Privacy Policy

LAST UPDATED: January 1, 2023

LAST REVIEWED: December 18, 2023

Welcome to our website (the “Website”), which is operated by HP Hood LLC (“Hood”, “company”, “we”, “our” or “us”). This policy describes the information we may collect from Website users or consumers (“you”) or that you may provide to us and our practices for using, sharing, maintaining and protecting your information.

Specifically, this policy applies to information we collect:

• Via this Website and Hood’s digital advertisements, and by email, forms, text and other electronic messages between you and us; or
• When you view or participate in consumer promotions we offer, including sweepstakes and contests, except as otherwise stated in the official rules accompanying such promotions.

Except with respect to our users and consumers who are California residents, this policy does not apply to information collected by us offline (other than from consumer promotions) or through any other means. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this policy for more

information about our practices, including with respect to personal information that we collect other than through the Website.

This policy does not apply to information collected by any third party from social media platforms on which Hood maintains its social media pages. We do not control and are not responsible for the privacy policies and practices of such social media platforms. As a result, we recommend that you carefully review any applicable privacy policies of social media platforms, as they may differ from our own.

Likewise, the Website may, from time to time, contain links to websites owned and operated by third parties (“Third Party Sites”). This policy does not apply to information collected by any third party on such Third Party Sites, and we are not responsible for the privacy policies or practices on Third Party Sites. We encourage you to review the privacy policies of such Third Party Sites so that you understand how those websites collect, use, and share your information.

1. Information We Collect About You and How We Collect It

We collect information, including personal information, in several ways:

Information you provide us directly – You may provide us with information when you fill out forms, send us emails, send us texts or other electronic messages, report problems on our Website, enter promotions, sign up to join our marketing list, or otherwise provide information to us. This information may include, for example:

• name
• postal address
• email address
• phone number
• age (e.g., when provided in connection with your participation in a contest, sweepstakes, or other promotion)
• comments and questions that you submit to us (e.g., using the Website’s “Contact Us” page or via email)
• purchase information you may provide to us when reporting a product-related concern

Information we collect automatically – Our service providers and we may collect information automatically when you use the Website or interact with our emails or digital advertisements through the use of automatic data collection technologies including cookies, web beacons (also known as pixels) and other technologies. Cookies are small files typically placed on the hard drive of your computer. Web beacons are small electronic files that may be contained in our Website pages, digital advertisements, and emails.

The information we collect automatically may include:

• online identifiers, such as your unique device identifier or MAC address;
• your browser or device type and operating system
• your approximate geographic location
• internet domain through which you access the Internet (e.g., yourServiceProvider.com if you use a commercial Internet service provider)
• your Internet Protocol (IP) address, from which we may derive your approximate geographic location
• information about your interactions with the Website or our digital advertisements (e.g., the web pages or digital advertisements you view, links you click, date and time of your access, sites you visited before and after visiting our Website)
• information about your interactions with our emails (e.g., whether you opened or forwarded an email we sent to you or clicked on a link contained in any such email)

We may combine the information that we collect automatically with information that we collect from other sources or that you provide to us.

2. How We Use Your Information

We may use your information:

• To respond to your inquiries, fulfill your requests, and provide you with customer service.
• To send administrative information to you, such as changes to our terms, conditions, and policies.
• To send you marketing communications and targeted advertising that we believe may be of interest to you.
• To personalize your experience on the Website by presenting products and offers tailored to you, and to facilitate social sharing and social sign-on functionality.
• To allow you to participate in interactive features and sweepstakes, contests, and similar promotions.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products or services, improving or modifying our Website, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business.

If you submit any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We may use information that has been de-identified or aggregated or both for any purpose.

3. Your Choices and Updating Your Information

Targeted Advertising and Analytics Cookies – As discussed above, we may, and our service providers and other partners may, use automatic information collection technologies to track your activities on our Website and across other websites so that we can serve you advertisements that are tailored to your inferred interests and for website analytics purposes. To do so, our service providers and partners may place or recognize a unique cookie on your browser or your unique device identifier (including through the use of web beacons). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.

For example, we use third party tools on our Website, such as Google Analytics and Google Tag Manager for a number of purposes, including to measure traffic and usage trends on our Website and to deliver you targeted advertisements. Please see www.google.com/policies/privacy/partners/ for information about how Google may use your information and how you can control the information sent to Google.

If you would like to opt out of our use of cookies and other technologies for purposes of targeted advertising and data analytics, you can adjust your cookie preferences by clicking on the “Do Not Sell or Share My Personal Information” link located in the footer of the Website. If you would like more information about targeted advertising more generally, or to learn how to opt out of it on the particular device on which you are accessing this Privacy Policy, please visit https://thenai.org/opt-out/ and https://youradchoices.com.

