Consolidated Privacy Notice
Punch Needle World services, including (without limitation) our retail and resource website Punch Need World, our educational website Punch Needle Academy, and other interactive properties through which the services are delivered (collectively, the “Services”) are owned, operated, and distributed by Micah Clasper-Torch LLC d/b/a Punch Needle World (referred to in this Privacy Notice as “Punch Needle World” or “we” and through similar words such as “us,” “our,” etc.). This Privacy Notice outlines the personal information that Punch Needle World may collect, how Punch Needle World uses and safeguards that information, and with whom we may share it. The type of information that Punch Needle World collects and how it uses it may vary depending on which website or feature you are utilizing.
THE SERVICES ARE OFFERED FROM THE UNITED STATES (“US”). For individuals located outside of the US, please note that Punch Needle World is a US based company. If you use the Services, all information, including personal information, will be transferred to Punch Needle World in the US and used as described in this Privacy Notice.
What personal information do we collect about you?
Personal information (also commonly known as personally identifiable information (PII) or personal data) is information that can be used to identify you, or any other individual to whom the information may relate.
The personal information that we collect directly from those registering for the Services, may include the following categories:
- Name and contact information (e.g. address; phone number; email);
- Billing Information (e.g. credit card, bank account, billing contact information);
- Order Information (e.g. current order/purchase information, purchase history, shipping details);
- Account information (e.g. email and account password for PNA)
- Information contained in posts you may on the public forums, reviews or comments you leave on products or blog posts, and/or other interactive features of the Services;
- Links to your personal, professional, or creative websites or platforms as part of your feature on the “Meet the Maker” series;
- Information in the “Cookies, Device Data, and How it is Used” Section below, the degree to which such information is defined as personal information under the laws of a particular jurisdiction;
- Other information that may be exchanged in the course of engaging with the Services. You will be aware of any subsequently collected information because it will come directly from you.
Collection of User Generated Content
We may invite you to post content on the Services, including your comments and any other information that you would like to be available on the Services, which may become public (“User Generated Content”). User Generated Content may include your comments on blogposts or the “Meet the Maker” series, your reviews on free patterns, questions posed in the “Q&A Forum” on a PNA lesson, or testimonials you provide on the Services. If you post User Generated Content, all of the information that you post will be available to authorized personnel of Punch Needle World and may be made available to the public at our discretion. You expressly acknowledge and agree that we may access in real-time, record, and store archives of any User Generated Content on our servers to make use of them in connection with the Services. If you submit a review, recommendation, endorsement, or other User Generated Content through the Services, or through other websites including Facebook, Instagram, Google, Yelp, and other similar channels, we may share that review, recommendation, endorsement, or content publicly on the Services.
What are the sources of personal information collected by Punch Needle World?
When providing personal information to Punch Needle World as described in this Privacy Notice, that personal information is collected directly from you, and you will know the precise personal information being collected by us. Punch Needle World does not collect personal information from any other sources, except where it may automatically be collected as described in the section titled “Cookies, Device Data, and How it is Used,” if the information in that section is considered personal information.
In certain limited circumstances, third-party service providers may collect information on behalf of Punch Needle World, though such collection will always be within the context of the Services. Punch Needle World may also automatically collect certain information as described in the section titled “Cookies, Device Data, and How it is Used,” the degree to which the information in that section is considered personal information. In particular, we may collect personal and non-personal information through the following additional channels:
- Our own cookies on our website;
- 3rd party cookies on our website;
- Social media networks;
- 3rd party software applications.
How does Punch Needle World use personal information?
Subject to the terms of this Privacy Notice, Punch Needle World uses the above-described categories of personal information in several ways. Unless otherwise stated specifically, the above information may be used for any of the following purposes:
- to administer the Services to you
- to improve the Services for you;
- to respond to your requests for assistance or questions regarding the Services;
- to distribute communications relevant to your use of the Services, such as system updates or information about your use of the Services;
- as may be necessary to support the operation of the Services, such as for billing, account maintenance, and record-keeping purposes;
- to send to you Punch Needle World solicitations, product announcements, and the like that we feel may be of interest to you (you may “opt out” of receiving these marketing materials);
- to send you monthly newsletters if you subscribe to them;
- to provide information to you about the Services or products; and
- in other manners after subsequent notice is provided to you and/or your consent is obtained, if necessary.
How does Punch Needle World share your Personal Information with third parties?
