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Privacy Policy

PRIVACY POLICY

 

Effective Date: This Privacy Policy was last revised on November 16, 2021.

 

Welcome to Democracy Clothing.

 

Democracy Clothing is a division of Kellwood Company LLC (“Kellwood”).  This Kellwood Privacy Policy (the “Policy”) describes how we collect and use personal information about you when you visit the Democracy Clothing website https://democracyclothing.com/ (including, without limitation, both mobile and online versions of our web sites, and also applies to your use of all features, applications, content, downloads and other services that we make available through these web sites and/or that post a link to this Policy (collectively, referred to herein as the “ Website”), regardless of how you access or use the Website, whether via personal computers, mobile devices or otherwise.  This Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below).

To the extent we provide you notice on our Website of different or additional privacy policies or practices ( e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Website’s Terms and Conditions of Service which governs your use of the Website.  By using our Website, you consent to our Policy and Terms and Conditions of Service and our collection, use and sharing of your information and data, and other activities, as described below.

 

Scope of Privacy Policy

 

This Policy explains how we collect, use, disclose and manage your personal information that you provide to us when using the Website, purchasing products, or otherwise, as well as our privacy practices. This Policy applies, without limitation, to any individual or entity that (i) uses the Website, (ii) creates an Account (as defined in our Terms of Service), (iii) purchases products directly from us or (iv) otherwise provides any personal information to us.

WHEN YOU ACCESS OR USE THE SITE, PURCHASE A PRODUCT, OR OTHERWISE PROVIDE ANY INFORMATION TO US, YOU AGREE TO THIS POLICY, INCLUDING THE MANNER IN WHICH WE USE YOUR INFORMATION, WHETHER OR NOT YOU HAVE AN ACCOUNT WITH KELLWOOD. IF YOU DO NOT AGREE TO THIS POLICY, OR TO ANY CHANGES WE SUBSEQUENTLY MAKE TO THIS POLICY, YOU MUST IMMEDIATELY STOP USING THE SITE OR OTHERWISE PROVIDING ANY INFORMATION TO US.

 

 

In this Policy, “we” and “our” means Kellwood d/b/a Democracy Clothing, and “you” means any person who visits the Website.

 

If you are accessing the Website in the European Union and the United Kingdom, then you will have additional rights which we explain in this Policy.

You accept the terms of this Policy by using and/or accessing the Website.

The Website contains links to other websites. This Policy does not apply to information collected on or through any such third party websites. We are not responsible for the privacy practices of such third parties or the content of their websites. Such third parties have their own privacy policies and you should review those privacy policies to determine their privacy practices.

This Policy is divided into the following sections:

  • Types of Information We Collect
  • Ways We Collect Information
  • Children Under the Age of 18
  • Cookies and Other Third-Party Tools
  • Ways We Use Information We Collect
  • Sharing Information
  • Transferring Your Personal Data If You Are Outside the United States
  • Our Legal Bases for Using Your Personal Information
  • Your Rights and Choices Regarding the Use of Your Personal Information
  • Amendments to this Privacy Policy
  • Onward Transfer of Information
  • Security of Information
  • Retention of Your Personal Information
  • Enforcement of this Privacy Policy
  • Intellectual Property
  • Hypertext Links
  • Your California Privacy Rights
  • Contact Us

 

  1. Types of Information We Collect

We collect various types of information including the following:

