Privacy Policy
KÜHL PRIVACY POLICY
Skythe, Inc. (“KÜHL” or “we”, “us”, or “our”) recognizes that you care how information about you is used, shared, and respects your privacy. This Privacy Policy (this “Policy”) explains how your information is collected, used, and the choices you have regarding your information. This Policy applies to all information collected by KÜHL from any source, including information collected through our online services and activities, including this Website and our mobile applications, and at retail locations. Throughout this Policy “Website” or “Site” refers to https://www.kuhl.com/, including mobile versions of those sites.
Please note that the Website may contain links to other third-party sites that are not controlled or operated by KÜHL. This Policy does not apply to such third-party websites, and KÜHL is not responsible for the content of such third-party websites or the privacy practices of such third parties.
Your Consent
Please review this Policy periodically. You should read this entire Policy before submitting information, including personal information, to us in any form or using our Site. Whenever you submit personal information to us, you consent to the collection, use, disclosure, share, sale, transfer, and storage of that information in accordance with this Policy.
All personal information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. We may also make full use of all user-generated content you submit to us, in accordance with our Terms of Use. If you enroll in our SMS/MMS mobile messaging program, your participation is governed by our SMS Terms, which are incorporated into this Policy by reference.
If you are a California resident, please also see our California Notice.
If you are a Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, OR Virginia resident, please also see our Multi-State Notice.
If you are a resident of the European Union please see our Notice to International Data Subjects below.
WHAT INFORMATION WE COLLECT
We collect personal information using three methods: (1) from you when you choose to voluntarily provide it to us or our affiliates with whom we jointly own certain categories of data; (2) using automated technology, including when you visit our Site or interact with our electronic advertisements or communications; and (3) using third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and social networking websites and other entities. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. More information is given below in the “Cookies and Other Technology” section below.
We may collect personal data from customers both online and offline. Online, we may collect information through the Website, an affiliated site (such as a promotional microsite linked to our site), a KÜHL page on a community website (such as Facebook or the like), when you interact with us through email, text messages, or mobile applications, or through similar online avenues. On some pages, you may order products, make requests, submit product reviews, and register to receive materials or information and this information may also be collected.
All personal information may be used for the purposes stated in this Policy. We may combine data collected from third-party sources. We will retain your personal information for the period necessary to fulfill that purpose and as otherwise needed to comply with applicable law and internal company policies.
You may also share your information with us in connection with surveys, contests, sweepstakes, or other promotions. Some of this information may be co-owned or jointly controlled with sweepstakes sponsors. Where the terms of a sweepstakes or contest include privacy practices that differ from or conflict with this Policy, the privacy practices of the contest or sweepstakes you entered will control, and will be disclosed in the rules for that promotion. Without limiting the foregoing, your personally-identifiable information may be used by us to contact you for winner notification, prize delivery confirmation or other promotional purposes. Your entry in the contest or sweepstakes may also result in your being added to our mailing/texting lists as well as those of our promotional partners associated with the contest or sweepstakes.
Offline, we may collect information through our sales associates at retail locations (such as email addresses for the purposes of sending electronic receipts). Our Policy applies to all information collected via any method.
We collect, use, and disclose your personal information as described in the chart in Annex 1 below.
Information We Collect From You
In particular, we have collected the following categories of personal information from our consumers, including within the last twelve (12) months:
Identifiers: Such as name, alias, postal address, email address, account name, and signature; contact information including telephone number and email; financial information (including bank account, credit card, and debit card numbers).
Protected Classification: demographic information such as age, gender, and veteran or military status.
Commercial Information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity: Information on a consumer's interaction with a website, application, or advertisement, Internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology information on the devices you use to access this website, including information about how you use our website.
