Notice of Privacy Practices
Last Updated: July 1, 2020
Leatherman Tool Group, Inc. (“Leatherman,” “we,” “our,” or “us”) recognizes that you care about how information about you is used and shared and respects your privacy. This notice of privacy practices (“Notice”) informs you of how information is collected on and through this Leatherman website, located at http://www.leatherman.com (the “Website”), how we may use the information and with whom we may share it. This Notice also describes (i) the measures we take to safeguard the information we collect and (ii) your rights concerning our collection, use and disclosure of information about you. Information collected on or through this Website may be collected by Leatherman or by third-party service providers acting on our behalf. The term “we,” as used in this Notice, may include our third-party service providers.
Updates to this Notice. We may update this Notice to provide clarification or notice of changes to our practices from time to time. If we make changes, we will revise the “Last Updated” legend at the top of this Notice. Any material changes to this Notice will be posted on the Website and we encourage you to check back from time to time to ensure continuing familiarity with the most current version of the Notice.
General Audience Website. Services offered by Leatherman are not directed to individuals under the age of thirteen (13). Leatherman does not knowingly collect personal information (as defined below) from individuals under thirteen (13) years of age. No information should be submitted to or posted to the Website by visitors younger than thirteen (13) years old.
Information We Collect
Personal Information is information that identifies you as an individual. When you order products from the Website, we collect personal information, such as name, billing address, shipping address, telephone number, email address, birthdate, payment information (including payment card number or online payment service number) and related information. We may also collect personal information in connection with orders placed over the telephone or calls to customer support. The personal information you provide will vary based upon the context, and we will not collect your personal information unless you make it available. As a result, you do not have to provide such information to us unless you wish to order products from the Website. However, in order to set up an account, place an order or to take advantage of certain features of the Website, such as product registration or to sign up for newsletters, we may require that you furnish the personal information outlined above. If you do not provide this personal information, you will not be able to use these areas or features of the Website.
From time to time, we may give you the opportunity to participate in online surveys, promotions, contests and sweepstakes, subscribing to newsletters and other offerings through the Website. If you participate in these or other requests made available through the Website, we will request certain information from you. By providing your personal information to us, you grant us permission to use this information consistent with this Notice and to contact you about selected products, services, and events and to provide to you other information we think may interest you. Your provision of requested personal information to us through the Website or other means is presumed by us to be voluntary and with your consent to the uses described in this Notice.
In addition, you may provide information about another person on or through this Website. For example, you must provide information about another person when you request that we ship an order to another person. If you provide information about a person other than yourself, you represent and warrant that you are authorized by that person to provide this information to us.
Information Collected by Automated Means
When you visit the Website, certain information regarding use of the Website or the services is collected and/or aggregated by or on behalf of Leatherman through the use of automated means. The information collected automatically may include information about your visit to, and use of, the Website, such as your IP address, type of browser and operating system used, date and time you access the Website, pages you visit, search engine used to access the Website, and if you linked to the Website from another website, the address of that website. Like many other websites, we may also collect information using cookies, web beacons, pixel tags and related technologies. “Cookies” are small files sent from a web server that are stored on a computer’s hard drive for the purpose of identifying the browser during interaction on websites or storing information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We may also allow certain third-party analytics, advertising, and social media providers to include cookies and web beacons within the pages of the Website to collect information regarding how visitors use the Website and the effectiveness of the Website to help us improve and optimize the Website and products and services we offer.
Most web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. You may also render some web beacons unusable by rejecting their associated cookies. If you choose to decline cookies, certain features of the Website may not function properly or at all as a result.
How We May Use the Information We Collect. We use the personal information we collect for the following purposes:
- for our business purposes, such as establishing and managing your customer account, providing products and services you request (such as processing and shipping orders and sending order and shipping confirmations), processing and collecting payments and providing customer support, and to send you important administrative communications regarding the Website;
- to offer our products or services and/or the products or services of others to you;
- to communicate about, and administer your participation in, special events, programs, surveys, contests, sweepstakes, and other offers or promotions;
- to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, and the Website;
- to perform data analyses, including market and consumer search, trend analysis, demographic analysis, and financial analysis; and
- to comply with applicable legal requirements, to enforce our policies and terms of service and to protect the Website and its users.
