We will collect information from you and about you, in order to provide you with the products and services you request, to better understand the ways our customers use our website and respond to marketing offers, and to more effectively market our products. The information we collect includes “Personal Information” as that term is defined under applicable laws, and includes information that identifies you as a specific, identified individual, such as your name and address. For example, we may collect:

• Contact information such as your name, shipping address, telephone number, or email address.
• You billing address and payment method.
• Communication preferences
• Feedback, survey response and comments you submit to us.
• Transaction history, order details and shopping preferences.
• Voice recordings and information that you share when you call our customer service line.
• Browsing and device information such as IP address, device identifiers, cookies, browsing activities, location data or other information collected automatically when you visit or use the sites.

For a more detailed description of the Personal Information, we collect on this website, the purposes for which it is collected, and whether that information may be shared or sold, please see the detailed Notice at Collection below.

We collect information

1) directly from you when you provide it to us.
2) automatically when you visit our website.
3) from third parties, all as described more fully below.

You may provide your Personal Information directly to us when you:

• Make a purchase (including online through the website, via email, or by phone).
• Register for an account or sign up to receive emails.
• Respond to surveys, submit product reviews, enter contests or sweepstakes or giveaways, or register for an participate in loyalty programs.
• Contact customer service (including directly through the website, via email, by phone, or by mail).

Every time you use our website, we collect the data that your browser automatically transmits. These are, in particular:

• IP address of the requesting terminal.
• Date and time of the request.
• Address of the web page called up and the requesting web page.
• Information about the browser used and the terminal's operating system (e.g., Windows 10, Linux, iOS).

The data processing is necessary to enable the website visit and to guarantee our systems’ functionality and security. This data will also be temporarily stored in internal log files for the purposes described above in order to produce statistical data on the use of our website, to further develop our website with regard to our visitors’ usage habits (e.g., if the proportion of mobile devices by which the pages are accessed increases), and to generally maintain our website administratively.

Analytics tools and aggregate data. The website uses analytics tools such as Google Analytics, web analytics services provided by Google, Inc. Google Analytics uses cookies to help the website analyze the extent of your use. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google in aggregate form. Google may use this aggregated information in order to evaluate use of the website, compile reports on the website’s activity and other services relating to website activity and usage. You can learn more about how Google Analytics and how to opt out here: https://tools.google.com/dlpage/gaoptout.

Session Replay. Our website also makes use of session replay analytics tools to help us reconstruct the user experience on the site. These tools collect data on our behalf. We use them to troubleshoot issues with and improve user experience on our site. The tools provide insight into what works and what doesn’t work for users of the site, and it allows us to, for example, identify and repair technical errors such as broken links that impair the site’s functionality. We may also use the tools to authenticate users, enable site features, prevent fraud, and implement security measures. The tools use cookies and similar technologies to collect and analyze information related to user behavior on our site, such as mouse movements, clicks, user inputs, scrolling, access times, visit duration, pages viewed, IP address (including location), operating system, page reloading, crash data, performance data, and other diagnostic data. The tools also collect name, email address, phone number, and physical address.

Information on the use of cookies and comparable technologies. In order to be able to implement certain technically necessary functions of our website, to be able to trace the use of our offers, and to be able to provide content adapted to your wishes for the constant optimization of the website, Starfire Direct uses cookies and comparable technologies. Cookies are small text files that are stored on your hard disk by a website. In addition to cookies, so-called tracking pixels or comparable common technologies can also be used, which serve to (temporarily) store information on specific users or usage processes.

You can manage cookies on our website by clicking the Cookie Preferences below. You can also prevent the storage of cookies on your computer at any time by changing the settings of your browser, however, some features of the website may be limited if you do so.

We use cookies for various purposes, as described below:

Strictly necessary cookies

The main purpose of these cookies is to enable you to use the functions of the website or to control the display of information. These cookies are required for the functioning of the website, including the processing of purchase transactions. 

Functional Cookies

These cookies enable the website to provide enhanced
functionality and personalization. They may be set by us or by third party providers whose services we utilize. These cookies allow us to measure visits to our website and traffic sources and improve the performance of our website, including by allowing us to identify which pages of our website are visited during a particular session, and to understand the paths taken by visitors to our website.

Advertising Cookies

These cookies are set by third parties and are used to target, serve and measure advertisements and marketing efforts on our behalf, including targeted advertising based on your browsing activity. You can read more about these cookies, and your choices regarding interest-based advertising, below.

Marketing and Interest-Based Advertising. Like many retailers, we contract with third-party vendors to serve or send advertisements on our behalf. We partner with these vendors that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you. Our advertising partners may place or recognize a cookie on your computer, device or directly in our emails/communications, and we may share Personal Information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners may link the information we share with them to the cookie stored on your browser or device and collect information such as your IP address, browser or operating system type and version, and demographic or shopping information. Our partners use this information to recognize you across different channels and platforms over time to assist us with our operations including for advertising, analytics, attribution, and reporting purposes.

The data sharing that occurs via advertising cookies may constitute a sale or sharing of your Personal Information under state privacy laws. You may opt-out of this type of automated sale or sharing of Personal Information by clicking here to manage your cookie preferences. If you de-activate advertising cookies, the advertisements you see will be less tailored to you and your interests, but you will still see advertisements. Please note that if you later delete your cookies, or if you access our website through a different device, you may need to set your opt-out preference again. Turning off advertising cookies also will not opt you out of receiving our marketing materials, and it will not opt you out of other types of sales or sharing of your Personal Information that may occur in other ways. In order to opt out of other sales or sharing of your Personal
Information, please click here.