Inferences drawn from other personal information: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you without your express consent (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
Automatically Collected Information
KÜHL and its analytics and other service providers use technologies such as cookies, web beacons, tags, scripts and other similar technologies (collectively, “Cookies”) to collect certain information. These technologies are used to help us and our business partners analyze trends, administer the Sites, remember preferences, track users’ movements around the Sites and gather demographic information about our customer base as a whole. Some types of Cookies, like web beacons, allow us or third parties working on our behalf to gauge and enhance the effectiveness of our marketing by allowing us to understand whether users follow links in our e-mails or on our Sites, and by gathering information about other sites users visit before and after visiting our Sites. Certain other Cookies are used to store preferences on a user's computer or mobile device, or display content based upon what a user viewed on the Site to personalize their visit. Currently, KÜHL employs cookies and tracking technologies on its Sites, including the following:
Essential Cookies. These cookies enable you to move around the Sites and to use their features. Without these necessary cookies, certain aspects of the Sites would not work. No information about your browsing habits is gathered by these cookies.
Session Cookies. We employ session cookies to manage and maintain user sessions on our website. Session cookies allow us to keep track of your activities during a single browsing session, such as keeping you logged in as you navigate through different pages. This ensures a seamless and continuous experience while you explore our website. Session cookies are essential for secure and efficient user authentication and session management, providing you with a smooth and secure browsing experience.
Functional (Personalization) Cookies. These cookies remember how you like to use the Sites and help to personalize them accordingly. These cookies do not collect personally identifiable information or track your browsing habits, but they do help us serve you with ads.
Analytics Cookies. These cookies collect information about your use of the Sites, and enable us to improve the way they work. For example, analytics cookies show us the most frequently visited pages on the Sites, help us record any difficulties you have with the Sites, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on the Sites, rather than the use of a single person. Some of the analytics cookies we use may be operated by third parties.
Advertising & Targeting Cookies. These cookies track user activity across websites to deliver personalized advertisements and measure the effectiveness of ad campaigns. They are often set by third-party advertising networks such as Google Ads and Microsoft Advertising. These cookies collect information about user interests, interactions with ads, and browsing behavior to provide targeted marketing. Users can manage advertising cookie preferences through their browser or the respective ad network’s settings.
Because technology is constantly changing, however, we may change the types of Cookies that are used with the Sites from time to time. We will update this Policy in accordance with applicable law and if we materially change the manner in which we collect information. To find more information about cookies and for instructions on how to disable them please visit www.allaboutcookies.org or visit the help section of your browser. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.
If you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our Website or mobile application, we will collect the information that you share with us, or that those social media platforms or networks share with us. Please review the privacy policies and settings of the social media platforms and networks that you use.
If you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our Website or mobile application, we will collect the information that you share with us, or that those social media platforms or networks share with us. Please review the privacy policies and settings of the social media platforms and networks that you use.
HOW INFORMATION IS USED
We will use your personal data only when the law allows. Most commonly, we will use your personal data in the following circumstances:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To detect and prevent fraud or misuse of services and for any other business purpose that is permitted by law, and legal compliance.
Send you information related to products and services including invoices, updates, security alerts, technical notices, and administrative messages
See our Terms of Use for more information. For more detail about how information is collected and used, see Annex 1 below.
CHANGE OF PURPOSE
We will use your personal data only for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
THIRD-PARTY HOSTING
We contract with a third party to maintain and host our Website. Therefore, any information you submit, including personal information, will be placed and stored on a computer server maintained by this third-party host. The third party has agreed to implement technology and security features and strict policy guidelines to safeguard the privacy of your personal information from unauthorized access or improper use.
OPTING OUT OF THIRD-PARTY ADVERTISING AND ANALYTICS DISCLAIMERS
We and/or third parties including advertising companies, social networking sites, and service providers on our behalf, use cookies, web beacons and other similar technology, to collect information for the purposes described in this Policy including advertising, analytics, online behavioral marketing, monitoring performance and improvement of our online services (traffic, errors, page load time, popular pages, etc.)
