Last Updated: April 29, 2022
- Effective Date and Changes to this Policy
- The Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- Canadian Resident’s Rights
- Marketing Choices
- Automated Decision-Making
- Information Retention
- Third-party Websites
- Contact Us
1. Effective Date and Changes to this Policy
2. Information We Collect
We collect personal information about you in specific instances as described below. We collect the following categories of personally identifiable information:
We collect identifiers such as name, e-mail address, phone number, correspondence, and any other personal information that you submit to us during the course of correspondence with us or when you create an account with us;
We collect device information when you visit the Site. This includes your computer or mobile device type, browser type, unique identifiers, IP address, and geolocation information.
Internet or Electronic Network Activity Information
We may collect information concerning your interaction with the Site, including when you access the Site and your browsing activity on the Site (such as which pages you visit, in what order, and for how long). This may include “traffic” data or tracking information provided by the Site’s host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving the Site.
We may draw inferences from the information we collect about you that may reflect your preferences, characteristics, or interests.
Your information is collected when you use our Site (e.g., via cookies, see details below) or request information.
A Note to Parents Regarding Children’s Information
Naked is committed to protecting the online privacy of children. We do not knowingly collect personal information from children under 16 or allow them to create an account through the Site. We take children’s privacy seriously and encourage parents to play an active role in their children’s online experience at all times. If you have questions or concerns about the internet and privacy for your child, we encourage you to check out https://www.priv.gc.ca/en/privacy-topics/information-and-advice-for-individuals/privacy-and-kids/.
What are cookies?
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. More information about cookies and how they work is available at www.allaboutcookies.org.
Cookies on our Site are generally divided into the following categories:
- Strictly Necessary Cookies: These are required for the operation of our Site. These cookies are session cookies that are erased when you close your browser.
- Functional Cookies: These improve the functional performance of our Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These cookies qualify as persistent cookies, because they remain on your device for us to use during your next visit to our Site. You can delete these cookies via your browser settings or as detailed below.
- Targeting Cookies
To learn more about certain cookies used for interest based advertising by third-parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, or your device settings if you have the DAA or other mobile application.
4. How We Use Your Personal Information
We collect and use personal information for the following purposes:
- To provide the Site and providing services requested by, or reasonably anticipated by, you;
- Managing our relationship with you and responding to your inquiries or requests;
- Personalizing the Site and the marketing messages you receive from us;
- Analyzing use of the Site;
- Assessing the success of our marketing and advertising campaigns;
- Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity or prosecuting those responsible; and
- Complying with legal and regulatory obligations.
5. How We Share Your Personal Information
We may share personal information with the following categories of recipients:
- Service Providers, providers, including hosting providers and IT outsourcing, web analytics providers, and marketing providers. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
- Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
- With third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganizations, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
- Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.
If you have questions about the parties with which we share personal information, please contact us as specified below.
6. Canadian Resident’s Rights
In accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), individuals in Canada have additional rights with respect to their personal information.
Under PIPEDA, individuals in Canada have the following rights:
- Access. You have the right to be informed of the existence, use and disclosure of the personal information that we hold about you and to request access to this personal information, which we will provide to you in electronic form. You also have the right to receive an accounting from us of the use that has been made of your personal information and the third parties to whom it has been disclosed. However, your right of access is not absolute. Where we are permitted or required by applicable law to deny your access request, we shall explain why.
- Rectification. If you can successfully demonstrate that any personal information that we hold about you is incomplete or inaccurate, you have the right to require that we supplement or amend or amend the information, as applicable. Depending on the nature of the information, this may mean that we will delete the questioned information.
- Withdrawing Consent. If you have consented to our collection, use and disclosure of your personal information, you have the right to withdraw your consent at any time, free of charge, subject to any legal or contractual restrictions. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us using the email address below. We will respond to your request consistent with applicable law.
If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada.
We take steps to ensure that we handle your personal information subject to appropriate safeguards. As a US company, most of our operations are conducted in the United States and in order to provide the Site, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. From time to time we may use service providers located in the United States and elsewhere to collect, process or store personal information on our behalf. If you would like to receive more information about our policies concerning the use of these service providers, please contact us at the email address listed below.
Please contact us at email@example.com:
- If you wish to access, update, and/or correct inaccuracies in your Personal Information or change your consent preferences (note: we may need to collect additional Personal Information for the purposes of verifying your identity before responding to your request);
- For information about how our foreign-based service providers process your Personal Information; or
- If you have any questions or complaints about the manner in which we treat your Personal Information.
We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. Internal access to your personal information is restricted to personnel on a need-to-know basis, in order to develop, operate and maintain the Site and our business. All of our personnel who have access to this information are trained in the maintenance and security of such information.
Whenever you give out personal information online there is a risk that third-parties may intercept and use that information. While we strive to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. Any information you provided to us, or received by us through this Site is provided at your own risk. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
8. Marketing Choices
To the extent permitted and in accordance with, applicable law, we may directly contact you with special offers from time-to-time. You have control regarding our use of your personal information for directing marketing. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as detailed below.
9. Automated Decision-Making
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
10. Information Retention
11. Third-party Websites
Our Site may contain hyperlinks to websites owned and operated by third-parties for your convenience. Where this is the case, we urge you to review the equivalent data protection, privacy and cookie policies available on such websites before providing any personal information. We do not accept any responsibility or liability for the data protection of privacy practices of third-parties in relation to such websites and your use of third-party websites is entirely at your own risk.
12. Contact Us