to our being able to reasonably authenticate your identity and authority to make these requests.

These rights are also subject to various exclusions and exceptions under applicable laws.

We will authenticate your identity by using data you provide, such your first and last name and email address. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to seek to exercise these rights, please

Please note that not all requests can be fulfilled because of obligations under federal, state, and local law as well as applicable regulatory and legal requirements.

If you wish to appeal our decision with regard to a request that you have previously made, please contact us using the information above or notify the Office of the Attorney General of Virginia.

11. COLORADO PRIVACY RIGHTS

This section applies to any Colorado residents about whom we collect personal data from any source, including through the use of the Service, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person. This section does not apply to data processed or maintained for individuals applying to, employed by, or acting as agents or independent contractors of the Company within the context of those roles.

For purposes of this section, “personal data” means information that is linked or reasonably linkable to an identified or identifiable individual. Personal data does not include de-identified data or publicly available information.
For purposes of this section, “publicly available information” means information that is lawfully made available from federal, state, or local government records and information that a business has a reasonable basis to believe the consumer has lawfully made available to the general public.

(a) What Personal Data We Collect

We may collect the personal data from or about you as detailed in Sections 1 and 7(a) of this Privacy Policy.
Except for employment-related purposes, we do not collect “sensitive data” as defined under Colorado law.

1)Identifiers
• Real name
• Alias
• Postal address
• Shipping information
• Email address
• Account name
• Account number
• Telephone number
• Account number
• Device identifiers, including your IP address, UDID, and other unique identifiers
• To process transactions

Processing Purposes Linked to Categories
• Marketing our products and services, including marketing communications
• Marketing the products and services of others, including marketing communications
• Customer communications and support
• Promotions, surveys, and sweepstakes
• Processing Service account registration, including, without limitation, loyalty program applications
• Administering and improving the Service
• Systems and data security
• Internal analytics
• Audit, compliance, legal, policy, procedure, and regulatory obligations
• Internal business purposes

Categories of Third Party Recipients (Excluding Services Providers)
• Third-party advertising and marketing companies

2) Financial Information
• Bank account number
• Credit card number
• Debit card number

Processing Purposes Linked to Categories
• Same purposes as noted for “Identifiers” except:
• Marketing our products and services, including marketing communications
• Marketing the products and services of others, including marketing communications
• Promotions, surveys, and sweepstakes

3) Commercial information
• Records of products or services purchased, obtained, or considered
• Other purchasing or consuming histories or tendencies

Processing Purposes Linked to Categories
Same purposes as noted for “Identifiers” as well as:
• To improve our marketing endeavors and service offerings.
• To identify your product and service preferences, to customize your experience on the Service, and to serve you specific content or ads that are relevant to you

Categories of Third Party Recipients (Excluding Services Providers)
• Third-party advertising and marketing companies
Internet or other electronic network activity information