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
You can opt out of remarketing and targeting advertising on the specific website of each third party company and also through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/. You can also opt out of participating companies from the European Interactive Digital Advertising Alliance in Europe: http://www.youronlinechoices.eu/, or opt out using your mobile device settings
HOW WE DISCLOSE INFORMATION
Service Providers and Contractors
We may disclose your personal information with our vendors, subsidiaries, partners, and third- party independent contractors for purposes of: (1) performing functions on behalf of us, such as processing credit card transactions; (2) providing you with product offers, marketing or promotional materials through phone, text, or electronic and/or postal mail; (3) tracking consumer complaints, and (4) tracking information generated through our Website or social media sites. Our vendors, partners and third-party independent contractors are obligated contractually not to use or share your personal information for unauthorized purposes.
Outside Parties
We disclose Personal Information to third parties we work with who help us gather information from you and communicate with you including entities that provide sweepstakes/contests sponsorship, social media companies, companies providing data analytics, targeted advertising, companies that help us oversee consumer complaints, or online behavioral marketing services. We may share product reviews that you submit with our authorized dealers solely for informational and promotional purposes. If our information practices change at some time in the future we will post the policy changes to our Website. If you are concerned about how your information is used, you should check back at our Website periodically.
Legal Obligations
We may disclose personal information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; to enforce the Terms of Use of our Website; to prevent imminent physical harm; in the event that we find that your actions on our Website violate any laws, our Terms of Use, or any of our usage guidelines for specific products or services; or in connection with disciplinary actions/investigations.
Sale or Corporate Restructuring
We may disclose Personal Information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company, provided that the third party agrees to adhere to the terms of this Policy.
PRIVACY OF CHILDREN
We do not knowingly collect information from minors in the United States or elsewhere with or without the consent of their parents or guardians therefore the Children’s Online Privacy Protection Act (“COPPA”) does not apply to us. Children (under the age of 18) are not eligible to use the Website unsupervised, and we ask that children do not submit any personal information to us. If you are not 18 or older, you should not visit or use our Website or social media accounts. If you are a parent or guardian of a child under the age of 18 and suspect he/she has provided personal information on or through our Website, Parents can, at any time, contact us at privacy@kuhl.com.
PROTECTION OF YOUR INFORMATION
The security of all personal data of our users is a primary concern of ours. To prevent unauthorized access or disclosure, maintain data accuracy and facilitate the appropriate use of information, KÜHL uses physical, technological and administrative procedures to protect personal information. Nevertheless, we cannot guarantee the complete security of your information in as much as no security systems over the internet are 100% secure. It is also important for you to protect against unauthorized access to your information as well as to your computer. In order to help protect the personal information you provide to us, you: (i) should not share your password or account information with others, (ii) should use a secure web browser, and (iii) should change your password frequently.
CHOICE AND OPT-OUT PREFERENCES
When you sign up to our Website, you agree to receive promotional e-mails and e-mail notifications including, but not limited to, customer service related e-mails pertaining to sales such as order confirmations, notifications that an item has shipped, returns and requests for reviews.
If you change your mind and no longer wish to receive our promotional e-mails, you may opt-out at any time simply by sending us an e-mail at privacy@kuhl.com, or by clicking on the unsubscribe link. If you establish an account, you may receive certain types of communications even if you have not opted-in to receive them because these communications may be necessary in order to maintain an account on the Website.
EXTERNAL LINKS
We may make available third party applications through our Website and social media applications for your use. Links to such applications, any other websites included in this Site or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Site or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account’s operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.
CONTACT US
By Mail:
KÜHL
1420 South 4800 West
Suite G
Salt Lake City, UT 84104 USA
By Email:
privacy@kuhl.com
Subject: Privacy Policy Questions
Attn: Privacy Officer
CALIFORNIA CONSUMERS ONLY:
YOUR CALIFORNIA PRIVACY RIGHTS
This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.
PERSONAL INFORMATION COLLECTED, DISCLOSED OR SOLD
Information Collected
Within the past 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice. To review these categories click Annex 1.
