Last updated June 1, 2021
Welcome to our website. This Privacy Statement describes the types of information that Commando, LLC (“we” or “us”) collects from and about you on www.wearcommando.com (the “Site”). The Site provides information about our company and our products and services. This Privacy Statement is for informational purposes only and describes how we generally collect and use information. When you interact with us through the Site, we may collect information from you, as further described below.
This Privacy Statement also explains how we may use and disclose such information, as well as your ability to control certain uses of it. By using this site, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement.
By using the Site, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement. We collect information about you in a range of forms, including personal information, when you choose to provide it to us. Personal information (or personal data) means information about an individual from which that person can be identified. It does not include personal information where the identity has been removed (anonymous personal information). This may include when you purchase a product, contact us with inquiries or otherwise contact us.
When you interact with us through the Services, we may collect information from you, as further described below.
In some countries, including in the European Economic Area (EEA) and the United Kingdom (UK), this information may be considered personal data under applicable data protection laws:
Information You Provide to Us
We collect information from you when you choose to provide it to us. This may include when you purchase a product, create an account with us, sign up for our rewards program or our email lists, use our Services, submit a rating or review, participate in a survey or promotion, or otherwise contact us.
The information we collect may include your name, address, email address, telephone number, mobile telephone number, geolocation information, photos or videos, user name, purchase history, credit/debit card number or other financial information and billing address. You may be required to provide certain authentication and credential information to create your account, including a username and password.
If you use a third party service to login, link to us, or communicate with us (such as a social network or third party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services.
Information Obtained from Third Parties
If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us, for example, if you have agreed to share information with one of our partners, we may add this information to the information we already hold about you.
Information Collected From Other Sources
We may obtain information about you from other sources, including social networks that you use to connect with Us. If you use a third party service to login, link to us, or communicate with us (such as a social network or third party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services. This information may include name, user name, demographic information, updated address or contact information, interests, and publicly-observed data, such as from social media and online activity.
Combination of Information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Services, Apps, as well as information collected offline or from third party sources to help us tailor our communications to you and to improve our Services.
We may use the information we collect from and about you to:
- Assess the needs of your business to determine suitable products;
- Send you requested product or service information;
- Respond to customer service requests, fulfill or manage orders, process payments and prevent transactional fraud, and contact and communicate with you;
- Send you a newsletter and marketing communications;
- Respond to your questions and concerns, request feedback and post customer reviews through a third party provider;
- Improve the content and functionality of our Web site and marketing efforts;
- Conduct research and analysis, develop new products;
- Display content based upon your interests, including delivering targeted advertising to you;
- Comply with applicable laws, including to respond to requests from public and government authorities;
- Enforce this Privacy Statement;
- Protect our rights, privacy, safety or property, and/or that of you or others.
- Develop new programs, products or services
- Protect the security or integrity of the Services and our business; and
- As described to you at the point of data collection or in our Agreement with our Customer.
We do not sell your personal information to third parties.
We may share the information we collect from and about you with selected third parties, that we believe may provide promotional materials, and goods and services that may be of interest to you:
- to our Service Providers, if the disclosure will enable them to perform a business, professional or technical support function for us;
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law; and
- as described to you at the point of collection.
If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.
We also may share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses. We do not sell your personal information to third parties.
If you do not want us to share your personal information as set forth in this Privacy Statement, contact us at firstname.lastname@example.org.
- Domain Name – through which you access the Internet (for instance, AOL for America Online, or MSN for Microsoft Network, or YAHOO etc.)
- IP address – from the computer or network used to access our website
- Web browser – and operating system used
- Date and time – you accessed our site
- Pages, files, documents, and links – that you visited
- Referral Internet address – of the website from which you clicked to get to our website
Search terms – used in a search engine (like google.com) that brought you to our website.
We may also use third-party tools or services to assist us with analyzing and improving the Site and Services. The service providers listed below are not permitted to use the information collected on our behalf except to help use conduct and improve our business.
Tracking Options and California Do Not Track Disclosures.
We strive to provide you with choices regarding the personal information you provide to us.
You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences.
- We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about how cookies or other technologies are used to deliver more relevant advertising or to opt out of receiving targeted ads please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize. Do Not Track headers or requests from some or all browsers.
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to email@example.com.
- Promotional Offers from the Us. If you do not wish to have your email address used by us to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending an email to email@example.com. For this opt-out to function, you must have your browser set to accept all browser cookies.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
We may contract with third parties to perform functions related to the Services (“Service Providers”). Service Providers will have access to your personal information needed to perform their business functions, but may not use or share that personal information for other purposes. These companies are authorized to use your personal information only as necessary to provide these services to us. For a representative list of Service Providers and their purposes click here:
Below are categories and names of Service Providers with home we share information:
- Advertising, Direct Marketing, and Lead Generation
Bing Ads, Bing Shopping, Google Ads, Google Shopping, Facebook Ads Manager, Facebook Shopping, Instagram Shopping, Klaviyo, SocialCode, JustUno, Bazaarvoice, Loyalty Lion, Returnly, LimeSpot Product Recommender
- Communicate and Chat with Users
Klaviyo, Instagram Messenger, Facebook Customer Chat, Back in Stock, and Bazaarvoice
- Content Optimization
Instagram embed, YouTube video embed, Google Site Search, and LimeSpot Product Recommender
- Data Backup and Security
CGS BlueCherry ERP
- Invoice and Billing
Apple Pay, Google Wallet, PayPal, Shopify Pay, Reach, Visa, Mastercard, Discover Card, American Express, Discover, JCB, Diners Club, and Afterpay
- Retargeting Platforms
Google Ads Remarketing, Google Analytics Remarketing, Facebook Custom Audience, and Facebook Remarketing, Klaviyo
- Social Media Sharing and Advertising
Facebook advertising, Facebook social plugins, Pinterest social plugins, Google Display, and Instagram advertising
- User Commenting and Forums
- Web and Mobile Analytics
Google Ads and Google Analytics
- Website Hosting
- Website Performance Monitoring
Shopify and Google Analytics
- Rakuten Advertising Partnership
If you would like to opt out of this data collection, you may do so here: https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/
CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. Our Site collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”) Personal information does not include:
publicly available information from government records.