  • "Personal information": any information that specifically can be associated with, identifies or which relates to a person and/or could be used to identify a person (i.e. name, address, email address, telephone number, payment information). It does not include personal information that is encoded or anonymized, or publicly available information that has not been combined with non-public information. If you are using the Website in the European Union and United Kingdom, it may also include additional data that could identify you or be indirectly be linked to you (i.e. your location, the way you use the Website, certain aggregated data).
  • Financial information, such as credit and debit card numbers and claims information;
  • Purchase history information, such as products you have bought, rented, and returned;
  • Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors;
  • Certain information we get from your usage of the Website, as described further in the next section.
  • Preference information, such as your contact and marketing preferences, and merchandise interests;
  • Profile and account information, which may include contact, purchase, and preference information as well as your account password, information about items in your online shopping cart or saved for future purchase, product review information, and other information about your profile or account;
  • Demographic information, which may include age or birthdate, gender, ZIP code, and other information about you;
  • Location informationof your device that you use with our Website, if your device settings allow us to collect location information; and
  • Device and browsing information, including information about your phone, tablet, computer, or device, and online browsing activity (collectively, “automatically collected information”). Automatically collected information may include IP addresses, unique device identifiers, cookie identifiers, device and browser settings and information, and Internet service provider information. Automatically collected information also may include information about when and how you access and use our Website, such as the date and time of your visit or use, the websites you visit before coming and after leaving our website, how you navigate and what you search for using our website and mobile application, the website pages and items you view using our website and mobile application, and the items you purchase.

 

  1. Ways We Collect Information

We collect information that you provide us, from third parties, and automatically when you use the Website. We also collect information from cookies and other third party tools. We may also collect information about your location.

Information we get automatically from your use of the Website. Certain information is provided to us automatically from your use of the Website, including:

  • Information about your browser type, language preference, referring site, and the time of each visit.
  • Information about how you use the Website (e.g. how long you use the Website, when you use the Website).
  • Information about your approximate location.
  • Information about you such as your Internet Protocol (IP) addresses, the Uniform Resource Locator (URL) accessed (which may reference the name of a board, card, username, or team), and the unique identification number associated with the account.
  • Information collected from cookies, which is explained further in the following section.

Information you provide to us directly. We may collect the following personal information:

  • Account information, such as your name, email address, postal address, telephone number and date of birth, if you choose to sign up for or purchase our Website.
  • Transactional and financial information, including payment information, credit card number, expiration date, authentication code, and similar information, if you choose to purchase any products on our Website.
  • Information you provide when you communicate with us, such as emailing us.

In each case, we only collect as much information as is necessary or appropriate given the type of interaction. We do not disclose personally identifying information other than as described below. And you can always refuse to supply personally identifying information, with the caveat that it may prevent you from engaging in certain activities or from using the Website.

When we collect your personal information, we'll tell you how we're using it, any types of third parties to which we might disclose it, (other than "agents," such as vendors or contractors, who are only processing such information for us or at our direction), and the choices we offer you to limit the use of your information.

Notice will be provided in clear and conspicuous language when you are first asked to provide us with personal information, or as soon as practicable thereafter, and we will notify you before we use the information for something other than the purpose for which it was originally collected.

 

  1. Children Under the Age of 18

The Website is not intended for children under 18 years of age. No one under the age of 18 may provide any personal information to or through the Website. We do not knowingly collect personal information from children under 18. If you are under 18, please do not use or provide any information to or through the Website. By using the Website and agreeing to this Policy, you represent and warrant that you are at least 18 years of age.

  1. Cookies and Other Third-Party Tools

We may also receive information through “cookies” and other third-party technologies. A cookie is a small piece of data that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. We use cookies and other tracking technologies (like Google Analytics) to help us recognize your visit and track visitors' use of and interaction with the Website. We use third-party technologies such as Google Analytics to improve our site and user experience, and have enabled certain features within Google Analytics. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files,or other technologies to receive, collect, and store information on our behalf.

 

Third Party Analytic Technologies: We may use third parties’ analytics and tracking tools, such as Google Solutions, Facebook Solutions and others, to help us track, segment and analyze usage of our Website, and to help us or those third parties serve more targeted advertising to you on the Website and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store non-personal information. They may also combine information they collect from your interaction with the Website with the information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies. To learn more about your advertising choices relating to the collection and use of your information, please see the Opt-Out section below.

 

California Do Not Track Disclosure

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on the DNT signal, the browser sends a message to the Website requesting them not to track the user. For information about Do Not Track, visit www.allaboutdnt.org . At this time, we do not recognize or respond to DNT browser settings or signals and we will still receive information. As a result, we may still collect information about you and your internet activity, even if you have turned on the DNT signal.