Business-to-Business ("B2B") Information
If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, you have the same rights as other consumers set forth in this Notice with respect to the information we collect from you in that role. We collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information and communications consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. For more details see Annex 1.
Information Sold or Shared
As explained in Annex 1 of this Policy, we share your data with third-party partners such as social networking sites and advertising companies in order to serve you with ads tailored to your preferences across various platforms. We also share your data with service providers to enhance user experience. For example, if a customer provides their email on one brand’s site, a service provider may pair it with the device and check the customer's email subscription status across other partner sites to either send relevant messaging or prompt for email opt-in if unsubscribed. This type of sharing may be considered “selling” or “sharing” under the CPRA. You can control the information shared about you and request an opt-out as explained below.
We have sold or shared the following categories of personal information for a business or commercial purpose in the preceding 12 months.
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Personal Identifiers
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Commercial Information
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Internet Activity
We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months:
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Personal Identifiers
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Commercial Information
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Internet Activity
We do not knowingly sell the personal information of individuals under 16 years of age without affirmative authorization.
For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1.
CPRA RIGHTS AND REQUESTS
Under the CPRA, you are entitled to certain rights, and you can make requests with regard to those rights as follows:
Right to Know about the Categories of Personal Information Collected (“Right to Know”)
Right to Request Deletion of Personal Information (“Right to Delete”)
Right to Correct or Rectify Inaccurate Information about you (“Right to Correct”)
HOW TO MAKE YOUR REQUESTS TO KNOW, DELETE, OR CORRECT.
You have the right to make requests for the aforementioned rights (Request to Know; Request to Delete; or a Request to Correct (a “Request”)).
To make a Request for any of the information set forth above, please submit a verifiable consumer request pursuant to the instructions below. The Request must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, shared, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. We will acknowledge your Request within 10 business days and will attempt to respond substantively within 45-90 days.
You may make a Request the following ways:
You may make a request here: privacy@kuhl.com
Call to submit your request: 1-888-218-3181
Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identification.
We will review all information provided by you to us, to determine whether we can respond to your Request We will inform you of our decision to deny or grant your Request.
For any Requests to Know, you may make such Requests twice within a 12-month period.
For Requests to Correct, you will need to provide evidence supporting the inaccuracy of the current information, and we reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.
We will retain correspondence, documents and information related to any Request for 24 months as required by law.
ADDITIONAL CPRA RIGHTS
The following are additional rights afforded to you under the CPRA.
Right to Know Sensitive Personal Information Collected
We do not collect or process sensitive personal information for the purpose of inferring characteristics or for any purposes other than those set forth in Regulations section 7027(m).
Right to Opt out of Sharing and Selling
To opt out of sharing of your personal information:
You may make a request here: privacy@kuhl.com
- Call to submit your request: 1-888-218-3181
RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS
You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.
OPT-OUT PREFERENCE SIGNALS
We honor opt-out preference signals that you enable, including a Global Privacy Control. Opt- out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information without first seeking your explicit consent.
COOKIES
As explained in our "Automatic Data Collection" section under subsection “Cookies,” you can opt out of cookies using your browser. Please Note:
Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors, analytics processors. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
You may still receive ads from us that are not tailored to your interests.
ADDITIONAL OPTIONS TO OPT OUT OF SALE OR SHARING
In addition to the above options to opt out of the sale or sharing of your information under the CCPA as described above, you have controls and choices with respect to collection and use of your information by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third-party companies and are not responsible for their operation.
ADVERTISING OPT OUT
You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites, for more information on how to do this please see section above titled “OPTING OUT OF THIRD-PARTY ADVERTISING AND ANALYTICS DISCLAIMERS.”
RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING
You can request access to information about automated decision making processes KÜHL uses and you may request to opt out of automated decision making. We engage in automated processing. For more information, please contact us at privacy@kuhl.com.