deidentified or aggregated consumer information.
information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Notice of Collection of Information.
In particular, our Website has/we have collected the following categories of personal information from its consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal
identifier, Internet Protocol address, email address, account name,
Social Security number, driver’s license number, passport number, or
other similar identifiers.
B. Personal information categories listed in
the California Customer Records statute
(Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number,
physical characteristics or
description, address, telephone number,
passport number, driver’s license or state
identification card number, insurance policy number, education, employment, employment history, bank
account number, credit card number, debit card
number, or any other financial information, medical
information, or health insurance information. Some
personal information included in this category may
overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition,
physical or mental disability, sex (including gender, gender identity,
gender expression, pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming histories
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or
activity patterns used to extract a template or other identifier or
identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s
interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an
educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification
codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal
Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
Commando obtains the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
WE DO NOT SELL YOUR INFORMATION TO THIRD PARTIES
We may use or disclose the personal information we collect for one or more of the following purposes:
-To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or 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.
-As described to you when collecting your personal information or as otherwise set forth in the CCPA.
-To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with Service Providers and with third party advertisers, analytics, and content providers
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have not disclosed personal information for a business purpose.
Your Rights and Choices
The CCPA provides consumers who are California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:
-The categories of personal information we collected about you.
-The categories of sources for the personal information we collected about you.
-Our business or commercial purpose for collecting or selling that personal information.
-The categories of third parties with whom we share that personal information.
-The specific pieces of personal information we collected about you (also called a data portability request).
-If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
-sales, identifying the personal information categories that each category of recipient purchased; and
-disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
-Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
-Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
-Debug products to identify and repair errors that impair existing intended functionality.
-Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
-Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
-Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
-Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
-Comply with a legal obligation.
-Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
Calling us at: 1-800-506-6880
Emailing us at firstname.lastname@example.org
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. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Notice of the Right to Opt-Out of Sale of Personal Information
WE DO NOT SELL YOUR INFORMATION TO THIRD PARTIES
Non-Discrimination; Notice of Financial Incentive
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
-Deny you goods or services.
-Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
-Provide you a different level or quality of goods or services.
-Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: email@example.com or write to us at the following mailing address:
472 Meadowland Drive
South Burlington, VT 05403
You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your e-mail address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Your rights as a visitor from the European Economic area (EEA) OR THE UNITED KINGDOM (UK)
If you are a European or UK resident, our legal basis for collecting and using your personal data or information is to do so with your consent; where we need the personal data or information for performance of a contract, or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question.
You have the right at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights. If we are the data controller, you can contact us to exercise these rights. If we are the data processor, you must contact the controller to exercise these rights:
- Access your personal data or information;
- Delete, or request deletion of, your personal data or information;
- Object to or restrict processing of your personal information;
- Request portability of your personal information;
- Complain to your local data protection authority at any time;
- Object to automated decision making; and
- Update your personal data or information.
To withdraw consent or exercise these rights, please contact Commando’s Privacy Officer or adjust your preferences through contacting firstname.lastname@example.org
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide personal data to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your personal data is required and if not, the consequences of not sharing your personal data with us.
Similarly, if we collect and use your personal information in reliance on our or a third party's legitimate interests and those interests are not already listed above (see "Information Use" section), we will let you know what those legitimate interests are.
LINKS TO OTHER WEB SERVICES
The Services may have links to third-party Services or applications, including payment processors or video platforms which may have privacy policies that differ from our own. We are not responsible for the practices of such Services or applications.
Protecting children’s privacy is important to us. We do not direct the Services to, nor do we knowingly collect any personal information from, children under the age of thirteen.
We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Services visitors and users. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.
DATA STORAGE AND RETENTION
Your personal information is stored on servers in the United States. You understand and agree that Commando may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement even if you are from an area outside the United States. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Services, or to fulfill any legal or contractual obligations we may have.
If you are a resident of the EEA or UK: Your personal information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact Commando’s Privacy Officer at email@example.com.
ACCESS TO YOUR PERSONAL INFORMATION
If you have an account on our Services, you may sign in to your account and update your personal information contained in the account.
IF YOU HAVE QUESTIONS
If you have any questions, requests or concerns about this Privacy Statement or the practices described herein, you may contact our Commando’s Privacy Officer at: firstname.lastname@example.org
REVISIONS TO THIS STATEMENT
We reserve the right to revise this Privacy Statement at any time. When we do, we will post the change(s) on the Services. If we change the Privacy Statement in a material way, we will provide appropriate notice to you.