However, you can adjust your browser settings to restrict Cookies. Also, it is possible that some or all of our third-party advertising partners or members of their affiliate network may participate in a consumer opt-out programs.

 

Your Options

 

If you do not wish to have cookies placed on your computer, you should set your browser to refuse cookies, but should be aware that certain features of our Website may not function properly without them. Please review your web browser settings to find out more on how to disable cookies. You can also visit the Digital Advertising Alliance and the Network Advertising Initiative pages to opt-out of cookies.

 

 

 

  1. Ways We Use Information We Collect

Among other things, we may use information about you to:

    • Allow you to register for our Website and to administer and process the registration;
    • Communicate with you about our products and services and related issues;
    • Evaluate the quality of our products and services, and to enhance your experience on our Website;
    • Maintain and administer our Website and comply with our legal or internal obligations and policies;
    • Transfer information to others as described in this policy or to satisfy our legal, regulatory, compliance, or auditing requirements, including to disclose information to law enforcement authorities upon validly served legal process or a valid judicial instruction (for example, pursuant to a court order);
    • Charge you any fees and provide you with a receipt or resolve billing issues associated with your account;
    • In the case of accounts created using business email domains, to provide your contact information to an administrator of the business email domain to facilitate the provision of additional products and/or services;
    • Complete transactions you have initiated through the Website, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
    • Contacting you about new features, to solicit your feedback, or to keep you up to date with what's going on with the Website or our products. If we do send you information that you did not expressly request, we will provide you with a way to request that you don't get any similar notices (opt-out, unsubscribe, etc.).

    To better understand how visitors use the Website and, where possible, to improve their experience.

    1. Sharing Information

    We may share personal information about you as follows:

    • With vendors, consultants, contractors and other service providers who access personal information to carry out work on our behalf and improve the products and services they provide to us (e.g., companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, analytics, marketing and advertising);
    • In response to a request for personal information if we believe disclosure is in accordance with any applicable law, regulation or legal process or as otherwise required by any applicable law, rule or regulation;
    • If we believe your actions are inconsistent with our user agreements or policies or to protect the rights, property and safety of us or any third party;
    • In connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company;
    • With our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
    • With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
    • By publicly posting, at our discretion, your product review or other user content if you provide one; and
    • With your consent or at your direction.

    We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

    1. Transferring Your Personal Data If You Are Outside the United States

    If you are outside the United States, any personally identifiable information you enter into the Website will be transferred out of your country and into the United States, and possibly to other countries. By using the Website, you consent to such transfer and are representing that you have the right to transfer such information outside your country. The laws that apply to the use and protection of personal information in the United States or other countries or jurisdictions in which we transfer or process personal information may be different than the laws and protections in your country. If you are accessing our Website from the European Union or United Kingdom, we will comply with applicable data protection laws anytime that we transfer your personal information outside of the European Economic Area (EEA). Some of the ways we will do so are:

    • Where the transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
    • Using the EU Model Clauses, which are specific contracts approved by the European Commission giving personal data the same protection it has in Europe.
    • Transferring data to US-based providers if they are part of the Privacy Shield, which requires similar protection to personal data shared between the Europe and the US.
    1. Our Legal Bases for Using Your Personal Information

    If you are accessing our Website from the European Union and United Kingdom, we must only process your personal information where we have a legal basis to do so. This means that one of the following must apply when we use your personal information:

    • You have consented to the use of your personal information. You may withdraw your consent at any time.
    • We need to use your personal information to perform under our contract with you (i.e. providing our Website to you or processing payment for products).
    • It is in our legitimate interests to use your personal information, for example as follows: in connection with our Website; to ensure that our Website is secure; to tell you about changes to our Website; to improve our Website; to tell you about offers or promotions we are running; for business reasons (for example to develop our business or if we are thinking of selling our business); for operational purposes; to tell you about new services or products we are offering.
    1. Your Rights and Choices Regarding the Use of Your Personal Information

    We provide a number of choices about how you may control the use, collection and storage of your personal information, and want you to be aware of that you have all of the following rights regarding your personal information:

