Privacy Policy

Bluffworks Inc. (“BW”) is committed to respecting your privacy and recognizing your need for appropriate protection and management of contact information you share with us (the phrase "contact information" means any information by which you can be contacted or personally identified, such as your name, mailing address, email address, telephone number, etc.). The purpose of this Privacy Policy is to inform you what information we may collect from you, how we use such information, and the choices you have regarding our use of, and your ability to review, correct and opt out of our use of, the information. This Privacy Policy applies to information we collect about you in our stores and through our websites and mobile applications. By using any of our web sites, mobile applications, or sharing your contact information with us, you are accepting and consenting to the practices described in this Privacy Policy.

As a part of our commitment to your privacy, BW supports and adheres to the guidelines and practices adopted by the Direct Marketing Association's "Privacy Promise to American Consumers." We have agreed to (1) provide customers with notice of their ability to opt out of information rental, sale, or exchange with other marketers; (2) honor customers' requests not to share their contact information with other marketers; and (3) honor customers' requests not to receive mail, telephone, or other solicitations from BW.

 

Collecting Information About You

 

There may be times (such as when you purchase or order a product, subscribe to a service, register to receive catalogs, or to participate in contests, sweepstakes or promotions, etc.) when we ask you to provide certain contact information about yourself, such as your name, shipping/billing address, telephone number, email address, social media user name, credit card information, birth date, gender, occupation, personal interests, and other information. We may also maintain a record of your product purchases.

Whether or not to provide such information is completely your own choice and is a contractual obligation. If you choose not to provide the information we request, you may be unable to purchase products, or access certain services, offers and content on our web sites. In addition, we may need to contact you via phone, email or mail to address questions or issues specific to your order, entry, etc., even if you have opted to not receive marketing communications from us.

In general, you can visit many of our web pages without telling us who you are or revealing any contact information about yourself. We may track the Internet domain address from which people visit us, other electronic markers and identifiers and other information about our site and mobile app traffic. We may analyze this data for preferences, trends, site usage statistics and to recognize you. We may also receive usage data from your mobile phone or other device you use to access our web sites or our mobile applications, including location data, which we may also combine with other information.

If you access any of our websites or mobile applications with your log-in credentials from a social networking site (e.g., Facebook or Twitter) or if you otherwise agree to associate your account with us with a social networking site, we may receive personal information about you from such social networking site, in accordance with the terms of use and privacy policy of the social networking site. We may add this information to the information we have already collected from you via our stores, websites and mobile applications.

 

Using Information About You

 We use your personal information for the following purposes, and as otherwise described in this Privacy Policy or at the time of collection:

We use your personal information in order to achieve our legitimate business interest of delivering Services you request or to fulfill contractual obligations to you.

We use your contact information for analytical and marketing purposes, such as:

• confirming and tracking your order, subscription, or registration;
• analyzing preferences, trends, and statistics;
• informing you of our new products, services, and offers; and
• providing you with other information from and about BW.

We contact you only in ways compatible with your communication choices. To the extent necessary for such purposes, we take reasonable steps to make sure that your contact information is accurate, complete, current, and otherwise reliable.

From time to time we might establish a business relationship with other persons or entities whom we believe trustworthy and whom we have asked to confirm that their privacy policies are consistent with ours. These are known as our Select Partners. In such cases we might rent, exchange, share and/or cross-reference information, including contact information about you that will enable such persons or entities to contact you regarding products and services that may be of interest to you.

To serve you better, we may combine information you give us online, in our stores or through our catalogs. We may also combine that information with publicly available information and information we receive from or cross-reference with our Select Partners and others, including providers of third-party cookie and other third party browsing and use data. We use that combined information to enhance and personalize the shopping experience of you and others with us, and to recognize our customers so that we can communicate with you directly about our products and events that may be of interest to you, and for other promotional purposes.

We may contract with companies or persons to provide certain services including credit card processing, shipping, data analysis and management, promotional services, etc. We call them our Service Providers. We provide our Service Providers with the information needed for them to perform these services.