NOTICE OF FINANCIAL INCENTIVE
(APPLICABLE TO RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, OREGON, TEXAS, AND OTHER STATES AS REQUIRED BY LAW)
From time to time, KÜHL may provide financial incentives to consumers who elect to participate in discount programs, sweepstakes, contests and other promotions, in exchange for allowing us to collect and retain certain personal information, such as Identifiers (e.g., your name, email address, or phone number), and Commercial Information (e.g., your purchase history). These incentives may result in differences in the prices of our products offered to consumers (e.g., discounts and other promotions). For example, the financial incentives we may provide include discounts based upon purchase activity, discounts in exchange for collection of your personal information, or other periodic discounts for promotional purposes. The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.
Participation in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please fill out a Request to Opt-Out of Incentive request here or contact us at privacy@kuhl.com.
Please note that once you opt-out (following receipt of your discount), you will not be permitted to use the same email to opt-in again for an additional discount.
The value of your personal information that allows us to make these offers and financial incentives is the value of the offer itself. Each financial incentive or price or service difference related to the collection and use of personal information is calculated based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself, the expense associated with the offer, and the anticipated revenue generation that may be realized by rewarding brand loyalty and repeat purchases.
RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
AUTHORIZED AGENT INFORMATION
You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.
Authorized agents can make requests under the California Consumer Privacy Act by emailing us at email address: privacy@kuhl.com. We will require authorized agents to provide proof of the consumer’s identity and proof of designation as an the authorized agent. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.
We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
CALIFORNIA DO NOT TRACK NOTICE:
Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow non- parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above and as described in Annex 1.
CALIFORNIA SHINE THE LIGHT DISCLOSURE INFORMATION
Although we do not disclose to any non- parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:
Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, email address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the email or mailing address specified below under Contact Us If we receive your request at a different email or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.
CHANGES TO THIS PRIVACY POLICY
This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.
CONTACT FOR MORE INFORMATION
For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us by sending an email to privacy@kuhl.com.
MULTI-STATE CONSUMER DATA PROTECTION ACT NOTICE
This Notice provides additional information to Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia residents.
RIGHT TO CONFIRM, ACCESS, AND DATA PORTABILITY
You have the right to confirm whether or not we are processing your personal data and to access such personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.
We have collected the categories of Personal Information about residents of the above mentioned states as described in this Notice in Annex 1. To review these categories, click here.
Information Sold or Used for Targeted Advertising
As explained in Annex 1 of this Policy, we and our third-party partners such as social networking sites and advertising companies, share your data in order to serve you with ads tailored to your preferences across various platforms. We also share your data with service providers to enhance user experience. For example, if a customer provides their email on one brand’s site, a service provider may pair it with the device and check the customer's email subscription status across other partner sites to either send relevant messaging or prompt for email opt-in if unsubscribed. This type of sharing may be considered a sale or sharing of information for targeted advertising purposes under certain state laws. You can control the information shared about you and request an opt-out.
We have shared the following categories of Personal Information for Targeted Advertising (See Annex 1 for further details):
Personal Identifiers
Commercial Information
Internet/Network Activity
We do not sell your data for monetary value and have not done so in the preceding 12 months.
For details regarding the categories of third parties with whom we have shared this information, please see Annex 1. You have the right to opt out of the sale or processing of your Personal Information for Targeted Advertising as set forth below.
RIGHT TO REQUEST DELETION OF PERSONAL DATA
You have the right to request the deletion of your personal data provided by or obtained about you (“Request to Delete”), subject to certain exceptions permitted by law.
RIGHT TO CORRECT (NOT APPLICABLE TO IOWA AND UTAH RESIDENTS)
You have the right to request that we rectify inaccurate information about you.
RIGHT TO OPT OUT OF THE SALE OF PERSONAL DATA
We do not sell your personal data for monetary value.
RIGHT TO OPT OUT OF DATA PROCESSING FOR TARGETED ADVERTISING
You have the right to opt out of the processing of your personal data for purposes of targeted advertising (“Request to Opt Out”).
