Copper-Crown-LX

Privacy Policy

Last Updated: 9/2/2021

This Privacy Policy (“Policy”) describes the personal information collected by or on behalf of Columbia Vehicle Group, Inc. (“Company,” “we,” “us,” or “our”) and its service providers through the websites www.tomberlinusa.com (collectively, the “Site“) and our interactions with you (“Personal Information”) and how that Personal Information is used, shared and protected. 

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. 

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:

  1. 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.
  2. 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.
  3. Commercial Information: Information about orders, purchases, ordering history, shipping history, and purchasing histories and tendencies.
  4. 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.
  5. Geolocation Data: Approximate geolocation data via IP Addresses.
  6. 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 info@nordicgroup.com with “Unsubscribe” in the subject line. Opting out of marketing communications does not opt you out of communications about your account or transactions.
  • 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.
  • Cookies & Other Tracking Technologies. We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Site.
    • 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.
    • Why do we collect Cookies? We use Cookies to:
      • 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 Agreement.
      • 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.
  • Google Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets Cookies and then your web browser will automatically send data to Google. Google uses this data to provide us with reports that we use to improve the Site’s structure and content. To learn more about how Google uses data, visit Google’s Privacy Policy. You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools.
  • Google Ads. We use Google Ads to serve ads across various sites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other sites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

    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.
  • Video Content. The Site contains videos and embedded content made available by TOMBERLIN, including visible content and/or feeds scripts embedded in the Site’s code. TOMBERLIN, along with the other parties that host this video content to stream on the Site, may collect data about how you interact with such content. Specifically, our use of YouTube content requires us to implement certain application programming interfaces (APIs) from YouTube, which allow for data collection, disclosure and use by YouTube pursuant to the Google Privacy Policy available here, whether or not you watch such videos. You may revoke YouTube’s access to your data by visiting the Google security settings page available here.
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 Agreement, 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, ArtBin 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 TOMBERLIN.
  • Business Transactions. In the event TOMBERLIN 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 info@nordicgroup.com to opt-out of any such monetary transactions in the future.

Age Requirements

We are committed to protecting children’s privacy. The Site is not directed at children under 13 years of age. We do not knowingly collect, use, or share data from children under 13. If a parent or legal guardian learns their child provided us with Personal Information without his or her consent, please contact us.

Use and Disclosure of De-Identified or Aggregated Information

TOMBERLIN 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. TOMBERLIN is the sole and exclusive owner of such anonymized and aggregated information, including if TOMBERLIN anonymizes Personal Information so that it no longer considered Personal Information under applicable laws.

Social Media

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.

The Site allows you to connect and share data with Social Media. In addition, you may tie your account to your Facebook account to login via Facebook. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media to facilitate those communications and features. The Site may use advertising networks and services offered by Social Media to deliver advertising content. Use of these services requires Social Media to implement Cookies to deliver ads to you while you access the Site.

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 Agreement. We encourage you to review those policies and terms.

Website Operator

The following operators may collect or maintain Personal Information through the Site:

  • Facebook
  • Instagram

Please direct all inquiries about any operator’s privacy practices to the operator of this website, which is:

Columbia Vehicle Group, Inc.
Attn: TOMBERLIN Website Administrator
1115 Commercial Avenue
Reedsburg, WI 53959 USA
www.tomberlinusa.com

844-363-7432
info@nordicgroup.com

Data Security

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.

Third-Party Websites

The Site may link to, or be linked to, sites not owned or controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Agreement does not apply to any third-party sites or to any data that you provide to third parties. You should read the privacy policy for each site that you visit.

California Residents
 
This section applies to residents of California. In the event of a conflict between this section and the remainder of this Agreement, 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 Agreement 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 Agreement, you may submit your request to us by contacting us at any of the following:

info@nordicgroup.com

Columbia Vehicle Group, Inc.
1115 Commercial Avenue
Reedsburg, WI 53959
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?

Subject to certain limitations, if you are a California resident you may make the following requests with regard to your Personal Information.

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.

Contact Us

If you have any questions you may contact us as set forth below:

Columbia Vehicle Group, Inc.
Attn: TOMBERLIN Website Administrator
1115 Commercial Avenue
Reedsburg, WI 53959 USA
www.tomberlinusa.com

1-844-363-7432

info@nordicgroup.com

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