We allow third-party companies to serve ads and/or collect certain information when you visit our web sites. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie or third-party web beacon to collect this information. Our systems do not recognize "Do Not Track" signals, but several of these third-party companies who utilize these cookies or beacons on our web sites enable you to opt out of this behavioral advertising. To learn more or opt out from these companies you can visit http://www.networkadvertising.org. We also provide you with additional tools to opt out of marketing from us or certain transfers of your information. You can learn about this in the "Opting Out of Marketing and Transfers" section of this Privacy Policy.

In certain instances, we may disclose your contact information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to BW or to others. We may also disclose your contact information when we believe the law or legal process requires it.

 

Opting Out of Marketing and Transfers; Updating and Deleting Information About You

 

 We want to communicate with you only if you want to hear from us. If you prefer not to receive direct marketing from us or from our Select Partners, or if you would like to opt out of our rental or exchange of your information with other marketers, please let us know by sending us an email to team@bluffworks.com. Please be sure to include your full name, email address, mailing address, and specifically what information you do not want to receive. If you would like to update or correct your email address, mailing address or other contact information with us please contact us the same way. If you like, you may use one of the following statements in your message to us:

• I prefer not to receive email advertisements, such as updates regarding products and services, special promotions or upcoming events.
• I prefer not to receive direct mail advertisements, such as periodic catalogs and mailings regarding products and services, special promotions or upcoming events.
• I prefer not to have my contact information provided to third parties for their marketing purposes.

Please note that any requests to remove or update your contact information may take up to ten days for your email request and 6-8 weeks to process your postal mail request.

 

International Customer Privacy

 

When you place your order, you may see a pre-checked box indicating that you would like to receive information from BW regarding offers and promotions that may be available from time to time.

If you choose to opt in to receive information from BW regarding offers and promotions that may be available from time to time, you consent to the transfer and storage of that information on our servers.

Any questions or concerns regarding the use or disclosure of your information should be directed to BW by sending us an email to team@bluffworks.com. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your information in accordance with this Privacy Policy.

 

Cookies

 

When you visit our web sites, we send one or more "cookies" to your computer or other device. We may also use cookies in emails that you receive from us. A "cookie" is a small data file that is placed on the hard drive of your computer when you visit a web site. A "session cookie" expires immediately when you end your session (i.e., close your browser). A "persistent cookie" stores information on the hard drive so when you end your session and return to the same web site at a later date the cookie information is still available. We use cookies to improve the quality of our service when you visit our web site and other web sites of interest to you. We also use cookies to remind us of who you are, tailor our products, services and advertising to suit the personal interests of you and others, estimate our audience size, assist our online merchants to track visits to and sales at our web sites and to process your order, track your status in our promotions, contests and sweepstakes, and/or analyze your visiting patterns.

We and/or our partners may use pixels and pixel tags, and place, read or use cookies the collect information from your device and/or Internet browser. These cookies do not contain personally identifiable information, however, it may be possible for our third-party business partners to combine it with other information in order to identify your email address or other personally identifiable information about you. For example, the cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form. By using our website, you agree that us and our third-party partners may store, sell, port, combine with other data, monetize, utilize and otherwise use either (i) the personally indefinable information about you that we share with them, or (ii) the personally identifiable information they discover and/or identify as described above. Visitors can also express their choices for display advertising, through the following platforms: Digital Advertising Alliance opt-out platform or the Network Advertising Initiative opt-out platform. We and/or our partners may also use cookies for delivering personalized advertising emails. These cookies are used to identify the visitors of our advertisers’ websites and send personalized emails based on the visitors’ browsing experience. We and/or our partners use cookies, pixels and other tracking technology to associate certain Internet-related information about you, such as your Internet Protocol address and what Web browser you are using, with certain of your online behaviors, such as opening emails or browsing websites. Such information is used to customize ads or content and may be shared with our partners. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

 

Security

 

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard your information delivered to us electronically, our web sites use Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only we are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your contact information, we cannot guarantee or warrant the security of any information you transmit to or from our web sites, and you do so at your own risk.

