Ethan Allen Global, Inc., its parent, and its subsidiaries (collectively, “Ethan Allen”) understand and respect your concerns about privacy, and we are committed to providing you with a rewarding and safe experience without regard to the manner in which you conduct business with us. This policy describes the types of information we may collect from you or that you may provide, how we use such information, and your choices regarding our use of such information.
Information We Collect
Ethan Allen collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, Ethan Allen has collected all or some portions of the personal information categories below from its consumers within the last twelve (12) months as relevant for its business purposes, including manufacturing, selling, marketing, and delivering its products and services as follows:
|A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, Social Insurance number, driver's license number, passport number, or other similar identifiers||YES|
|B. Personal information categories contained in customer records||A name, signature, Social Security number, Social Insurance 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, or information on a consumer's interaction with a website, application, or advertisement||YES|
|G. Geolocation data||Physical location or movements||YES|
|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
[Employment applicants only]
[Please see “Employment Applicants” section]
|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
- publicly available information from government records;
- deidentified or aggregated consumer information;
- information excluded from the policy'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; and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Ethan Allen obtains the categories of personal information listed above from the following categories of sources:
- Directly from you, when you provide it to us when you make a purchase in one of our stores, visit or make a purchase on our website ethanallen.com or ethanallen.ca (our "Website"), use our mobile app, create an account, join our Gift Registry, participate in a sweepstakes or contest or any other promotion, engage with us on our various social media platforms, apply for financing, participate in our surveys, send us any feedback, questions, comments, or interact with us in any way.
- Automatically as you navigate through our Website or use our mobile app(s). Such automatic data collection technologies include but are not limited to the following:
- Web beacons. Pages of our the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- From third parties; for example, our business partners. We also allow third-party companies to serve ads and/or collect certain anonymous information when you visit our Website or use our mobile app(s). These companies may collect non-personally identifiable information (e.g., subject of advertisements clicked or scrolled over, browser type, etc.) via a cookie or third-party web beacon. You may opt out by clicking in the appropriate place on the ad or by visiting the Network Advertising Initiative opt-out page, which can be found here: networkadvertising.org/choices.
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following business 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 send you promotional communications, including but not limited to catalogs, direct mail, telephone calls, email, and SMS messages.
- To send you surveys including, but not limited to email and SMS messages.
- 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.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ethan Allen's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ethan Allen about our customers is among the assets transferred.
Ethan Allen 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
Ethan Allen may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). 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. Our policies also prohibit third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt out of further sales.
We share your personal information with the following categories of third parties:
- Service providers, such as delivery companies and warranty providers
- Data aggregators
- Authorized Ethan Allen™ Independent Retailers
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:
- Category A – Identifiers
- Category B – Customer records personal information categories
- Category D – Commercial information
- Category F – Internet or other similar network activity
- Category I – Professional or employment-related information (employment applicants only)
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers, such as delivery companies and warranty providers
- Authorized Ethan Allen™ Independent Retailers
Sales of Personal Information
In the preceding twelve (12) months, the Company has not sold any personal information, and we do not plan to do so in the future. If those plans change, this policy will be updated accordingly.
Your Rights and Choices
We strive to provide you with choices regarding the personal information you provide to us. This section describes your rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Ethan Allen 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
- 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); and
- 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 Ethan Allen 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 do any of the following:
- 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.
- 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.
- For residents of California only, comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information. If you are a California resident and want a copy of this notice, please submit a written request to the following address: Ethan Allen Client Services, P.O. Box 1966, 25 Lake Avenue Extension, Danbury, CT 06811. In your request, please specify that you want a "Your Ethan Allen California Privacy Rights Notice." Please allow 30 days for a response. If you are a minor under 18 and have a profile on ethanallen.com, you may ask us to remove reviews or other content that you posted on the site by writing to firstname.lastname@example.org. We will begin to process your request within 30 days. Please note that processing your request does not ensure complete or comprehensive removal of content that you posted.
- 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.
- Call us at 888-324-3571, if in the U.S.; at 877-386-9741, if in Canada.
- Email us at email@example.com or CanadaCS@ethanallen.com.
Only you, or, for California residents only, 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.
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 either the person about whom we collected personal information or that person’s authorized representative; and
- 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, if you maintain an account, we may contact you to verify your request. If you do not maintain an account with us, you may be required to bring a government-issued ID to one of our locations in order to verify your request.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 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, according to your preference.
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 usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically PDF format or paper copy.