We use information collected through automated means for purposes such as: (1) customizing visits to the Website based on observable user preferences and actions; (2) delivering content (including advertising) correlating to our users’ interests based on the ways in which our users interact with the Website; (3) to perform data analyses, including market and consumer search, trend analysis, demographic analysis, and financial analysis; (4) diagnosing technical and service problems; and (5) administering the Website.
Google Analytics. Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. You can opt-out of having Google Analytics collect traffic data here: https://support.google.com/analytics/answer/181881?hl=en.
Information We Share
Except with your consent or as described in this Notice, we do not sell or otherwise share personal information collected on this Website with third parties. We may share and disclose your personal information to third parties for any of the purposes listed in the above section titled “How We May Use the Information We Collect.” We share personal information in the following ways:
- Affiliates. We may share your personal information with our Affiliates so long as the disclosure and use of your personal information by such entities is consistent with this Notice.
- Service Providers. We may engage third parties to provide the services offered through this Website on our behalf, or other services with us for example, website development, order fulfillment, payment processing and collection, website hosting, credit verification and monitoring, and e-mail administration. We use a third-party service provider to send emails and newsletters to users and customers. We use a third party service provider to operate surveys and product evaluations and to collect information on our behalf in connection with those surveys.
- Surveys/Sweepstakes/Contests/Promotions. If you participate in a survey, sweepstakes, contest, or other promotion in connection with the Website or order placed through the Website, such participation serves as your consent for Leatherman to share your personal information collected in conjunction with the survey, sweepstakes, contest or promotion with the third party for administration of the survey or promotion and use in accordance with the terms provided with the promotion or survey.
- Other. We may share or disclose information, including personal information, to: (i) protect or defend our interests and the legal rights or property of Leatherman and our Affiliates; (ii) protect the rights, interest and safety and security of users of our Website or members of the public; (iii) protect against fraud or for risk management purposes; or (iv) comply with prudent legal practice as we may determine, applicable law or legal process. In addition, if we sell all or substantially all of our business, or sell or transfer all or a material part of our assets, or are otherwise involved in a merger or transfer of all or a material part of our business (including transfers made as part of insolvency or bankruptcy proceedings), we may transfer all information we have collected and stored, including your personal information, to the party or parties involved in the transaction as part of that transaction.
We may sell or share non-personally identifiable data, including anonymized data derived from personal information collected from the Website, with third parties, including our Affiliates, dealers, marketing businesses and lead generation businesses, for any purpose.
Advertising Networks. We may work with advertising networks that deliver targeted advertisements to consumers and generate statistics and metrics related to the delivery of such advertisements using information collected through cookies, web server logs and web beacons. This information is used to provide customization, auditing, research and reporting for us, our Affiliates and other advertisers. This data collection takes place both on this Website and on third-party websites that participate in the advertising networks. We do not provide any personal information to an advertising network when you interact with or view a customized advertisement. However, when you view or interact with an advertisement, the possibility exists that the advertiser will make the assumption that you are interested in the subject matter of the advertisements.
Many companies that collect information for behavioral advertising are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). NAI and DAA offer the ability for you to opt-out of the behavioral advertising programs of their members by going to https://www.networkadvertising.org/managing/opt_out.asp or https://www.aboutads.info/choices. Please note that if you use a different computer, change your web browser, or delete your cookies, you will need to renew all of your opt-out choices.
When you view or interact with an advertisement, the possibility exists that the advertiser will make the assumption that you are interested in the subject matter of the advertisements. Click on the links in the above paragraph to learn more about ad serving companies and opt-out from each of those listed.
Please note that this does not opt you out of being served advertising but only excludes you from interest-based advertising. If you use the Leatherman website or Affiliate websites, you will continue to receive generic advertisements.
Your Choices; Accessing and Modifying Your Personal Information. You are able to make certain choices about how we communicate with you and the information we collect from you and share with third parties. You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in our marketing emails, adjusting your email preferences via the hyperlink provided on the “My Account” page on the Website, or contacting us as specified in the “How to Contact Us” section below. You may still receive service oriented, administrative communications from us as you cannot opt-out of receiving such administrative communications.
Subject to applicable law, you may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information through the “My Account” page on the Website. If you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may request that we correct or amend the information by contacting us as specified in the “How to Contact Us” section below. We will endeavor to implement requested changes as soon as reasonably practicable after receiving your request. We reserve the right to retain any personal information reasonably necessary to document our business activities and for archival and record retention purposes.
Data Transfers. This Website is governed by and operated in accordance with the laws of the United States. If you are located outside the United States, please note that we may transfer the personal information we collect about you to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Notice and in accordance with applicable law.
