Action Bronson Privacy Policy

EFFECTIVE DATE: 05/23/2024

Action Bronson Corporation (“Action Bronson,” “we,” “us,” “our”), is committed to protecting the privacy and security of the information we handle and to being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you.  It applies to the websites and online service(s) that we operate and that link to this Privacy Policy (i.e., www.actionbronson.com; www.baklavafleamarket.com; www.specializinginlife.com) (the “Services”).  

We may update this Privacy Policy from time to time. We will notify you of material changes to this Privacy Policy by updating the effective date shown above. We encourage you to regularly check for updates and changes to this Privacy Policy when you access our websites and mobile applications.

INFORMATION WE COLLECT

When you visit and use the Services, we may collect the following categories of information, depending on how you interact with us.

Information you provide directly to us. 

• Identifiers, including name, email address, telephone or mobile phone number, address;
• Commercial Information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Transaction and Billing Data, including payment card details; 
• Geolocation Information, including information about your location of your device, such as information derived from your device (e.g., based on a browser or device’s IP address); 
• Inferences, including inferences drawn from the other information described above.

Correspondence you send to us.

Information we collect automatically.  We may collect information related to your electronic network activity, such as your browsing history, information about how you use the Services, and information about your device.

We also receive the categories of information described above from other sources, including from internet service providers, and operating systems and platforms.  For example, if you access any social media or similar services through the Services to login or to disclose information about your experience on our Services with others, we may collect information from these third-party services.

Without this information, we may not be able to provide you with all the requested services.  We may aggregate or de-identify the information described above.  Aggregated or de-identified data that we do not attempt to re-identify is not subject to this Privacy Policy.

HOW WE USE YOUR INFORMATION

We may use your information for legitimate business purposes, including to provide the products and services you request, to perform customer service functions, for security and fraud prevention, and to perform website and mobile application analytics.  Additional information about these business purposes is as follows, including the legal bases we rely on to process your information (where applicable law requires this):

Purpose/Activity	Lawful Basis for Processing (where required by applicable law)
To provide you with products and services and information you request from us; to allow you to participate in interactive features of our Services, when you choose to do so; to manage accounts; to manage our relationship with you; and to notify you about changes to our terms or privacy policy.	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (for instance, to keep our records updated)
To make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you, or to send promotional materials from us or by our affiliates and trusted business partners.	(a) Necessary for our legitimate interests (to grow our business) (b) Consent (where required by applicable law)
To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device; to administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.	(a) Necessary for our legitimate interests (for instance: running and protecting our business; provision of administration and IT services; network security and to prevent cybercrime and fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy) (b) Necessary to comply with a legal obligation

We may also process other information in order to fulfill any other business or commercial purposes at your direction or with your consent, which may subsequently be withdrawn in accordance with relevant laws by contacting us as set forth below in the “Contact Us” section.  Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.

Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services).  In this case, we may cancel a product or service you have with us.

TO WHOM WE DISCLOSE YOUR INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may disclose the information we collect. 

• Corporate affiliates. We may disclose your information with our corporate affiliates.
• Authorized third-party vendors and service providers. We disclose your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, data hosting, auditing, and data processing.  To the extent we use an unaffiliated payment service to allow you to purchase a product or make a payment (“Payment Service”), information you provide the Payment Service may be subject to the applicable Payment Service’s privacy policy, rather than this privacy policy.
• Business transfers. If we become involved with a merger, corporate transaction or another situation involving the transfer of some or all of our business assets, we may disclose your information with business entities or people involved in the negotiation or transfer.
• Legal purposes. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property, safety of Action Bronson or our customers or partners.
• With your consent or at your direction. We may disclose your information for any other purposes disclosed to you at the time we collect the information, or pursuant to your consent or instruction.  

If you choose to engage in public activities on the Services, you should be aware that any information you post can be read, collected, or used by other users of these areas.  You should use caution in disclosing information while participating in these areas.  We are not responsible for the information you choose to submit in these public areas.

In the twelve months prior to this Privacy Policy taking effect, Action Bronson has not sold your information to third parties nor has it shared your information with third parties for interest-based advertising.

We do not use or disclose sensitive data to infer characteristics about you or for any purpose other than those permitted by applicable law.  

ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES

We and others may use a variety of technologies to collect information about your device and use of our websites and mobile applications.  These technologies use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. By using the Services, you consent to our use of cookies and similar technologies, unless applicable law requires that we obtain affirmative consent for the use of cookies that are not strictly necessary to provide our Services, in which case you may indicate your preferences on our cookie consent interface available in our website footer.  In addition, most web browsers can be programmed to accept or reject the use of some or all of these technologies, although you must take additional steps to disable or control other technologies. For more information on exercising your preferences in relation to cookies and similar technologies, please see the section of this Privacy Policy titled “Your Choices & Rights”.

The following types of cookies are used on our Services:

• Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services.  These cookies also help keep our Services safe and secure.
• Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
• Analytics and Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.

We may use other categories of cookies in the future, including targeting and social media cookies, where that is permitted by law.

Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit “do-not-track” signals.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  We currently do not take action in response to these signals.

YOUR RIGHTS AND CHOICES

Depending on where you live, you may be entitled, in accordance with applicable law, to request access to, correction, deletion, and portability of your information, to object to or request restriction of processing of your information, or more information about our information practices.  To exercise your privacy rights, contact us as set forth below in the “Contact Us” section.  If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected.  Once we receive your request, we may verify it by requesting information sufficient to confirm your identity.  You may be entitled to submit a request through an authorized agent or to appeal a refusal to take action on your request.  To designate an authorized agent to exercise your rights, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

If you disagree with a decision made in response to a request to exercise your rights, you may be entitled, in accordance with applicable law, to appeal the decision. To appeal a decision, please contact us as described in the “Contact Us” section below. 

You may be able to refuse or disable cookies by indicating your preferences on our cookie consent interface and/or adjusting your web browser settings.  Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent.  Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section).  If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data.  Deleting cookies may in some cases cancel the opt out selection in your browser.

Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies.  To learn more, please click here or here.  Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest based advertising for mobile applications.  Please check your device settings and mobile app permissions for additional information on how to opt out.  You also may stop further data collection from a mobile application by removing it from your mobile device.

You also may be able to control our collection and use of your location information through your mobile device or app settings.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you.  Any difference in the Services are related to the value provided.  

You may lodge a complaint with a supervisory authority if you have concerns about our processing of your information.

INTERNATIONAL TRANSFERS

When you use the Services and provide us with information, please note that we may process and store your information on servers located in the United States or other locations outside the jurisdiction where you reside, all in accordance with applicable law.  To the extent required by the laws of the jurisdiction where you reside, you consent to the transfer of your information to the United States for processing by us in accordance with this Privacy Policy.

CHILDREN

We do not knowingly collect, sell, or share for interest-based advertising, any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.

DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws. 

We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current.  Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

CHANGES TO THE PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy.  We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.

CONTACT INFORMATION

If you have any questions about this Privacy Policy or our practices, please contact us via email at store@baklava.nyc, or mail us at 3000 Marcus Ave, Suite 1w5. Lake Success, NY 11042