    • To “opt-out” of promotional or marketing emails from us.
    • To have access to any personal information we hold about you.
    • To ask us not to use your personal information for direct-marketing purposes.
    • To ask us to erase the personal information we hold about you.
    • To restrict the way that we process your personal information.
    • To have a copy of any personal information which we hold about you.
    • To have your personal information provided to a third-party provider of services.
    • To object to our processing of your personal information.
    • To complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available here. [LINK: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080]

    You have the ability to correct, update, modify or delete your personal information by updating your information on the Website. Please note that some information may remain in our records even after you request deletion of your information. Additionally, there may be limits to the amount of information we can practically provide. For example, we may limit an individual's access to personal information where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy or where doing so would violate others' rights.

    Please contact us using the details below with any questions or requests in regards to any of the above.

    1. Amendments to this Policy

    We may amend this Policy from time to time by posting a revised version and updating the date in the Change Log below. In the event that we change this Policy to permit the collection and sharing of information with a non-agent third party, we will first give you the opportunity to explicitly consent (opt-in) to such disclosure or to any use of the information for a purpose other than the one for which it was originally collected or previously authorized.

    ANY ACCESS OR USE OF THIS WEBSITE BY YOU AFTER NOTICE OF REVISIONS OR ADDITIONS TO THESE TERMS SHALL CONSTITUTE AND BE DEEMED TO BE YOUR ACCEPTANCE OF SUCH REVISIONS OR ADDITIONS.

    1. Onward Transfer of Information

    Prior to providing agents with any personal information, we will obtain assurances that they will safeguard it in accordance with this policy. In the unlikely event that we should discover that an agent is using personal information in a way that conflicts with this Policy, we will take all reasonable steps to stop it immediately.

    1. Security of Information

    All records containing personal or financial information are considered to be our property and are afforded confidential treatment at all times. We work hard to protect against the unauthorized access, use, alteration or destruction of personal or financial information. All such electronic information is stored on restricted database servers, and is generally kept until such time as you may ask us to edit or delete it, as described below. We only disclose such information to our employees, contractors or affiliates that a) need to know that information in order to process it for us or to provide other services, and b) have agreed not to disclose it to others. All interactions with our Website use the Secure Sockets Layer (SSL) protocol and firewall network protection. We use a third-party, industry-accepted Payment Gateway to securely process credit card transactions.

    Unfortunately, information transmitted through the Internet may not be perfectly secure, and we are unable to guarantee the security of your personal information.  We encourage you to take steps to help protect the confidentiality and security of your account and personal information, including by doing the following: 

    • Reviewing your account periodically and immediately reporting any unexpected activity or unrecognized information;
    • Installing the latest security updates and anti-virus software on your computer to help prevent malware and viruses;
    • Using complex passwords (a minimum of 7 alpha/numeric cAsE sEnsitive characters);
    • Not using the same password on more than one website;
    • Not sharing your password with others;
    • Password protecting your computer and mobile device; and
    • Sign out/log off of website sessions so that your session is closed, especially when using a public computer.

     

    To protect Kellwood’s customers from fraudulent transactions on the Website, all orders are subject to review and verification. As part of the verification process, an order may be temporarily placed on hold in order to verify credit card billing information, which may include contacting the credit card holder.

    1. Retention of Your Personal Information

    We retain personal information as long as your account is active or as required to provide you with the Website.  If you decide to delete your account with us or otherwise opt-out from receiving information from us, we will generally delete your personal information, except in certain circumstances such as retaining certain personal information in anonymized or aggregated form about your use of the Website to analyze and improve the Website. We may also retain your personal information in order to protect our legal rights, or those of third party, or to comply with the law. You can find out further information by contacting us at customerservice@democracyclothing.com or by calling 1-626-269-2860.

    1. Enforcement of this Privacy Policy

    We will conduct internal audits of our compliance with this privacy policy, including an annual self-assessment. We will take all reasonable measures against any employee found to be in violation of this policy.