Data Security. We maintain measures designed to safeguard personal information in our possession.. Despite these measures, we cannot guarantee the security of networks, servers and databases we operate or that are operated on our behalf or that the information you transmit to Leatherman over the Internet will not be intercepted, deleted or altered. Therefore, although we work to protect your privacy, we cannot promise, and you should not expect, that personal information or communications you transmit via the Internet are guaranteed to remain secure.
How to Contact Us. If you have any questions or comments about this Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at email@example.com or call us at (503) 253-7826 (toll-free: (800) 847-8665).
You also may write to us at:
Leatherman Tool Group, Inc.
P.O. Box 20595
Portland, OR 97294
Additional Notice for California Residents
This part of our privacy notice applies to consumers who reside in the State of California.
Personal information we collect about California consumers. We describe the personal information we have collected from consumers in the twelve (12) months preceding the “Last Updated” date of this Notice of Privacy Practices in the above section titled, “Information We Collect.” The information we have obtained includes the following:
- Identifiers such as: name; billing address, shipping address, other postal addresses, email addresses; internet protocol (IP) address; social media handles; username; password and other contact information used to register and access Leatherman products and services, participate in online surveys, promotions, contests and sweepstakes, and subscribe to newsletters and other offerings through the Leatherman Website.
- Characteristics of protected classifications under California or federal law, such as age and gender.
- Commercial information, including (1) records of products or services purchased or received from Leatherman, (2) username, password, or other account information used to obtain access to Leatherman’s online services; (3) information on actions taken on Leatherman’s websites, which may include information about Leatherman’s products or services considered and the times you visit our websites or use, and (4) information about consumer preferences and behavior that we collect on our websites or purchase from third parties in order to target consumers for digital advertisements or to personalize content we deliver on our websites.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, as well as the information listed above in the section titled “Information We Collect,” including: IP address, type of browser and operating system used, date and time you access the Website, pages you visit, search engine used to access the Website, and if you linked to the Website from another website, the address of that website.
- Electronic information in the form of Internet or other electronic network activity information as described above.
- Inferences drawn from the information listed in points (A) through (G) above, as well as any other information described in the above section titled “Information We Collect” in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
We collect this personal information from customers, other companies and organizations, and information that is publicly available. For more information, please see “Information We Collect.”
Use of Personal Information. We use the personal information we collect for our operational purposes, including all purposes notified to you in the above section titled “How We May Use the Information We Collect.” In addition to the purposes described above for which we use personal information, we use personal information for the following business purposes:
- Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
- Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
- Debugging to identify and repair errors in our systems;
- Short-term, transient use including contextual customization of ads;
- Providing services on our behalf or on behalf of others, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
- Conducting internal research to develop and demonstrate technology; and
- Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide, or to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for us, or controlled by us.
We do not sell or disclose personal information in exchange for monetary or other valuable consideration. As is common practice among businesses that operate Internet websites and mobile apps, within the past 12 months, we may have shared certain identifiers, information about the use of our websites and apps, and inferences drawn about you to our social media, advertising, and analytics partners. Under California law, this may be considered to be sharing of information for valuable consideration.
Your California Privacy Rights. If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
- Right to Know and Access regarding Personal Information. You have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
- the categories of Personal Information we have collected about you;
- the categories of sources from which the Personal Information is collected;
- our business or commercial purpose for collecting or selling Personal Information;
- the categories of third parties with whom we share Personal Information;
- the categories of personal information about you, if any, that we have disclosed for valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
- the categories of personal information about you that we disclosed for a business purpose;
- the specific pieces of information we have collected about you.
- Right to Deletion. You have the right to request that we delete Personal Information about you that we have collected from you.
- Right to Opt Out. If we disclose your personal information for valuable consideration, you have the right to opt-out of such sharing. To submit an opt-out request, click Do Not Sell My Personal Info.
Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights. As required or permitted under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted under applicable law.
To exercise any of these rights, please fill out a rights request form.
- Right to Know and Access regarding Personal Information. You have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
- Data Sharing for Direct Marketing Purposes. California Civil Code Section 1798.83 entitles California customers to request information concerning whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. As stated in this Notice, Leatherman will not sell or share your personal information with non-Leatherman companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How to Contact Us” section above.
- Do Not Track. Please note that our Web sites are not designed to respond to "do not track" requests from Web browsers.