Responding to Do-Not-Track and Global Privacy Controls. A “do-not-track” signal is a privacy preference feature in some web browsers that tells a website that a user does not want their online activity to be tracked. We currently support Global Privacy Control (GPC), a specification designed to allow internet users to notify businesses of their privacy preferences, such as whether or not they want to be tracked or have their personal information sold or shared with third parties for targeted advertising. It consists of a setting or extension in the user’s browser or mobile device and acts as a mechanism that our websites can use to honor the user’s privacy settings. If you would like to use GPC, you can download and enable it via a participating browser or browser extension. If your browser or device has enabled GPC, it will override your preferences selected in the privacy settings on this Website.

Email – You can stop receiving promotional email from us at any time by following the instructions provided in the email or by contacting us at the address or phone number set forth below.

Location Information: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information via your device or browser. Note that some services may not be available if you disable location-based services, and you may experience difficulties using the Website.

Access and Correction – If you would like to request to update or correct your information, or to request access to your personal information, please contact us at the address or phone number set forth below. Requests for access must be in writing. We will consider and respond to such requests promptly, and otherwise in accordance with applicable laws.

If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this policy for more information about your choices and rights with respect to your personal information.

4. Third Party Service Providers

We may employ third party service providers to perform a variety of functions on our behalf. For example, third party service providers may help us administer promotions, analyze data, deliver email, deliver targeted advertisements, determine the geographic location associated with your IP address, and host and improve the functionality of our Website. We may share your information with third party service providers so that they may provide services to us.

5. Information We Share

We may disclose information about you:

• To our affiliates.
• To our service providers, as explained above.
• To other third parties to fulfill the purpose for which you provide it.
• To a buyer or other successor in the event of a sale, merger, divestiture, reorganization, bankruptcy, dissolution, or other similar event of some or all of our business, assets, or stock, including to prospective buyers or other third parties for the purposes of evaluating such a transaction.
• To any other third party and for any other purpose disclosed by us when you provide the information.

We may also use and disclose your information:

• To comply with applicable law, court order, or legal process, including to respond to any government or regulatory request or cooperate with law enforcement.
• Where we believe in good faith that it is necessary to prevent a crime or an injury to ourselves or third parties.
• To enforce or apply our Terms of Use.
• If we believe disclosure is necessary or appropriate to protect the rights, privacy, property, or safety of Hood, our licensors, our affiliates, our customers, you, or others.

We may disclose information that has been aggregated or de-identified or both without restriction.

6. Children Under the Age of 13

Our Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under the age of 13. If you are under 13, do not use or provide any information on this Website, enter any promotions offered by us, or provide any personal information to us, including your name, address, telephone number, email address or any screen name or user name you may use.

7. Location of Your Information

Your information may be collected, processed and maintained outside your country of residence (including in the United States and Canada) by our third party service providers or us. Such countries may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your information.

8. Security

We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information within our organization. No transmission via the Internet or storage system can be guaranteed to be fully secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How To Contact Us” section below.

9. Retention

We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

10. Changes to Our Privacy Policy

This Privacy Policy was last updated on the date indicated above. We may update or modify this Privacy Policy from time to time, and any changes will become effective when we post the revised Privacy Policy on the Website. Please review this Privacy Policy periodically to check for any changes.

11. How To Contact Us

If you have any questions or concerns about our Privacy Policy, you can contact us at:

HP Hood LLC | Six Kimball Lane | Lynnfield, MA 01940 USA

Attention: Consumer Affairs

1-800-242-2423

privacy@hphood.com

12. Additional Information Regarding California

If you are a past/present/future employee, agent, subcontractor, consultant or vendor of Hood, please click Privacy Notice for the CCPA notice applicable to you.

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Right Act of 2020, together with all implementing regulations (“CCPA”), we are providing the following details regarding the categories of personal information about California residents that we have collected (whether online or offline) or disclosed within the preceding 12 months. We may not collect and/or disclose all of the information listed below from you. What we collect and/or disclose depends on your relationship with us.