We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place such as a library or Internet cafe.

 

Protecting Children

 

BW takes special care to protect the safety and privacy of children. Our web sites are general audience sites. We do not permit anyone under the age of 13 to register with us. We also do not send email correspondence to anyone who tells us that they are under the age of 13.

Children under the age of 13 should always ask their parents or guardians for permission before providing any contact information to anyone online. We urge parents and guardians to participate in their children's online activities and use parental control or other web filtering technology to supervise children's access to the Internet.

California users under the age of 18 may request the removal of their content or information publicly posted on web sites or mobile applications by sending us an email to team@bluffworks.com. Please note that most of the user content that appears on our Site or Services is stored and controlled by third party providers; thus, complete and comprehensive removal of the content may not be possible.

 

Data Retention

 

We retain your personal information for as long as necessary for the relevant purpose for which that personal information was provided or collected, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). This will be for as long as we provide access to the website and services to you. However, we may keep some data after your account is closed or you cease using our website for the purposes set out below. 

After you have closed your account or ceased using our website we usually personal information, however we may retain personal information where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our contracts, or fulfill your request to “unsubscribe” from further messages from us. 

 

Links to Third Party Sites

 

Our web sites may contain links to web sites operated and maintained by third parties, over which we have no control. Privacy policies on such linked sites may be different from our privacy policy. You access such linked sites at your own risk. You should always read the privacy policy of a linked site before disclosing any of your information on such site.

 

RESIDENTS OF THE EEA

 

The following section outlines the privacy rights that the General Data Protection Regulation (“GDPR”) grants to resident of countries in the European Economic Area (“EEA”) or Switzerland (“European Resident”), you have additional rights regarding your personal information, including:

• The right to information. You have the right to know what personal information is collected about you, why, who is collecting data, for how long, how they can file a complaint, and if any personal information is shared with a third party.
• The right to access. You have the right to request us for copies of your personal data.
• The right to rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
• The right to erasure. You have the right to request that we. erase your personal data, under certain conditions with exceptions provided for by the GDPR.
• The right to restrict processing. You have the right to request that we restrict the processing of your personal data, under certain conditions with exceptions provided for by the GDPR.
• The right to object to processing. You have the right to object to our processing of your personal data, under certain conditions with exceptions provided for by the GDPR. 
• The right to data portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions with exceptions provided for by the GDPR.
• The right to make a complaint to a data protection regulator. If you are a resident of the EEA, you can find your local regulator’s contact details here. 

You can withdraw your consent to our collection or processing of your personal information at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

 

EXERCISING YOUR GDPR RIGHTS

 

To exercise any of the above rights, you must submit a request to us by email at: team@bluffworks.com. Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. We cannot respond to your request if we are unable to verify your identity or authority. Your verifiable request must include the reference “Request for GDPR Privacy Information” in the subject line and the body of the message must:

• provide sufficient information that allows us to reasonably verify that you are the person whose personal information we have collected;
• describe your request with sufficient detail; and 
• include an e-mail address or mailing address, as applicable, for us to send our response. 

We strive to respond to verifiable consumer requests within 28 days; however, if we require an extension (up to an additional 28 days) we will inform you of this extension and the reason in writing. 

 

The Site generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. 

 

Policy Changes

 

If we decide to change our privacy policy in whole or in part, we will inform you by posting a notice on our web sites, as applicable. Those changes will go into effect on the effective date posted in the notice and at the end of the revised Privacy Policy. The new policy will apply to all current and past users of our web sites and will replace any prior policies that are inconsistent. Your continued use of our web sites or other services constitutes your acceptance of the practices described in the revised Privacy Policy.

 

Your Feedback

 

To help us improve our privacy policy and practice, please give us your feedback. You may email us at team@bluffworks.com.

 

Effective Date: November 7, 2024