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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt out"). 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 between 13 and 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.
To exercise the right to opt out, you (or your authorized representative) may submit a request to us by calling 888-324-3571 or emailing firstname.lastname@example.org (877-386-9741 or CanadaCS@ethanallen.com if in Canada).
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by calling 888-324-3571 or emailing email@example.com (877-386-9741 or CanadaCS@ethanallen.com if in Canada).
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
There are other mechanisms in place to provide you with control over your information:
- Promotional Offers from the Company. If you do not wish to have your contact information used by Ethan Allen to promote our own or third parties' products or services, you can opt out by clicking on the “Mailing List Preferences” in the Client Services section at the bottom of any page on ethanallen.com or ethanallen.ca, or you may contact Client Services by phone: in the U.S. by calling 888-324-3571; in Canada by calling 877-386-9741. If you no longer wish to receive our digital communications, please call Customer Service at the above number (if in the U.S.), click on “Email Preferences” in the Client Services section at the bottom of any page on ethanallen.com. or click the "Unsubscribe" link at the bottom of any of our emails or SMS messages.
Our Website includes a Careers feature that allows you to submit an online job application. When you submit an online application, you will be required to provide personal information, including but not limited to your name, contact information, job interests, educational and job history, and references. This information will be used by us to assess and process your application.
You will also be asked to provide equal opportunities information. Disclosure of this information is not mandatory, and if you don’t provide it, it will not affect your application. Ethan Allen will not make the information available to any staff outside of its recruitment team, including hiring managers, in a way that can identify you. Any information you provide will be used to produce and monitor equal opportunities statistics.
The online application process is hosted and supported by a third-party service provider, CareerBuilder. The CareerBuilder Applicant Tracking System receives and stores the information you provide. CareerBuilder does not disclose the personal information it receives and maintains for us to anyone else.
If we decide to interview you, we may print your application and use it during the interview process. If you are hired, your application becomes part of your employee file. If you are not immediately hired, your printed application is kept for one year and then typically will be destroyed. We may ask you to provide additional information during the interview or hiring process. We may also use the information you provide to contact you about your application; for example, to ask you to agree to a background check or to send you an offer letter.
We do not share the information you provide in the online application with anyone outside of Ethan Allen, except as we believe is required by law, with one exception: our applicant tracking system shares Equal Opportunity Employer information with HR Works, a third-party vendor that assists with analysis for our affirmative action plans. All data shared with HR Works is stripped of personally identifiable information.
Additional Rights for California Residents
We will not discriminate against you for exercising any rights granted to you under the California Consumer Privacy Act of 2018 (“CCPA”). 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; or
- 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
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 firstname.lastname@example.org or write us at: P.O. Box 1966, 25 Lake Avenue Extension, Danbury, CT 06811, Attn: Client Services.
Additional Rights for EU Residents
If EU data protection laws apply to our processing of your information, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below.
You can access, amend or update your information by contacting us at 888-324-3571 or email@example.com (877-386-9741 or CanadaCS@ethanallen.com if in Canada). If you email us, please include your full name (previous and current, if applicable), mailing address, email address, and phone number. Your request should contain a detailed, accurate description of the data you want to access. For your protection, we may need to verify your identity before responding to your request.
In the event that we refuse a request under rights of access, we will provide the individual with a reason why.
A list of your rights is below:
- Right of access – the right to request a copy of the information that we hold about the individual
- Right of rectification – the right to correct data that we hold about you that is inaccurate or incomplete
- Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records
- Right to restriction of processing – where certain conditions apply, to have a right to restrict the processing of your data
- Right of portability – the right to have the data we hold about you transferred to another organization
- Right to object – the right to object to certain types of processing such as direct marketing (we do not engage in direct marketing to individuals that we know reside in the EU)
- Right to object to automated processing, including profiling – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect (we do not currently engage in any automated processing or profiling of individuals that we know reside in the EU)
We have implemented physical, electronic, and procedural measures designed to protect the confidentiality and security of your information. Our Website’s secure server uses Secure Sockets Layer (SSL) protocol to encrypt your personal information before its transmission to us.
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Changes to Our Privacy Notice
Phone: 888-324-3571 (in the U.S.); 877-386-9741 (in Canada)
Website: ethanallen.com; ethanallen.ca
Email: firstname.lastname@example.org; CanadaCS@ethanallen.com
P.O. Box 1966
25 Lake Avenue Extension
Danbury, CT 06811
Attn: Client Services