Privacy Policy

Last Updated: July 24, 2023

Caraway Home, Inc. and its affiliates (“Caraway,” “we,” “us,” or “our”) respect your privacy. This Privacy Policy describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, applications, social media pages, or other platforms that link to this Privacy Policy (collectively, the “Site”). It also describes your choices about the collection, sharing, and use of your Personal Information.

1. Personal Information We Collect We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The types of Personal Information we collect may include:

• Contact Information – If you submit an inquiry, register for an account, or provide information on our Site, we may collect your contact information. This may include your name, email address, mailing address, demographic information, and phone number.
• Financial Information – If you make any purchases through our Site, we will collect your financial information, including your name and payment information. We may use a third- party service, such as Shop Pay, Amazon Pay, Google Pay, Apple Pay, AfterPay, PayPal, or a social media platform, to collect this information.
• Location Data – While navigating our Site your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.
• Usage Information – When you use our Site, our servers may automatically record information, including your Internet Protocol address (IP Address), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information.
• Employment Information – If you apply for employment, we will collect your employment and work history, as well as other Personal Information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
• Communication Information – We may collect audio, electronic, or visual information; any data in any files uploaded, emailed or otherwise provided by customers; the contents of your communications with us, whether via e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect.

2. How We Collect Your Personal Information

• We May Collect Your Personal Information Directly From You – For example, if you register for an account on the Site, or request or purchase products, services, or information from us.
• We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.
• Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Site. We and our third party service providers process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in. We utilize the following types of cookies: Strictly Necessary Cookies These cookies are fundamental to the functionality of the Site. These cookies are essential. Performance Cookies This type of cookie collects information on how people use the Site, and the data is merged with other users to enable us to improve how the site operates. For example, Google Analytics cookies help us understand how customers arrive at the Site, browse or use the Site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. Functionality Cookies These cookies may remember the operations such as your preference so that we can provide you with better services and improve our operation models. Targeting Cookies or Advertising Cookies These cookies collect information about your browsing habits in order to make advertising more personalized to you. These cookies may remember the websites you have visited and share them with third parties, such as advertisers. Social networking cookies These cookies are used to enable you to share pages and content on our websites and services through third-party social networking and other websites. These cookies may also collect information about your browsing habits for advertising purposes. Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the Privacy Policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.
• Through Analytics – We use analytics services, including Google Analytics and Heap, to assist us with analyzing our website traffic through cookies and similar technologies. For more information on Google Analytics’ processing of your Personal Information, please see https://policies.google.com/technologies/partner-sites?hl=en-US. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

When accessing the Site, you are provided the option to adjust/opt out of certain cookies via our Cookie Preference Page. Most browsers also provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable.

3. How We Use Personal Information To the extent permitted by applicable law, we may use Personal Information to:

• operate the Site and provide support to our business functions;
• fulfill customer requests, such as to create an account or complete customer purchases;
• protect against criminal activity, claims and other liabilities;
• send you information about our company, products, services, and promotions;
• respond to reviews, comments, or other feedback provided to us;
• support and personalize the Site and our advertising efforts;
• protect the security and integrity of the Site;
• provide customer support;
• the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Site, facilitating product, software and applications development, improving the Site or our services and products, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
• meet our contractual requirements;
• comply with applicable legal or regulatory requirements and our policies;
• respond to inquiries related to employment opportunities;
• market, advertise, and provide the Site and our services and products; and
• the extent necessary for any other lawful purpose for which the Personal Information is collected.

4. Sharing of Personal Information We may share your Personal Information in the following circumstances:

• To Third Parties for Marketing Purposes – We may share your Personal Information with third parties for their marketing purposes. This may include third parties whose services we believe you may be interested, or who are interested in providing you with services.
• For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Caraway, its users, or the public against harm.
• In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
• To Service Providers – When we hire a service provider to help operate the Site or our business, we may give access to, or share, Personal Information as necessary to perform the service for Caraway. This may include service providers that operate our Site, analyze how our Site is used, send our communications, run our promotions, or operate our chat functionality.
• To Business Partners – We may share Personal Information with our trusted business partners. For example, we may share your Personal Information with a company when we co-sponsor a promotion or service. These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.

5. How Long Do We Keep Your Personal Information We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Policy, or any longer retention period required by law.

