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Privacy Policy

Privacy Policy

Effective date: 24. March 2022.

  1. Introduction

    Early Majority (“Early Majority”, “us”, “we”, or “our”), operates the Early Majority website https://www.earlymajority.com/ (“Website”) and provides Early Majority’s e-commerce platform selling Early Majority outdoor apparel (“Platform”) (collectively referred to as the “Services”).  The Early Majority entity who acts as controller of your personal data is set out in the “Contact Us” section below. The protection and security of your personal data is important to Early Majority. Personal data means data about a living individual who can be identified from that data (or from that and other information either in our possession or likely to come into our possession) (“Personal Data”). This Privacy Policy (“Policy”) tells you how we collect, use, share and protect your Personal Data which is collected through our Services.

    If you do not agree with this Policy or any part thereof, you should not access or use any part of the Services. If you change your mind in the future, you must stop using the Services and you may exercise your rights in relation to your Personal Data as set out in this Policy.

  2. Personal Data Collection and Use

    We obtain Personal Data about you from various sources as described below.

    Personal Data You Provide to Us

    • Account Information: when you create an account with us to purchase goods via the Platform, we will collect your email address, name, password, billing address, shipping address and phone number.
    • Contact Information and Other Information you Choose to Provide: you have the ability to provide a variety of information during your interactions with us, such as through emails or other communications, including when you enquire about our Services. When you contact us [via a contact form, email, or other means, you provide us with Personal Data, such as your name, contact details and the content of your communications.]
    • Reviews: if you choose to provide a review of our Services on the Website, we will collect and publish your username, and the content of your review.
    • Support Information: when you request technical support services, we will process your Personal Data such as your name and the contact details you use to contact us, as well as information on the reasons for your support request, and any additional information you may provide in that context.
    • Payment Information: when you make a purchase via the Platform, whether for membership or individual goods, we collect your payment card information, solely for the purpose of fulfilling your payment request. To process these payments we use third party payment processors. These payment processors process your personal data, including payment information, in accordance with their own privacy policies.  We also collect records of any transactions you make.

    Where applicable, we may indicate whether and why you must provide us with your Personal Data as well as the consequences of failing to do so. For example, it may be necessary for you to disclose certain Personal Data in order for us to provide the Services to you.

    Information Collected via Automated Means

    • Cookies and Similar Technologies: we collect Personal Data via cookies, pixel tags, or similar technologies on our Services (collectively referred to as “Cookies”), [including for conducting analytics and advertising]. For more information on our use of Cookies, please read our Cookie Policy.
    • Usage and Device Data: when you access and use the Services, we receive and store information about interactions with our Services, such as [date/time stamps, usage information and statistics, as well as your device, including your internet protocol (IP) address, network connection, browser type, device type, device identifiers, operating system version and type.]
  3. How and Why we Use Your Personal Data

    To the extent we collect Personal Data from you, as described in this Privacy Policy, we use such information for the purposes listed below.

    If you are based in the European Economic Area (the “EEA”), Switzerland or the United Kingdom (the “UK”), we only process your Personal Data if we have a valid “legal basis” pursuant to European data protection laws for the processing. These legal bases are set out below. Note, that in certain circumstances detailed below, we will process Personal Data on more than one legal basis depending on the specific purpose for which we are using your Personal Data. In some instances, as set out below, we have a legitimate business interest in processing your Personal Data. We only rely on legitimate interest as a legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms and we ensure we comply with any request you make to exercise your rights.

    Purpose

    Legal Basis

    To provide our Services, including to provide the Platform, process payments and access resources such as our newsletter, and to operate, maintain and support our Services.

    Performance of contract; or our legitimate interests  

    To create your account and to secure and maintain it.

    Performance of contract; or our legitimate interests  

    To allow you to post reviews

    Performance of contract; our legitimate interests; or to comply with our legal obligations

    To communicate with you, including to notify you about changes to the Services and this Policy, contact you for administrative purposes, to provide services and information that you request, and to contact you regarding issues concerning your use of our Services.  If you are a reseller or partner, we will communicate with you to manage our relationship.

    Performance of contract; or our legitimate interests

    Subject to any consent requirements, to send marketing materials by email, send alerts about latest developments and newsletters.  You will always be provided with an opportunity to opt-out of receiving such communications.

    Consent; or our legitimate interests

    To provide support including to help us fix any technical issue, including where we respond to your questions or respond to your request for support, maintenance, troubleshooting, or other performance issues.

    Performance of contract; or our legitimate interests

    For administrative and legal purposes, such as for compliance purposes, including enforcing our Terms of Service or enforcing or defending other legal rights, for tax reporting purposes, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency, and to comply with our legal obligations and internal policies as permitted by law, and to help keep our Services safe and fair. 

    To comply with our legal obligations; or our legitimate interests

    For analytics and product development, including by analysing and evaluating your usage of the Services and/or by asking you to participate in market research and surveys, so that we can continue to develop, test and improve our Services to offer new and/or enhanced functionality and features.

    Our legitimate interests

    To create aggregated or anonymised information, in a form that does not allow individuals to be identified, and using the resulting information for statistical purposes, including to better understand our customer base.

    Our legitimate interests

    For personalisation, to customise our Services and communications.

    Our legitimate interests

    To advertise our services to you on other websites.

    Consent, legitimate interests

    To measure the effectiveness and distribution of our advertising campaigns.

    Our legitimate interests

    If, where we are processing your Personal Data to perform our contract with you, you do not provide the Personal Data, we may not be able to conclude or fulfill our contract with you.