Many of our advertising partners are members of the Network Advertising Initiative (NAI), or the Digital Advertising Alliance (DAA), and have agreed to honor consumers’ opt-out preferences submitted through the websites of those organizations. To learn more about your choices regarding this type of data collection or to opt-out of interest-based advertising by members of the NAI or the DAA, please visit http://optout.networkadvertising.org or http://www.aboutads.info.

You can also manage the use of cookies on this website, and can opt-out of marketing cookies on this website, by accessing the Cookie Settings and saving your preferences. Please note that if you clear cookies on your browser, your preferences in Cookie Settings will also be
erased.  

We augment our customer data, including personal data, with information that we receive from companies selected to assist us in acquiring new customers. These companies may include data brokers and social media platforms. In some cases, we also receive addresses from these companies in order to address new customers who match our customer profile.

We may send you advertising or promotional messages via email. You may opt out of commercial emails at any time by clicking on the “unsubscribe” link included at the bottom of every commercial email we send. If you opt out of commercial emails, we may still send you transactional emails such as order confirmation or delivery updates.

Advertising partners. We receive information from selected operators of online advertising networks such as Google or Facebook and data providers who carry out advertising for or together with us (subsequently referred to as "advertising partners"). The information we receive from advertising partners includes information and statistics about demographics (such as age, gender, region, etc.), device and access data, and our users’ interests. This information can help us better understand our users, for example in the context of customer structure analyses and user segmentation.

We may use your Personal Information to accomplish our business purposes including to:

• Complete your transaction, process and ship your order, or respond to your questions or requests.
• Personalize your experience, store your preferences, and provide your products and services.
• Analyze the use of our website and make improvements.
• Communicate with you.
• Respond to reviews, comments, or other feedback you provide or questions you submit.
• Manage and customer promotional offers and advertisements we think may be of interest to you.
• Analyze the effectiveness of our advertising efforts.
• Detect and prevent fraud and protect the security and integrity of our website and systems.
• Protect our legal rights for the health or safety of our customers, employees or others.
• Comply with our legal obligations or to respond to law enforcement or legal and regulatory inquiries or requests or legal proceedings.

We share information with our service providers as necessary for them to fulfill their functions. In addition to the service providers mentioned by name in this privacy policy, this may include in particular data centers that store our website and databases, IT service providers who maintain our system, consulting companies, suppliers, transporters, postal service providers. If we share data with service providers, they may only use the data for the fulfilment of their tasks. We have carefully selected and commissioned the service providers. They are contractually bound by our instructions, have appropriate technical and organizational safeguards in place to protect the rights of the persons concerned, and are regularly monitored by us. We may share information with our family of companies, including our parent company, subsidiaries, and affiliates for business operations and to send you information about products or services we think may be of interest to you.

We may also share your name, postal address and purchase data with third parties or cooperative databases, as described above. If you would like to opt out of this type of sharing, you can do so by clicking on cookie preferences link, by calling us at (866) 578-8538, or by emailing us at privacy@starfiredirect.com.

In addition, we may share data in connection with official inquiries, subpoenas, court orders and other legal proceedings if this is necessary for legal prosecution or enforcement. We reserve the right to share data where necessary to protect our legal rights.

We may also transfer data to a purchaser or successor entity in the event of a merger, or a sale of all or substantially all of our assets.

Third-party marketing purposes.

We may share data such as last name, first name, address, and purchase data for our own and third-party marketing purposes with retailers, mail-order companies with an interesting product range and cooperative databases.

If you would like more information, please call us at (866) 578-8538 or email us at privacy@starfiredirect.com. If you would like to opt out of our sharing data with third party marketing partners as described above, you may also click on our cookie preferences link.

Children’s Privacy.

Our website is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information on the Website. We do not knowingly collect Personal Information from children under 16. If you are under 16, please do not use or provide any information on this Website. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information.

You can choose not to provide us with Personal Information we request, but in some cases, we will not be able to provide our products or services or respond to your requests without certain information. Your rights and choices about the collection and use of your Personal Information include:

• Update your information. You can view, update and correct your Personal Information by logging into your account or by contacting us. It may take up to 10 business days for requested changes to take effect.
• Communication preferences. You may request to be removed from our marketing emails or our catalog mailing lists by contacting us. You can also opt out of marketing emails by clicking on the "unsubscribe" link at the bottom of each of our commercial emails.

Residents of certain states, including California, Connecticut, Colorado, Utah and Virginia have certain rights under state law. The below section describes these data rights and how residents of these states can exercise them. For residents of other states who may wish to exercise a data request, we will respond as time permits, but reserve the right to prioritize requests from consumers located in states that have enacted these consumer privacy laws.

The Personal Information we collect about you will depend upon how you use our website or otherwise interact with us. The below chart describes the categories of Personal Information, as defined under California law, that we may collect about you when you visit our website or interact with us, the business purpose for which the data is collected, how the information may be shared or sold. The below chart also describes the manner in which Personal Information was collected and used in the past 12 months.

How are we defining third-party in this context? Thinking about related companies under a platform (common owner) or across platforms within the BFC portfolio.