Last Updated: August 31, 2020
We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.
TO LEARN MORE ABOUT OUR COLLECTION, USE AND DISCLOSURE PRACTICES OF THE PERSONAL INFORMATION OF CHILDREN UNDER 13 YEARS OLD, AND HOW WE ADDRESS THE REQUIREMENTS OF THE CHILDREN'S ONLINE PRIVACY PROTECTION ACT AND ITS RULES ("COPPA"), PLEASE SEE THE SECTION BELOW TITLED "CHILDREN'S ONLINE PRIVACY (COPPA)."
IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE BELOW FOR ADDITIONAL PROVISIONS THAT MAY APPLY TO YOU IN THE SECTION TITLED “CALIFORNIA RESIDENTS”.
If you use this Site, you must comply with our Term of Use (“Terms”) found here
Categories of Personal Information We Collect
We may collect the following categories of Personal Information, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Identifiers: Identifiers such as: a real name, account user name, postal address, online identifier, internet protocol address (“IP Address”), email address, videos, or other similar identifiers. We may also collect parent names as required for obtaining parental consent under COPPA.
- Customer Records: Information relating to orders, shipping and payment such as credit card number, debit card number, signature, and cardholder information such as address and telephone number.
- Commercial Information: Information about orders, purchases, ordering history, shipping history, and purchasing histories and tendencies.
- Internet Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet site, application, or advertisement.
- Geolocation Data: Approximate geolocation data via IP Addresses.
- Inferences: Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Sources
We may collect all categories of Personal Information listed above from the following categories of sources:
We Collect Personal Information Directly From You and/or Your Household.
We collect Personal Information that you provide directly to us. Personal Information is required to use certain Site features, for example, to create online accounts, purchase products or services, contact us via email, phone, or our Contact Us form (where we may retain your message’s content and our response), receive or request data from us (e.g., catalogs and newsletters), and respond to communications from us (e.g., surveys and promotional offers).
- Order & Payment Data. To make purchases through the Site, you must submit your name, credit or debit card type, number, expiration date, security code, billing address, and shipping address. All credit and debit card data is provided directly to our PCI-compliant third-party payment processors.
We do not directly access, handle, or store your credit or debit card data. We will keep a record of your purchases. We store your payment card’s last four digits to facilitate future orders. We collect tax identification numbers you submit for tax-exempt purposes.
- Account Setup. If you wish to create an account with us, you will need to submit your name, email address, and your user account name. You will also need to set up your password to access your account. You may also link your account to sign in with Facebook, which requires sharing certain data from Facebook as set forth below in “Social Media”.
- Marketing Communications; Opt-Out.If you opt-in to receive marketing communications from us, you must submit your email address. We use this data to send you promotional and other electronic communications. We may use third-party providers to deliver communications to you. You may opt-out of such emails by using the unsubscribe link in the email or contacting us at DuncanAdministrator@flambeau.com with “Unsubscribe” in the subject line. Opting out of marketing communications does not opt you out of communications about your account or transactions.
- Program Information. If you request information on one of our programs, you must submit your email address, name and zip code along with an identification of the program in which you are interested. We may also collect your troop number. We use this information to send you information on the program that you request and will add you to our marketing communications database to receive marketing communications from us. You may opt-out of such marketing communications as set forth above.
- Feedback. When you provide comments or feedback about our Site, the content on the Site, or our products or services (“Feedback”), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
We Collect Personal Information Automatically
- Automated Data. We automatically collect certain information from you when you access our Site. For examples, we may collect information such as the sites you visit before or after you visit the Site, pages you click-on on the Site, IP Address, search requests, browser type, operating system, date and time you visit the Site, the amount of time spent on the Site, and the device you use to access the Site.
- Account Activity. We may collect data about how you use (i) your online account, and (ii) the Site when you are logged into your account. We may combine data automatically collected from you with other Personal Information about you.
- What are cookies and web beacons / pixel tags? A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
- make our Site function properly;
- provide personalized experiences;
- tailor our interactions with you;
- help with our marketing efforts;
- provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and
- help us improve our services.
- What type of information do Cookies collect?The Cookies on our Site may collect information such as:
- IP Addresses assigned to the computers and other devices you use;
- your internet service provider;
- device ID number;
- approximate geographic location;
- browser type;
- Site pages visited;
- sites you access before and after visiting the Site, and
- data related to how and when you use the Site.
- We may combine information from Cookies with your Personal Information.
- How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Our persistent Cookies exist for a set period of time, typically 3-6 months. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
- We are not responsible for third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party site, such as a third party social media site, the source of an ad that appears on the site you are visiting or a third-party analytics provider. We do not have control over third-party Cookies. Third-party Cookies are not governed by this Policy.
- How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.
- BECAUSE OF THIS AUTOMATIC COOKIE COLLECTION, WE CURRENTLY DO NOT RESPOND TO “DO NOT TRACK” REQUESTS.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.