    1. Intellectual Property

    Kellwood, its suppliers, licensors, or the original creators of all materials on the Website own all copyrightable subject matter on the Website and all trademarks, patents, proprietary information, technologies, products, processes or other proprietary rights of Kellwood and/or such other parties. No license to or right in any such copyrights, trademarks, patents, proprietary information, technologies, products, processes and other proprietary rights of Kellwood and/or other parties is granted to or conferred upon you. In addition, direct linking, deep linking, framing, page-jacking, metatagging, and using a robot, spider, or automated device of any kind to monitor or copy the Website is strictly prohibited.

     

    Notwithstanding the foregoing, Kellwood hereby authorizes you only to copy the content herein solely for your personal and private use in learning about, evaluating, or acquiring Kellwood products. Except where expressly noted, no other permission is granted to print, copy, reproduce, distribute, transmit, upload, download, store, display in public, alter, or modify the content contained on the Website. Any unauthorized use of any material contained on the Website may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes. Any other use of materials on the Website, including reproduction for purposes other than those expressly permitted herein, modification, distribution, or republication, without prior written permission of Kellwood is strictly prohibited. Any copy made by you as permitted herein must retain all copyright and trademark notices, including any other proprietary notices, contained in the materials. The use of such materials on any other website or in any environment of networked computers is prohibited.

     

    • Hypertext Links

     

    In the event this website contains hypertext links to websites that are not created or maintained by Kellwood, this Policy applies only to the Website and not to any of these third party websites. Kellwood is not responsible for the accuracy, relevance, timeliness, or completeness of those third party websites. The inclusion of any link to such websites does not imply endorsement, sponsorship, or recommendation by Kellwood of the third party websites. Kellwood disclaims any liability for links (1) from another website to this Website, and (2) to another website from this Website. Kellwood cannot guarantee the standards of any website to which links are provided on this Website, nor shall Kellwood be held responsible for the contents of those websites, or any subsequent links. For this reason, Kellwood does not represent or warrant that the contents of any third party website is accurate, compliant with state or federal law, or compliant with copyright or other intellectual property laws. Kellwood does not endorse the contents of these third party websites in any way. Also, Kellwood is not responsible for web casting or any other form of transmission received from any linked website. Any reliance on the contents of a third party website is done at your own risk, and you assume all responsibilities and consequences resulting from such reliance.

     

    • Opt-Out.
    If you want to be removed from our marketing list and do not want us to send you email, postal mail or other messages about our products and services, you can opt out. To do so, please send an email to customerservice@democracyclothing.com with the word “REMOVE” in the subject line.

       

      • Your California Privacy Rights

      As of January 1, 2020, California residents are provided with specific rights regarding their personal information. This section describes further how we comply with the requirements of the California Consumer Privacy Act of 2018 (“CCPA”) and your rights under that law. Any capitalized terms used but not defined in this section shall have the meanings given to them in the CCPA. 

       

      California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding our disclosures of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at the following address:

       

      By Email: customerservice@democracyclothing.com, Subject “Privacy Policy Question”

       

      By Mail:

      Democracy Clothing

      ATTN: Legal Department

      13071 East Temple Ave

      City of Industry, CA 91746

       

       

      Collection and Use of Personal Information: In the preceding 12 months, we have collected the following categories of personal information: identifiers, information subject to Cal. Civ. Code § 1798.80(e), characteristics of protected classifications under California or U.S. law, commercial information, Internet or other electronic network activity information, geolocation data, professional or employment-related information, audio, electronic, visual or similar information, inferences drawn about you and other categories of personal information that relate to, describe or are reasonably capable of being associated with you. For examples of the precise data points we collect and the sources from which we collect this personal information, please see “Ways We Collect Information” above.

      Recipients of California Personal Information.

      We may share your personal information with third parties as described in the “Sharing Information” section above.

      The CCPA has defined a “sale” to include any transfer of personal information by us to another entity for anything of value. Sale is defined very broadly in the CCPA and encompasses the “sharing” of your information with third parties. We do not sell your information for monetary gain, but we may share your information with third parties like Google, Facebook, PayPal, and Apple Pay.