  4. How we Share your Personal Data

    In some circumstances we will disclose Personal Data about you:

    • Affiliates: affiliates and subsidiaries of Early Majority may receive your Personal Data.
    • Other Users of the Services: when you leave a review on the Website, your username which does not need to be linked to your real name, and a photo or avatar should you choose to add one, will be visible to other users of the Services, as will any content or review you choose to post.
    • Service Providers: we work with third parties to provide services such as hosting, maintenance and support. These third parties may have access to or process your Personal Data as part of providing these services to us. For the purposes described above we engage providers of website analytics, hosting and cloud computing services and other IT services, e-commerce platforms services, review platform services, consultancy services, regulatory services, legal services, event software providers, customer support services and advertising services in addition to other administrative services.  
    • Service Providers: when you use a payment card to pay for our services, information such as your name, billing address, phone number, email address and credit card information will be submitted to service providers for verification and to manage any recurring payments. These payment processors will use your personal data in line with their own privacy policies. Our payment processors include Shop Pay whose privacy policy you can review at https://shop.app/privacy.
    • Advisors: we work with various advisors, including tax consultants and legal advisors, with whom we may share your Personal Data.
    • Legal: information about our users, including Personal Data, will be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Early Majority, our users, a third party, or the public.
    • Business Transaction: if Early Majority is involved in a merger, acquisition or asset sale, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data may be transferred including as part of any due diligence process. 
    • Aggregated Information: we may use and disclose aggregated or otherwise anonymised information for any purpose, unless we are prohibited from doing so under applicable law.
  5. Exercising Your Privacy Rights and Choices

    If you are in the EEA, Switzerland or the UK, you have the following rights in relation to your Personal Data, as provided under applicable law, and subject to any limitations in such law:

    • access the Personal Data we hold about you;
    • request we correct any inaccurate Personal Data we hold about you;
    • request we delete any Personal Data we hold about you;
    • restrict the processing of Personal Data we hold about you;
    • object to the processing of Personal Data we hold about you; and/or
    • receive any Personal Data we hold about you in a structured and commonly used machine readable format or have such Personal Data transmitted to another company.

    Where you have been asked to consent to the processing of your Personal Data, you can withdraw consent, including by contacting us using our contacts details below. Any withdrawal of consent will not affect the lawfulness of the processing based on your consent before the withdrawal. Please also note that where you withdraw consent, we will only stop processing your Personal Data that relates to the withdrawal of consent.

    You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email or by contacting us at support@earlymajority.com. You may continue to receive service-related and other non-marketing emails.

    For information about your choices with respect to Cookies, please read our Cookie Policy.

    To exercise any of your rights or choices in connection with your Personal Data, please contact us using the contact information in the “Contact Us” section below. Please note that we may ask you to verify your identity before responding to such requests. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. Note that applicable laws contain certain exceptions and limitations to each of these rights.

  6. International Data Transfers

    Your information, including Personal Data, may be accessed from and transferred 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 based in the UK, the EEA or Switzerland, this means that your Personal Data may be transferred outside of the UK, the EEA and Switzerland, including to our affiliates and service providers in the United States.  Please note that these counties may not provide the same protections as the data protection laws in the UK, the EEA and/or Switzerland. In these instances we will ensure that relevant safeguards are in place to afford adequate protection for your Personal Data and we will comply with applicable data protection laws, in particular by relying on an EU Commission adequacy decision or on contractual protections for the transfer of your Personal Data. For more information about how we transfer Personal Data internationally, please contact us as set out in the “Contact Us“ section below.

  7. Children’s Privacy

    Our Services are not directed to children, and we do not knowingly collect Personal Data from anyone under the age of 16. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us as set out in the “Contact Us” section below. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

  8. Retention of Personal Data

    We retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws or until you withdraw your consent (where applicable).

    To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  9. Security of Personal Data

    We have implemented administrative, technical and physical safeguards to protect the confidentiality, integrity and availability of your Personal Data.

    The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. If you think your account has been compromised, please contact us as soon as possible, using the contact details in the “Contact Us” section below.

    The transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk.

  10. Do Not Track 

    Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

  11. Links to Other Sites

    The Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

    We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

  12. 12. Changes and Updates to this Policy

    We may update our Policy from time to time. We will notify you of any changes by posting the new Policy on this page.

    If we make material changes, we will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

    You are advised to review this Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

  13. Complaints

    If you wish to lodge a complaint about how we process your Personal Data, please contact us at support@earlymajority.com. We will endeavor to respond to your complaint as soon as possible. If you are based in the EEA, UK or Switzerland, you may also lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.

  14. Contact Us

    If you are based:

    • in the United Kingdom, Early Majority Ltd, based at  11 Netherconesford, 93-95 King Street, Norwich, NR1 1PW UK, is the entity responsible for the processing of your Personal Data, and for the purpose of the United Kingdom’s General Data Protection Regulation is the data controller in respect of the processing of your Personal Data;
    • elsewhere in Europe, Early Majority SAS, based at 11 Rue Carnot 94270 Le Kremlin-Bicetre Paris, FRANCE, is the entity responsible for the processing of your Personal Data, and for the purpose of the European Union’s General Data Protection Regulation is the data controller in respect of the processing of your Personal Data;
    • in the United States, Early Majority Inc, based at 712 Cuyama Road Ojai, CA 93023 USA, is the entity responsible for the processing of your Personal Data.

    If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Data, please contact us at the address above, or alternatively at support@earlymajority.com.