Purpose for Collecting Personal Information
We may use all categories of Personal Information listed above for the following business purposes:
- As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested by or consented to by you.
- Administration. We use Personal Information for administrative purposes, such as managing your accounts, facilitating transactions, informing our business strategies, understanding the Site’s demographics and user preferences, evaluating submissions, and managing profiles.
- Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.
- Advertising and Notifications. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Site, to notify you of changes to our Terms or this Policy, and for other similar communications.
- To Protect Our Rights.We may use Personal Information to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.
Categories of Third Parties with Whom We Share Personal Information
We may share all categories of Personal Information listed above with the following categories of third parties:
- Employees and Affiliates. We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.
- Third-Party Service Providers. We may share Personal Information with our third-party service providers, suppliers, consultants, agents, partners and representatives that provide services for us. For example, we may share Personal Information with service providers to help us host and manage the Site; provide targeted advertising and other marketing; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; provide payment processing services and online storefronts; provide shipping; provide public relations; provide learning management systems; provide email services; provide data processing; and support or provide the security of the Site.
- Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Duncan or any other party.
- Professional Advisors. We may share Personal Information with certain service providers that are our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Duncan.
- Business Transactions. In the event Duncan or its affiliates are the subject of a change of control, merger, acquisition, sale, or corporate reorganization, in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).
- Other. We may share Personal Information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
- Sales. We do not sell, rent, or loan any of your Personal Information for monetary payments. Regardless, you may notify us at DuncanAdministrator@flambeau.com to opt-out of any such monetary transactions in the future.
Our Site is available to users of all ages. To learn how we handle Children's Personal Information, please see the section below titled "Children's Online Privacy (COPPA)."
Use and Disclosure of De-Identified or Aggregated Information
Duncan may collect, use, share, transfer and otherwise process anonymized and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Duncan is the sole and exclusive owner of such anonymized and aggregated information, including if Duncan anonymizes Personal Information so that it no longer considered Personal Information under applicable laws.
We are active on social media, including Facebook, YouTube, Twitter, LinkedIn and Pinterest (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages. YOU AGREE TO HOLD COMPANY AND ITS AFFILIATES HARMLESS AND WITHOUT LIABILITY FOR THE RESULTS OF ANY AND ALL CONTENT YOU POST ON COMPANY’S SOCIAL MEDIA.
Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those sites and not by this Policy. We encourage you to review those policies and terms.
Children's Online Privacy (COPPA)
This section only applies to children under the age of 13 years old ("child" or "children") and supplements the remainder of our Policy. This section explains our practices regarding the collection, use and disclosure of the Personal Information of children. With regard to this section only, "Personal Information" and "parent" have the definitions set forth in the Children's Online Privacy Protection Act ("COPPA"). To learn more about COPPA, please click here.
Certain services on our Site are only available to registered users with a Company account. Prior to accessing these features of our Site, we ask Site visitors to provide their age. For any child indicating that they are under 13 years old, we will send an email notice to the parent’s email address as provided by the child, and have the parent respond to the communication to provide consent, prior to any further collection, use or disclosure of that child's Personal Information. We will send a confirmation to the parent via email. The parent can revoke their consent anytime by contacting DuncanAdministrator@flambeau.com.
There are certain exceptions permitted under applicable law permitting us to communicate with a child or collect Personal Information without prior parental consent (e.g., to respond to a one-time request received from a child).
Children’s Personal Information We Collect and How We Use It
The type of Personal Information we collect, and how we use that information, is the same for all users of the Site (including children). If we receive verifiable parental consent from the parent of a child, we will collect and use that child's Personal Information consistent with, and as described throughout, the rest of this Policy. For example, some information we request and collect directly from the user (e.g., when a user registers for an account), and some information is automatically collected from users through use of technologies like Cookies. See the sections above titled "Categories of Personal Information We Collect” and "Purpose for Collecting Personal Information” to learn more.
In addition, we will collect from children the name and email address of the child's parent in order to provide the parental notice and seek the consent as set forth above. We only use the parent's Personal Information for the purpose of providing this notice and seeking consent.
We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more Personal Information than is reasonably necessary.
Disclosing Children's Personal Information
If we receive parental consent from the parent of a child under 13 years old as set forth above, we will disclose that child's Personal Information consistent with, and as described throughout, the rest of this Policy. See the section entitled "Categories of Third Parties with Whom We Share Personal Information" to learn more.
A parent has the option of consenting to our collection and use of your child's Personal Information without consenting to the disclosure of the child's Personal Information to third parties beyond our service providers that help us make the website and online services available, subject to any exceptions permitted by applicable law.
A child's parent may review the Personal Information we collect and maintain about their child (and ask for corrections), including a description of the specific types of Personal Information collected. At any time, a child's parent may refuse to permit further use or future online collection of Personal Information from their child and they may direct us to delete their child's Personal Information. A parent may exercise these rights by contacting Duncan at DuncanAdministrator@flambeau.com. We may require any individual making such a request to verify his or her identity and parental or guardianship status prior to responding to requests made by parents pursuant to this section.
