Kotis Design Privacy Policy

Effective  3/31/2022. Kotis Design LLC (“Kotis Design”) knows that you care how your personal information is used and shared and appreciates your trust that Kotis Design will do so wisely.  Kotis Design acts as the Data Controller, as defined by GDPR regulations. This Privacy Policy describes how your personal information is collected, used, and shared when you visit, browse or make a purchase from https://kotisdesign.com (the “Site”). The Site includes our subdomains, including but not limited to https://go.kotisdesign.com and https://stores.kotisdesign.com. On client-branded pages, even if hosted on a Kotis subdomain, Kotis acts as a Data Processor and the client’s Privacy Policy applies instead of the policy herein.

 

 

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view and/or purchase, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using multiple technologies, like many websites, including the following: 

“Cookies”  are data files that are placed on your device or computer and often include an anonymous unique identifier, which we use to help us improve your access to the Site and identify repeat visitors. For more information about cookies, visit http://www.allaboutcookies.org.

“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site. This includes, but not limited to, Google Analytics and Facebook Pixel. Google may provide us anonymized demographic and interest-based information about you, consolidated in reports. 

Vendors under contract – We utilize 3rd-party services to collect, store, and provide insights to your data. For example, we use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. Additionally, we may utilize Facebook Pixel to track user acquisition and gather anonymous data to be used for future advertising. For more information on Facebook Pixel privacy, read more here: https://developers.facebook.com/docs/privacy/. 

Controlling your data – You may edit or disable cookies, tracking, and other functions on our website by clicking “Cookie Preferences” in the website footer. We request consent from all visitors to our site, and do not begin tracking users until we receive consent in areas where legally required. 

Additionally, if you make a purchase or attempt to make a purchase through our hosted web stores, we collect certain information for fulfilling your order. During the checkout process you are required to enter certain personal information, including your email address, name and shipping address. We collect this information in order to process your order and facilitate the provision and delivery of services by Kotis. This information is only shared with the store platforms we host, not any advertising third parties. We refer to this information as “Order Information.” 

We also may track offline sales data if you submit a product quote request (“PQR”) form through our website with your personal information. Additionally, we reserve the right to merge sales data with anonymized browsing data tracked while you are browsing our website. 

If you complete a web form on our website, we will use your information to complete your request. With your consent, we will use your information to engage in marketing or re-marketing campaigns. 

We do not collect all information automatically; most identifiable information is received when purchasing from us, registering service, or submitting requests for information. Kotis Design’s Site and Service have collected the following categories of personal information from its consumers within the last twelve (12) months: 

Categories Examples Collected?
A. Identifiers A real name, alias, address, unique personal identifier, IP Address, email address Yes
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.		 Yes
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). No
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
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. No
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location or movements. No
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current or past job history or performance evaluations. No
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. No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

Personal information does not include any information that is exempt under the CCPA or other applicable law.

Kotis Design 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 through the Service (including when you purchase via one of our clients).
  • Indirectly from you. For example, from observing your actions on our Website.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to: 
Communicate with you
Screen our orders for potential risk or fraud;
When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services; and for other internal purposes. 

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). 

With your consent, we may use any information submitted to our website for marketing purposes, including, but not limited to, email newsletters, sales follow-ups, and re-targeting. Email newsletters will always carry an opt-out link, and we will honor this to our best ability and where legally obligated.

 

 

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. This does not include your Order Information. Please see the above section titled “Vendors under contract”

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. 

 

 

BEHAVIORAL ADVERTISING

As described above, we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

 

 

SECURITY

When you submit sensitive information via the website, we take steps to protect your information both online and offline. 

For example, wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon on your web browser or looking for “https” at the beginning of the address of the web page. 

Also, while we use encryption to protect sensitive information transmitted online, we also protect your information offline. For example, only employees who need the information to perform a specific job (e.g. billing or customer service) are granted access to personally identifiable information. The servers on which we store personally identifiable information are kept in a secure environment and are hosted and encrypted on third party servers – generally owned and operated by Amazon Web Services, WP Engine, and Google.

While there is no such thing as a security guarantee, we will continue implementing new strategies to protect your data as technologies develop. 

 

FOR EUROPEAN USERS

 

YOUR RIGHTS

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. 

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

 

 

FOR CALIFORNIA RESIDENTS

This section for California residents supplements the information contained in Kotis Design’s Privacy Policy and 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 section.

Information We Collect
See “PERSONAL INFORMATION WE COLLECT” 

Disclosures of Personal Information
In the preceding twelve (12) months, Kotis Design has disclosed the following categories of personal information for a business purpose: 

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category D: Commercial information.

We disclose your personal information to the following categories of third parties:

  • Service providers (e.g., payment processor, technology vendors).
  • Clients who run a program from where you have purchased

We do not sell your data.

Your Rights and Choices
The CCPA provides consumers (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 Kotis Design 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, if requested:

  • 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 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).

Deletion Request Rights
You have the right to request that Kotis Design 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 your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us, our Providers, or our service provider(s) to:

    1. 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, or otherwise perform our contract with you.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Debug products to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). Engage in public or peer-reviewed scientific, historical, or 6. 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.
    6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    7. Comply with a legal obligation.
    8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Do Not Sell My Personal Information
Kotis Design does not sell personal information.

Exercising Access, Data Portability, Deletion, and Opt-out Rights 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
• Visiting this link or

• Mailing us at:
PO Box 24003
Seattle, WA 98124-0003

Only you, or a person registered with the California Secretary of State that you authorize 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. 

Kotis Design may request additional information (e.g. your Google ClientID, I.P. Address, email, full name, order dates) to ensure we find all your data 

 

DATA RETENTION/UPDATES

When you place an order through the Site and input your shipping information, that shipping information will be retained as follows: 5 years from shipment for orders shipping outside the USA, 18 months from shipment for orders involving a credit card, and 12 months for all other orders. When you place an order through the Site or use the Site, we will maintain and control all other Personal Information (besides shipping information referenced above) unless and until you ask us to delete this information.  You may request that we delete or modify your personal information and preferences at any time by contacting us via the contact information below. 

We keep non-identifying information indefinitely, unless deletion is requested.  

 

MINORS/CHILDREN

Our site does not knowingly collect personal information from children under the age of 16 

 

LINKS/THIRD PARTY SITES

The Site contains links to other sites, including as part of third-party advertising. Please be aware that we are not responsible for the content or privacy practices of such other websites or third parties. We encourage our users to be aware when they leave our Site and to read the privacy statements of any other website that collects personally identifiable information.

 

POLICY REVISIONS

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.  If so, updated versions of this policy will be made available on the Site.  

 

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint or request, please contact us by visiting this link or by mail using the details provided below: 

PO Box 24003
Seattle, WA 98124-0003