       

      In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients:

       

      Category:

      Categories of Sources:

      Business or Commercial Purposes for Collection, Use or Sharing:

      Disclosed for Business Purposes to Third Parties:

      User provided information (e.g. identifiers, such as, first name and last name, email address, phone number; and financial information)

      All categories listed below

      All purposes listed below

      All categories listed below

      Location Information (geolocation information and commercial information)

      All categories listed below

      All purposes listed below

      All categories listed below

      Website and Account usage information (e.g. browsing history, order history, search history, interactions with a website, email, application or advertisement, pages viewed, and customer service inquiries)

      All categories listed below

      All purposes listed below

      All categories listed below

      Device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information)

      All categories listed below

      All purposes listed below

      All categories listed below

      Inferred Data (e.g. inferred user information, preferences or tastes)

      All categories listed below

      All purposes listed below

      All categories listed below

      Professional or employment related information

      Job applicants only.

      All purposes listed below

      All categories listed below

      Other information about you that is linked to the personal information above

      All categories listed below

      All purposes listed below

      All categories listed below

       

      Categories of Sources: We collect this personal information from the following categories of sources:

      • Directly from consumers, including you;
      • Service providers;
      • Affiliates;
      • Third party sources, including social media; and
      • Consumer data resellers

      Why We Use and Disclose California Information. We use and disclose the personal information we collect for our commercial and business purposes as further described in this Policy (see “Ways We Use Information We Collect” above). These commercial and business purposes include, without limitation:

      • Our commercial purposes, including marketing, advertising, offering promotions, authentication, providing you with information you request, identity resolution, fraud prevention, facilitating transactions, and providing you with customized services or recommendations near you (including marketing and advertising).
      • Our business purposes as identified in the CCPA, which include:
        • Auditing related to our interactions with you;
        • Legal compliance;
        • Detecting and protecting against security incidents, fraud, and illegal activity;
        • Debugging and improving our services;
        • Performing services (for us or our service provider) such as account servicing and analytics;
        • Internal research for technological improvement;
        • Internal operations;
        • Processing job applications;
        • Activities to maintain and improve our services; and
        • Other one-time uses.

       

      Your Rights and Choices

      As applicable under the CCPA, from January 1, 2020, if you are a California resident, you may make requests to us as set out below. We will review all requests received and determine the extent to which and how to respond. We will not discriminate against any California resident who makes such requests.

      Right to access/know

      You may request from us a list of: (i) the categories and specific pieces of personal information we collect, use, disclose, and sell about you; (ii) the categories of sources from which we collected your personal information; (iii) our purposes for collecting or selling your personal information; (iv) the categories of your personal information that we have either sold or disclosed for a business purpose; and (v) the categories of third parties with which we have shared personal information. In addition, for certain categories of personal information, you have the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.

      Right to delete your personal information

      You may request to delete your account and the personal information we have collected from you or maintain about you.

      Right to opt-out from the sale of your personal information

      You may request, at any time, to direct us to stop “selling” (for the purposes of the CCPA) your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

      Right to Non-Discrimination

      You have the right to not receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We may offer you certain financial incentives permitted by applicable law as compensation for allowing us to collect, sell, or maintain your personal information.

      Making Requests

      To exercise rights described above, please submit a verifiable consumer request to us by either:

      Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
      • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

      We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

      Making a verifiable consumer request does not require you to create an account with us.

      We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

      You may also submit such requests through an authorized agent. To designate an authorized agent, please send us a notarized power of attorney / notarized letter authorizing said agent. Requests from agents that do not submit such proof that they have been authorized by you to act on their behalf will be denied.

      Other California Privacy Rights

      California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to customerservice@democracyclothing.com

      1. Contact Us

      If you have any questions or suggestions regarding this Policy, please contact us as follows:

      By mail:

      Kellwood Apparel, LLC, ATTN: Legal Department, 13071 East Temple Ave, City of Industry, CA 91746, or by telephone to 1-626-269-2860.

      Email: customerservice@democracyclothing.com

       

      1. Contact Us

      If you have any questions about this policy or our site in general, please contact us at customerservice@democracyclothing.com or by mail to Kellwood Apparel, LLC, ATTN: Legal Department, 13071 East Temple Ave, City of Industry, CA 91746, or by telephone to 1-626-269-2860.