RIGHT TO OPT OUT OF PROFILING (NOT APPLICABLE TO UTAH RESIDENTS)
You have the right to opt out of the processing of your personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects (“Request to Opt Out of Profiling”). We do not process your personal data for profiling purposes.
HOW TO MAKE YOUR REQUESTS TO CONFIRM, ACCESS, DATA PORTABILITY, CORRECT, DELETE, AND OPT OUT OF TARGETED ADVERTISING
You can make a Rights Request in the following ways:
You may make a request here: privacy@kuhl.com.
We will acknowledge your Request within 10 days and will attempt to respond substantively within 45-90 days.
You must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.
Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity. We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.
OPT-OUT PREFERENCE SIGNALS
We honor opt-out preference signals that you enable, including a Global Privacy Control. Opt- out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information for targeted advertising purposes without first seeking your explicit consent.
COOKIES
As explained in our “Automatically Collected Information” section, you can opt out of cookies using your browser. You may also exercise your right to opt-out of cookies using our Cookie Preference Center.
Please Note:
Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
We may still share your Personal Information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
You may still receive ads from us that are not tailored to your interests.
ADDITIONAL OPTIONS TO OPT OUT OF SALE OR TARGETED ADVERTISING
You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites, for more information on how to do this please see section above titled “OPTING OUT OF THIRD-PARTY ADVERTISING AND ANALYTICS DISCLAIMERS.”
RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS
You have the right not to receive discriminatory treatment for exercising your privacy rights , including by exercising the rights specified herein. As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.
NOTICE OF FINANCIAL INCENTIVE / BONA FIDE LOYALTY PROGRAM (APPLICABLE TO RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, OREGON, TEXAS, AND OTHER STATES AS REQUIRED BY LAW)
For information about our loyalty programs and financial incentives, including disclosures required by state law, please see our Notice of Financial Incentive/ Bona Fide Loyalty Program above.
AUTHORIZED AGENT
You may designate an authorized agent to make a request on your behalf to opt out of the sale of personal information.
Authorized agents may make requests on behalf of consumers by emailing privacy@kuhl.com. We will require authorized agents to provide proof of the consumer’s consent to and designation of the authorized agent for purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the consumer who is the subject of the request. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.
RIGHT TO APPEAL (NOT APPLICABLE TO UTAH RESIDENTS)
You have the right to appeal our decision to deny any of your privacy rights requests above. Within 60 days of receipt of your appeal (45 days for Colorado residents), we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied and you remain unsatisfied with our response, you may contact your state’s Attorney General to submit a complaint or seek further assistance. For help locating your state’s Attorney General’s contact information, visit Consumer Resources - File a Complaint.
Making an Appeal
You can make an appeal in the following ways:
RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for as long as it is necessary for the purposes set out in the Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
NOTICE TO EU/EEA DATA SUBJECTS
PERSONAL INFORMATION
With respect to international data subjects, “personal information,” as used in this Privacy Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).
HOW INFORMATION IS COLLECTED, USED AND DISCLOSED
We may collect certain personal information for various purposes, and we may disclose such information to various third parties. For more information on what types of personal information is collected, from what sources, for which purposes, and how that information is disclosed, please click here.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
If you provide Personal Information to us, you agree to the use, collection and disclosure of the Personal Information by us for the purposes described in this privacy policy.
If you are a resident of the European Economic Area (EEA), the legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it. In addition, we process Personal Information with the principle of data minimization in mind. This means that we limit ourselves to the minimum amount of Personal Information which is needed to achieve the particular purpose for which we process the Personal Information. Below are the legal bases for which your Personal Information may be processed.
We may process your Personal Information because:
The processing is necessary to provide the services and features you have requested;
The processing is necessary to perform a contract with you;
The processing is necessary for the legitimate interests of our business, such as fraud prevention, information security, direct marketing, or to comply with the law;
To fulfill a legal obligation;
As permitted by applicable law;
You have provided consent for us to do so.
RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for as long as it is necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. For more details on data retention periods, please click here.
SECURITY
We have adopted reasonable and appropriate security procedures to help protect against loss, misuse, and unauthorized access to the information you provide to us. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Site and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.
COOKIES
As explained in our “Automatically Collected Information” section, you can opt out of cookies using your browser. You may also exercise your right to opt-out of cookies using our Cookie Preference Center .
Please Note:
Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
We may still share your Personal Information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.
CROSS-BORDER DATA TRANSFERS
Your information, including Personal Information, may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside of the United States and choose to provide information to us, please be aware that your personal data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. We transfer your personal information out of your country of residence only upon your consent. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our Site.
Whenever we transfer your personal information to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.
YOUR DATA PROTECTION RIGHTS
The Data Controller
The Data Controller who collects and processes your Personal Information is:
KÜHL
1420 South 4800 West
Suite G
Salt Lake City, UT 84104 USA
Data Subject Rights
If you are a resident of the European Economic Area (EEA), Canada, you have certain data protection rights. Barring certain exceptions and depending on the country where you reside, you have the following data protection rights:
The right to access, update or erasure of the information we have on you. You have the right to access, update and erase your Personal Information.
The right of rectification. You have the right to have your Personal Information corrected if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Information.
The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
The right to data portability. You have the right to be provided with a copy of the information that we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You have the right to withdraw your consent at any time where werelied on your consent to process your Personal Information.
The right to know about automated decisionmaking. As a data subject you also have the right to not be subject to decisions based on automated decision making alone, including profiling, and which may lead to legal consequences for you. This right does not apply if such processing is necessary in order for us to enter into or fulfil an agreement with you, if such processing is allowed according to applicable legislation, or if the legal basis for such processing is your consent.
We have implemented reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information via the online submission form at:privacy@kuhl.com. If you wish to be informed of the type of Personal Information we hold about you and/or if you wish to remove such Personal Information from our systems, please contact us at: privacy@kuhl.com. Please note that for your safety and security, we may ask you to verify your identity before responding to such requests.
ANNEX 1
Category | Examples | Collected From | Purposes | Disclosed | Sold or Shared | Retention Period |
|---|---|---|---|---|---|---|
Personal Identifiers | Name, signature, company name, mailing address, telephone number, email address, financial information including credit card or debit numbers, and location. Also includes account log-in credentials (email address and password or password hash, if accounts are created), cookie IDs, pixel IDs, device identifiers, and advertising identifiers (e.g., IDFA/GAID). | You when you visit our Site, purchase a product (through the Site, in person, or by phone), register for an account, engage with us on social media, communicate with us via phone, email, or otherwise interact with us; automated technologies (cookies, pixels, SDKs); third-party sources (business partners, service providers, consumer reporting agencies, publicly available data). May also be jointly collected with sweepstakes or promotional co-sponsors, or received from SMS/text messaging vendors who transmit opt-in/opt-out information. | To operate and maintain our Website and services; fulfill and deliver orders; process payments and returns; authenticate and manage accounts; provide customer support; send service updates and promotional communications (unless you opt out); personalize user experience and deliver targeted marketing; prevent and investigate fraud and security incidents; comply with legal obligations and enforce our agreements. Also to administer sweepstakes and contests, verify winners, and to provide financial incentive programs (e.g., discounts in exchange for personal information). | Service providers and contractors (hosting, analytics, payment processing, fraud detection, marketing); third-party partners for targeted advertising and remarketing; government and law enforcement as required; acquirers/successors in a merger or transaction. Also to sweepstakes or promotional co-sponsors (jointly controlled information), SMS/text vendors for program administration, and cloud hosting/CDN providers. | Shared: Yes Sold for monetary value: No To opt out of selling or sharing this information , you may fill out a Your Privacy Choices Request | We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. |