6. How We Protect Your Personal Information We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.

7. Your Choices and Controls Depending on where you live, you may have the following rights with respect to your Personal Information:

• Access
• Data portability
• Erasure
• Correction
• Restriction of processing
• Out of sale of Personal Information

For a broader description of these rights, please see the applicable chart in Section 11 below. In addition, you may have the right to opt out of targeted advertising and profiling, to the extent that profiling makes decisions that produce legal or similarly significant effects concerning you. To exercise any of these rights available to you, see Section 13 below. To opt-out of marketing communications please email us at [email protected] or by following the instructions included in the email or text correspondence.

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our services to you.

8. International use of the Site This Site is hosted in the United States. If you are visiting this Site from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our data center and servers are located and operated.

9. Children's privacy We do not knowingly collect or solicit any Personal Information from children under the age of 16. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at [email protected] or contact us using the information listed in Section 13.

10. Links to third-party websites We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

11. California residents  This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CCPA, (2) your privacy rights under CCPA, and (3) how to exercise your rights.

When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 13.

We make the following disclosures regarding the Personal Information we have collected within the 12-month period preceding the effective date of this Privacy Notice:

Sources of Personal Information. We collect Personal Information: (i) directly from you; (ii) automatically through tracking technologies; and (iii) from third parties.

Use of Personal Information. We collect Personal Information for the business and commercial purposes detailed in Section 3 above. Disclosure of Personal Information. The categories Personal Information, and the third parties to which we disclose personal information for a business or commercial purpose or to whom we sell or share Personal Information, are summarized in the chart below. We do not knowingly sell or share the personal information of minors under the age of 16.

Category of Personal Information	Categories of Third Parties to Which We Disclose Personal Information for a Business or Commercial Purpose	Categories of Third Parties to Which We May Sell or share Personal Information
Identfiers	Service Providers	We do not sell this category of Personal Information. However, we share this category of information with third parties for purposes of cross- context behavioral advertising
Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code §1798.80(e))	Service Providers	We do not sell or share this category of Personal Information.
Protected classification characteristics under California or federal law	Service Providers	We do not sell or share this category of Personal Information.
Commercial information	Service Providers	We do not sell or share this category of Personal Information.
Internet or other similar network activity	Service Providers	We do not sell this category of Personal Information. However, we share this category of information with third parties for purposes of cross-context behavioral advertising.
Geolocation data	Service Providers	We do not sell or share this category of Personal Information. However, we share this category of information with third parties for purposes of cross-context behavioral advertising
Professional or employment-related information	Service Providers	We do not sell or share this category of Personal Information.
Inferences drawn from other personal information	Service Providers	We do not sell or share this category of Personal Information.

We will retain each category of your Personal Information for as long as necessary to fulfill the purposes described in Section 2 above, unless required to do otherwise by applicable laws. Criteria we will use to determine how long we will retain your information include whether: we need your information to provide you with products or services you have requested; we continue to have a relationship with you; you have requested information, products, or services from us; we have a legal right or obligation to continue to retain your information; we have an obligation to a third party that involves your information; our retention or recordkeeping policies and obligations dictate that we retain your information; we have an interest in providing you with information about our products or services; and we have another business purpose for retaining your information.

B. Your California privacy rights Subject to certain exceptions, if you are a resident of California, you may have the following rights:

Privacy Right	Description
Notice	The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Data Portability	The right to receive the Personal Information you have previously provided to us.
Access	The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Erasure	The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
Correction	You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
To Opt Out of Sales or Sharing of
Personal Information	You have the right to opt-out of the sale and sharing of your Personal Information by clicking the “Do Not Sell or Share My Personal Information” link on the footer of our Site.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to [email protected] or send us a letter with your request at the mailing address in Section 13. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.

Other California Privacy Rights California Civil Code Section 1798.83 permits visitors to our Websites and Services who are California residents and who have an existing business relationship with us to request certain information regarding our disclosure of personal information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please send an email with the subject heading “California Privacy Rights” to us at [email protected], or you may write to us at the address below.

12. Changes to this Privacy Policy Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with an updated Privacy Policy if material changes are made. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Site.

13. Contact us If you have any questions about our practices or this Privacy Policy, or if you would like to exercise any of your rights under applicable data protection law, please contact us at [email protected]. You may also write to us at: Caraway Home, Inc 228 Park Ave S PMB 75861 New York, New York 10003

14. Postscript In addition, you agree to our Messaging Terms and Messaging Privacy Policy.