       

       

      CTSC Disclosure

      Kellwood Company LLC d/b/a Democracy Clothing (“Democracy Clothing”) and its subsidiaries expect all of its business suppliers to comply with the applicable laws and regulations of the United States and those of the respective country of manufacture or exportation. Democracy Clothing will not conduct business with any factory that uses involuntary labor of any kind; including prison labor, indentured labor, bonded labor or labor obtained through human trafficking or slavery. Pursuant to the California Transparency in Supply Chains Act (2012), below you will find disclosure of the efforts Democracy Clothing is taking to eradicate slavery and human trafficking from our direct supply chain.

      Engagement in verification of product supply chains to evaluate and address risks of human trafficking and slavery.  

      Democracy Clothing utilizes an independent third party to conduct Workplace Conditions Assessments (“WCA”) to determine every prospective supplier’s risk level. The risk assessment includes additional focus on monitoring for human trafficking and slavery risks within the supply chain. Democracy Clothing will only accept suppliers that meet a high-performance threshold following their WCA. When potential risks are identified, a course of action is determined to best address them. Democracy Clothing may require prospective suppliers to complete a corrective action plan (“CAP”) to remediate risks identified in the WCA. All business partners are reviewed annually by an independent third party for social compliance, which includes evaluating risks related to human trafficking and slavery. Partners with identified risks will be required to complete a CAP or other remediation to alleviate such risks. Partners who fail to complete the CAP or fail to demonstrate remediation cannot be approved as Democracy Clothing business partners.

      Auditing of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains.  

      New suppliers that produce Democracy Clothing goods agree to adhere to Kellwood’s Supplier Manual for Social Responsibility through confirmation and acknowledgement exercises. Also, Democracy Clothing audits and monitors existing suppliers that produce Democracy Clothing goods against the Kellwood Supplier Manual for Social Responsibility, Kellwood’s Code of Conduct and the suppliers' country labor laws through independent third party monitoring companies that conduct both unannounced and announced audits. In addition, for all suppliers, Purchase Order Terms and Conditions include statements regarding compliance standards against trafficking and slavery practices. By acceptance of each and every Purchase Order, our suppliers are confirming their understanding and agreement to the compliance standards.

      Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.  

      All Democracy Clothing suppliers agree to adhere to the Kellwood Supplier Manual for Social Responsibility and Code of Conduct, which include language regarding human trafficking and slavery. The Kellwood Supplier Manual for Social Responsibility requires that all suppliers abide by applicable local laws, including laws related to labor practices, health and safety, environmental sustainability, anticorruption and anti-bribery, and brand protection. In addition, the Kellwood Supplier Manual for Social Responsibility and Code of Conduct specifically state that all suppliers must adhere to both the guidelines therein and country labor laws, whichever are stricter. Democracy Clothing specifically monitors for forced labor in our preproduction assessment of all vendor partner factories. If there are any findings, we end any relationship or potential relationship with the supplier. Democracy Clothing also includes similar requirements in its Purchase Order Terms and Conditions and other service agreements. Democracy Clothing sends periodic communications to suppliers making them aware of new laws or revisions to existing laws as appropriate.

      Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. 

      Democracy Clothing expects all employees and contractors to adhere to Kellwood’s  Code of Conduct, which includes information related to our hiring practices. Human Resources is responsible for ensuring that all employees are aware of and adhere to the Kellwood Code of Conduct, and addresses any incidences where an employee or contractor does not do so.

      Training on human trafficking and slavery for company employees and management who have direct responsibility for supply chain management.  

      All Democracy Clothing employees responsible for supply-chain-related decisions are required to complete a training and assessment that ensures their knowledge of identifying and addressing human trafficking and slavery in Democracy Clothing direct supply chains. Further, Democracy Clothing conducts focused employee education in order to mitigate labor and compliance risks within our direct supply chain and will continue to raise their awareness of this issue through regular trainings, information posted on the company's internal websites and communications sent to employees.