We may provide any of the described categories of personal information to Punch Needle World employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to provide the Services to you. In such circumstances, we require that these parties agree to protect the confidentiality of such information consistent with the terms of this Privacy Notice. Third parties receiving personal information may include:
- Third-party vendors or service providers providing crucial services and necessary to provide the Services;
- Business partners, contractors, channel partners, or other affiliated entities;
- Government agencies or other parties in response to legal process or other requests, where permitted by law.
We will not share your personal information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.
How long does Punch Needle World retain your personal information?
Punch Needle World will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Punch Needle World will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Sites and/or Portals, or we are legally obligated to retain this data for longer periods.
Cookies, Device Data, and How it is Used
When you use our Services, we may record unique identifiers associated with your device (such as the device ID and IP address), your activity within the Services, and your network location. Punch Needle World uses aggregated information (such as anonymous user usage information, cookies, IP addresses, browser type, clickstream information, etc.) to improve the quality and design of the Services and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends. Specifically, we may automatically collect the following information about your use of Services through cookies, web beacons, and other technologies:
- domain name
- browser type and operating system
- web pages you view
- links you click
- IP address
- the length of time you visit the Sites, Portals, and/or Services
- the referring URL or the webpage that led you to the Sites
We may also collect information regarding application-level events, such as crashes, and associate that temporarily with your account to provide customer service. In some circumstances, we may combine this information with personal information collected from you (and third-party service providers may do so on behalf of us).
Third Party Ad Networks
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will remove you from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through the Services or on other third party websites. Even if you opt-out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page, you may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt-out on the DAA or NAI websites, your opt-out action may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at https://www.networkadvertising.org/.
International Data Transfer
If you are located outside the United States, in particular if you are located in Canada, Brazil, the European Union (“EU”), the European Economic Area (“EEA”), New Zealand, the Republic of South Africa, Switzerland, the United Kingdom, or other countries with similar data privacy laws, please note that we and our servers are located in the United States. Any information that you provide to us may be transferred to and processed in the United States or other countries around the world where we do business. Although this may include recipients of information located in countries where there may be a lower level of legal protection for your personal information than in your country, we will make efforts to protect your information in accordance with requirements applicable to the law in your particular jurisdiction and take steps to only share with third parties that offer similar protection. By using the Services, you unambiguously consent to your information being collected, processed, used, and transferred as disclosed herein.
Data Privacy Rights (European Union and Similar Jurisdictions)
If you are located in the EU or a jurisdiction with a similar law, the GDPR or its local equivalent may grant you certain rights under the law. In particular, the right to access, correct, and delete the personal information we hold about you. Punch Needle World will retain your personal information for the length of time you engage with our services as described in the retention section of this Privacy Notice, until you request deletion of such personal information. Punch Needle World is considered the Data Controller (or equivalent distinction) with regard to your personal information. You can find our contact information as described herein or in other portions of the Services.
In certain circumstances, you have the following data protection rights:
- The right to access, update, or delete the personal information we have on you.
- The right of rectification. You have the right to have your personal information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your personal information.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the personal information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
In order make a request regarding your personal information, please contact [INSERT].
If you have a comment, question, or complaint about how we are handling your personal information, we hope that you contact us as described in this Privacy Notice in order to allow us to resolve the matter. In addition, if you are located in the EEA, you may submit a complaint regarding the processing of your personal information to a regulatory authority. The following links may assist you in finding the appropriate regulator:
In the UK, you have the right to lodge a complaint with the Information Commissioner:
In South Africa, you have the right to file a complaint with the Information Regulator: https://www.justice.gov.za/inforeg/index.html
In Switzerland, you have the right to contact the Federal Data Protection and Information Commissioner (FDPIC)
In the EU, you have the right to lodge a complaint with your local data protection authority. To find your local authority, you can check the list on the European Data Protection Board website:
In Brazil, you have the right to lodge a complaint with the National Data Protection Authority (ANPD)
(Note: Jan 2021 - not yet established)
In Argentina, you have the right to contact the National Directorate for Personal Data Protection
In Canada, you have the right to lodge a complaint with the Office of the Privacy Commissioner in Canada:
In Japan, you have the right to contact the Personal Information Protection Commission.
In Australia, you have the right to lodge a complaint with the Privacy Commissioner
In New Zealand, you can contact the Privacy Commissioner’s office
Legal Basis for Processing under GDPR
If you are located in the EEA or a jurisdiction that requires a similar legal basis for processing, our legal basis for collecting and using the personal information described in this Notice depends on the personal information we collect and the specific context in which we collect it.