(a) We collected the following categories of personal information (as defined by the CCPA):

(i) Identifiers, such as name, postal address, email address, telephone number, IP address, and online identifiers (e.g., unique device identifier or MAC address);

(ii) Personal information, as defined in the California customer records law, such as your signature (e.g., when provided in connection with your participation in a contest, sweepstakes, or other promotion);

(iii) Characteristics of protected classifications under California or federal law, specifically, your age (e.g., when provided in connection with your participation in a contest, sweepstakes, or other promotion);

(iv) Commercial information, such as transaction information and purchase history (e.g., when you report a product-related concern to us);

(v) Internet or network activity information, such as browsing history, search history, and interactions with our Website, emails, or digital advertisements (e.g., the web pages or digital advertisements you view, links you click, date and time of your access, sites you visited before and after visiting our Website), whether you opened or forwarded an email we sent to you or clicked on a link contained in any such email, information about your internet service provider, and information about your browser or device and operating system;

(vi) Geolocation data (non-precise);

(vii) Audio, electronic, visual, similar information, such as photographs or videos you choose to submit to us, and call recordings make when you call customer support; and (viii) Inferences drawn from any of the above information to reflect your preferences and characteristics.

We collect this personal information directly from you, automatically when you interact with our Website, emails, or digital advertisements (e.g., via cookies and web beacons), and from other categories of sources, such as social media platforms (e.g., when you contact us using our social media pages), publicly available databases, and joint marketing partners when they share the information with us.

(b) As described above, we use the personal information listed in Subsection (a) to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to:

• To respond to your inquiries, fulfill your requests, and provide you with customer service;
• Develop, improve, and maintain our products and services;
• Personalize, advertise, and market our products and services (including by providing sweepstakes, contests, and similar promotions), and to measure the effectiveness of our promotional campaigns;
• Conduct research and analytics;
• Maintain our facilities and infrastructure;
• Undertake quality and safety assurance measures;
• Conduct risk and security control and monitoring;
• Detect and prevent fraud;
• Perform identity verification;
• Perform accounting, audit, and other internal functions, such as internal investigations;
• Comply with law, legal process, and internal policies;
• Maintain records;
• Process claims; and
• Exercise and defend legal claims.

(c) We disclosed the personal information listed in Subsection (a) to our service providers for our operational business purposes listed in Subsection (b).

We may also disclose the personal information listed in Subsection (a) to our affiliates.

(d) Sale and Sharing of Personal Information: We may disclose or provide access to your personal information to third parties, including for purposes of cross-context behavioral advertising and data analytics, which may constitute “selling” or “sharing” under the CCPA. Such sale or sharing does not include information about individuals we know are under age 16. In the previous 12 months, Hood may have sold or shared the categories of personal information listed below with the categories of third parties listed below.

 

(e) If you are a California resident, you may request that we:

(i) Disclose to you the following information:

• The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
• The specific pieces of personal information we collected about you, subject to certain exceptions;
• The business or commercial purpose for collecting, selling, or sharing personal information about you; and
• The categories of third parties to whom we disclosed personal information.

(ii) Delete personal information we collected from you, subject to certain exceptions.

(iii) Correct inaccurate personal information that we maintain about you, subject to certain exceptions.

(iv) Opt out of our sale or sharing of your personal information.

You also have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

To opt out of our sale or sharing of your personal information, please click on the “Do Not Sell or Share My Personal Information” link located in the footer of the Website. To make a request for the disclosures described above, or for the deletion or correction of your personal information described above, please visit our “Contact Us” https://hood.com/contact-us web form or email us at privacy@hphood.com using the subject line “CCPA Consumer Request”. To ensure we can verify your identity and help us respond to your request please include in your email or web form submission your full name, email and home addresses, and clearly state the request(s) you’d like to make.

In order to help ensure that your personal information is not disclosed to any person who does not have the right to receive it, and to help ensure your personal information is not mistakenly deleted or changed, we will attempt to verify that you are the subject of the personal information you are requesting to access, delete, or correct. We will compare the information you provide to any information we may have in our possession in order to verify your identity. We may also contact you at the email address you’ve provided to request additional information in relation to your request. We will use the information collected through the request process only for verification purposes and responding to your request.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at privacy@hphood.com.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will contact you at the email address you provide.

Authorized Agent. You may also choose to authorize an agent to make the above requests or exercise your rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of both you and your agent’s identity and authorization.

Please note that we may not be able to respond to your request if we cannot verify your identity, or your agent’s identity and authority to make the request, and confirm the personal information relates to you.

Notice of Financial Incentives: We may offer discounts, coupons, and similar benefits (each, a “financial incentive”) to customers who sign up to receive our marketing emails. When you participate in a financial incentive, we may collect personal information from you, such as your name, postal address, and email address. You can opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by contacting us at privacy@hphood.com. In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up. The value of the offer or discount presented to you is reasonably related to the value of your personal information.