If a parent either (a) declines to provide consent, (b) requests that we stop collecting and/or using their child's Personal Information, or (c) requests that we delete their child's Personal Information, then we will terminate that child's account and access to those services on our Site that require an account. Keep in mind that we cannot stop any individual, adult or child, from accessing our public facing website.
Further, if we do not hear back from a parent who we contacted to request verifiable parental consent within a reasonable timeframe, we treat that parent’s response as declining to provide consent. If the parent declines consent, we will delete that parent's contact information from our records and the child will not be permitted to create an account or use those services on our Site that require an account.
The following operators may collect or maintain Personal Information from children through the Site:
Please direct all inquiries about any operator’s privacy practices to the operator of this website, which is:
Attn: Duncan Website Administrator
801 Lynn Avenue
Baraboo, WI 53913 USA
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.
Access from Outside the United States
If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.
This section applies to residents of California. In the event of a conflict between this section and the remainder of this Policy, this section shall take precedence to the extent of the conflict for California residents. In this section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).
The Collection, Source, Purpose and Sharing of Your Personal Information
- Categories of Personal Information. We collect the categories of Personal Information described in Section 1.
- Categories of Sources From Which Personal Information is Collected. The categories of sources from which your Personal Information is collected is described in Section 2.
- Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in Section 3.
- Categories of Third Parties / Services Providers With Whom Personal Information is Shared. The categories of third parties and / or service providers with whom we share your Personal Information are described in Section 4.
We Do Not Sell Personal Information
In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information. "Sale" / "Sold" / "Sell" has the definition set forth in the CCPA. We do not have knowledge that we sell Personal Information of any individual under the age of 16.
Categories of Personal Information Disclosed for a Business Purpose
Every category of Personal Information collected in the last 12 months has been disclosed to one or more of our services providers for our Business Purposes, where “Business Purposes” has the definition set forth in the CCPA. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category and section above titled “Categories of Third Parties / Service Providers with Whom Personal Information is Shared” for more detail on the categories of third parties to whom we share for Business Purposes.
Your Rights to Access and Deletion
California residents have a right to make certain requests with regard to their Personal Information. These rights are subject to exceptions permitted by applicable law and verification of your identity and authentication of the request.
- Right to Request Additional Disclosures. You have the right to request disclosures of any of the following: (a) the categories of Personal Information we collected from you in the prior 12-month period, (b) the categories of sources from which such Personal Information was collected, (c) the Business Purpose or Commercial Purpose for collecting such Personal Information, (d) the categories of such Personal Information we disclosed for a Business Purpose during the applicable 12-month period, and (e) for each such category of Personal Information we disclosed, the categories of third parties to whom we disclosed such Personal Information.
- Right to Request Access. You have the right to request access to the specific pieces of Personal Information we collected from you in the prior 12-month period and disclosure of that Personal Information to you (i.e. data portability).
- Right to Request Deletion. You have a right to request that we delete Personal Information we collected from you.
- Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. We will not discriminate against your for your exercise of any of the above rights.
How to Exercise Your Rights of Access and Deletion
To exercise your California rights described in this Policy, you may submit your request to us by contacting us at any of the following:
801 Lynn Avenue
Baraboo, WI 53913
Attn: Website Administrator/Legal Counsel
Authentication and Verification of Requests.
In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.
When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including additional Personal Information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc. Certain types of request, such as a request for access, will require additional verification to ensure you are who you say you are, as we are subject to higher standards of authentication with respect to such requests. These additional verifications may require a signed declaration under penalty of perjury that you are the data subject.
If we have to request additional Personal Information from you in order to verify your identity, we only use that additional Personal Information for such purposes.
If you maintain an account with us, we may use that account to respond to your request and/or verify your identity.
If we are unable to verify identity as required by applicable laws and regulations, we are prohibited by law from complying with your request and will respond to you accordingly.
When and How We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you.
Fees. We generally do not charge fees to process or respond to requests, but reserve the right to do so if your request is excessive, repetitive, or manifestly unfounded.
Who May Exercise Your Rights?
You may only make a request to exercise your rights on behalf of yourself or the child for whom you are the parent or guardian. We may request additional information to verify your parental or guardianship status.
You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. Any legal entity acting as your agent must be registered with the Secretary of State in California to conduct business in California. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity as set forth above, which may include the requirement of a signed declaration under penalty of perjury that you are the data subject or the authorized agent, respectively. We will also require you to confirm to us directly that you provided the agent permission to submit the request and provide us a copy of your signed authorization to the agent, unless the agent holds a lawful Power of Attorney under California probate laws in which case we will require evidence of such Power of Attorney.
We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
Shine the Light
Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below.
If you have any questions you may contact us as set forth below:
Attn: Duncan Website Administrator
801 Lynn Avenue
Baraboo, WI 53913 USA