We may process personal information because:
- We need to perform a contract with you;
- You have given us consent to do so;
- The processing is in our legitimate interest to offer the Services, when that legitimate interest is not overridden by your rights;
- To comply with the law.
Where personal information is processed based on consent, you may have the right to withdraw such consent at any time. To do so, please contact us as described in this Privacy Notice. If there is a different legal basis that would permit us to continue processing your personal information after withdrawing consent, we will notify you of that legal basis at the time of your request.
California Privacy Rights
If you are a California resident, California law may provide you with certain rights with regard to your personal information under the California Consumer Privacy Act (“CCPA”). Throughout this Privacy Notice you will find information required by CCPA regarding the categories of personal information collected from you; the purposes for which we use personal information, and the categories of third parties your data may be shared with. This information is current as of the date of the Privacy Notice and is applicable in the 12 months preceding the effective date of the Privacy Notice.
While Punch Needle World is not currently subject to the CCPA, Punch Needle World is committed to supporting individual rights with regard to a person’s personal information as well as fulfilling Punch Needle World’s commitment to any California based partners or businesses.
As a California resident, the CCPA provides you the ability to make inquiries regarding to your personal information. Specifically, the degree to which the information is not already provided in this Privacy Notice, you have the right to request disclosure about the collection and use of your personal information over the past 12 months, including:
- The categories of personal information collected about you.
- The categories of sources for the personal information collected about you.
- The business or commercial purpose for collecting your personal information.
- The categories of third parties with whom your personal information was shared.
- The specific pieces of personal information collected about you.
- If your personal information was disclosed for a business purpose, the personal information categories disclosed and the categories of third parties to which the information was disclosed.
- If your personal information was sold in the past 12 months, the personal information categories sold and the categories of third parties to which the information was sold. Punch Needle World does not sell, re-sell, or distribute for re-sale your personal information.
Please note that you may only make the above requests twice in a 12-month period. You also have the right to request that any of your personal information collected and retained be deleted, subject to certain exceptions. Finally, you have the right to not receive discriminatory treatment by Punch Needle World or any business for exercising any of the rights provided under CCPA.
You may submit a request regarding your rights under CCPA by submitting a request through the following form [INSERT LINK] or by contacting us at one of the following: [INSERT A SECONDARY METHOD OF CONTACT].
If we receive a CCPA request from you, we will first make a determination regarding the applicability of the law, and we will then take steps to verify your identity prior to responding. The steps to verify your identity may vary based on our relationship with you, but, at a minimum, it will take the form of confirming and matching the information submitted in the request with information already held by Punch Needle World and/or contacting you through previously used channels to confirm that you submitted the request (i.e. confirming identity through contact information that we have on file, not the contact information submitted to make the request).
Your rights as stated here can also be exercised by an authorized agent on your behalf. Punch Needle World will follow the standards set by the Attorney General of California regarding designation of an authorized agent to exercise rights under CCPA. You may review information available through from the Attorney General regarding how an individual can be designated as an authorized agent under CCPA.
In addition to CCPA, California Civil Code Section 1798.83 permits users of the Website who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as described here.
Third Party Advertisers
Information Security and User Responsibility
We employ industry-standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.
Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Services. In order to protect you and your information, we may suspend your use of the Services, in whole or in part, without notice and pending an investigation, if any breach of security is suspected.
The Services may contain links to other websites maintained by third parties. Examples of external links on our Services may include, but are not limited to, links to social media platforms, video sharing platforms, website links to a curated list of suppliers in various countries, or websites linked in a “Meet the Maker” feature. Please be aware that we exercise no control over linked sites and Punch Needle World is not responsible for the privacy practices or the content of such sites. Each linked site maintains its own independent privacy and data collection policies and procedures, and you are encouraged to view the privacy policies of these other sites before providing any personal information.
You hereby acknowledge and agree that Punch Needle World is not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release Punch Needle World from any and all claims arising out of or related to the privacy practices, data collection policies and procedures, and/or the content of such third-party sites.
The Services are not intended for children under the age of 13, and Punch Needle World does not knowingly collect the personal information of children under the age of 13.
Changes to this Privacy Notice
Punch Needle World reserves the right to modify this Privacy Notice from time to time in order to ensure that it accurately reflects the regulatory environment and our data collection principles. When material changes are made to this Privacy Notice, Punch Needle World will post the revised Notice on our website. Changes are effective upon posting. This Privacy Notice was last modified as of March 4, 2022.
If you have any questions or comments about this Privacy Notice or the Services provided by Punch Needle World, please contact us at: email@example.com