Commercial Information | Records of products or services purchased, obtained, considered, reviewed, or other purchasing or consuming habits. Also includes loyalty program activity, financial incentive program participation, and product reviews linked to a purchase. | You when you place orders or interact with our Site or retail channels; third-party sources (business partners, payment processors, service providers, and publicly available data). | To process transactions, fulfill and deliver orders, manage customer interactions, provide service updates, improve our offerings, deliver targeted marketing and promotions, and for research, legal, and other business purposes. Also used for product review syndication with authorized dealers and for administering promotions and discounts. | Same as above. | Shared: Yes of selling or sharing this information , you may fill out a Your Privacy Choices Request | Same as above. |
Internet/ Network Activity | IP address, your device information, domain name, browser type and operating system, cellular carrier, webpages viewed before and after visiting our Website, time spent on webpages, links clicked, transactions entered into, site- navigation patterns, and location information. Also includes cookie IDs, pixel IDs, log data, error logs, and session replay/heatmap data from analytics vendors | Your computer or mobile device when you use our Site, services, or social media accounts; automated technologies (cookies, pixels, SDKs); third-party sources (analytics providers, marketing partners, publicly available data). | To analyze and track use of our Site and services; evaluate popularity and performance; personalize user experience; develop and improve products; deliver targeted advertising and promotions; detect, prevent, and investigate fraud and security incidents; comply with legal obligations and enforce our agreements. Also to honor Global Privacy Control (GPC) signals and user cookie preferences. | Same as above. | Shared: Yes To opt out of selling or sharing this information , you may fill out a Your Privacy Choices Request | Same as above. |
Business to Business Information | Name, signature, company name, mailing address, telephone number, and email address. | You when you purchase products, register for an account, communicate with us via phone, email, social media, or other contact methods; when you interact with us for a business purpose; or when we engage you to provide goods or services. We may also collect from third-party sources such as business partners, service providers, opt-in lists, consumer reporting agencies, referrals, and publicly available data. | To conduct business- to-business interactions, including selling our products, purchasing your goods or services, and maintaining ongoing commercial relationships. | Same as above. | No | Same as above. |
Protected Classification / Demographic Information | Age, gender, veteran or military status. May also include other demographic data if voluntarily provided in surveys, promotions, or reviews. | You when provided voluntarily; may also be inferred or obtained from third-party sources where applicable. | To personalize services, conduct analytics and reporting, meet legal and regulatory obligations, and respond to customer needs and concerns. | Same as above. | No | Same as above. |
Geolocation Data | General location (e.g., from IP); other location tied to website/app use. | Your device/browser via automated technologies (cookies, pixels, SDKs); third- party analytics and advertising partners. | To support site functionality, enhance security and fraud prevention, perform analytics, personalize services, and deliver targeted advertising (where permitted). | Same as above. | Shared: Yes | Same as above. |
Inferences Drawn | Profiles reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (derived from other collected data). | Created internally from other categories of personal information and user interactions with our Site, applications, and services. | To personalize and improve user experiences, develop new products and services, conduct marketing and advertising, and perform analytics. Also used to build audience segments for targeted advertising and measurement. | Same as above. | Shared: Yes | Same as above. |
Category Examples Collected From Purposes Disclosed Sold or Shared To opt out of selling or sharing this information , you may fill out a Your Privacy Choices Request Retention Period |
Category Examples Collected From Purposes Disclosed Sold or Shared of selling or sharing this information , you may fill out a Your Privacy Choices Request Retention Period |
Category Examples Collected From Purposes Disclosed Sold or Shared To opt out of selling or sharing this information , you may fill out a Your Privacy Choices Request Retention Period |
Category Examples Collected From Purposes Disclosed Sold or Shared Retention Period |
Category Examples Collected From Purposes Disclosed Sold or Shared Retention Period |
Category Examples Collected From Purposes Disclosed Sold or Shared Retention Period |
Category Examples Collected From Purposes Disclosed Sold or Shared Retention Period |
Effective date: Sept. 12, 2025
