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Effective Date: September 5th 2025
We at A Fine Gauge, Inc. dba White & Warren (“White & Warren,” “we,” “us,” or “our”) value and respect your privacy. This Privacy Policy is meant to help you understand our data practices, and explains what personal data we collect about users of the White & Warren website (https://www.whiteandwarren.com), including both mobile and desktop versions (the “Site”), and other interactive features, widgets, plug-ins, mobile applications, content, downloads, and/or other online services that we own and control and that post a link to the Privacy Policy (collectively with the Site, the “Services”). We encourage you to review our Terms of Service, which govern your use of the Services.
For the purposes of many privacy laws, we are the data controller of your personal data. Our contact information is found under Contact Us if you have any questions or concerns about this Privacy Policy. If you are a visually impaired individual, an individual with another disability, or seek support in another language, you may access this Privacy Policy by emailing us at privacy@whiteandwarren.com.
Please note that we are providing the following disclosures and rights in this Privacy Policy in the interest of transparency. Such disclosures and rights are not intended to waive any applicable exemptions under state and federal law.
For ease of review, below is a table of contents.
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We collect, use, and disclose information that may be used to uniquely identify you in various ways in accordance with applicable law. |
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We may collect personal data from various sources. |
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We may disclose your personal data to certain third parties, such as our service providers and advertising partners. |
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We collect information about your use of our Services through cookies and other tracking technologies. |
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We rely on one or more legal bases to process your personal data under applicable law. |
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We use reasonable and appropriate technical and organizational measures to protect your personal data. |
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We will retain your personal data only for as long as is necessary for the purposes set out in this Policy, and use reasonable and appropriate technical and organizational measures to protect your personal data. |
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If you are located outside of the United States and choose to provide information to us, we transfer the data to the United States and process it there. |
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Our Services are not intended for individuals under the age of 18. |
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We explain how you may exercise choices and rights related to your personal data. |
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We provide additional disclosures and rights to Nevada residents. |
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We provide additional disclosures and rights to California residents. |
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We provide additional disclosures and rights to residents of certain other states. |
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We provide additional disclosures and rights to individuals in the EEA and UK. |
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We provide additional disclosures and rights to individuals in Canada. |
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Changes to this Privacy Policy will become effective on the date they are posted. |
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You may contact us for comments or questions in various ways. |
As used in this Privacy Policy, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes “personal information” as that term is defined in applicable privacy laws.
Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.
We may create aggregated, de-identified, or anonymous information from data by removing certain data components (such as your name, email address, or linkable tracking identifier) that makes the data identifiable, or through aggregation, obfuscation or other means. Subject to applicable law, our use and disclosure of such aggregated, de-identified, and anonymized information is not personal data or subject to this Privacy Policy.
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Category of Personal Data |
Processing Purposes |
Categories of Third-Party Recipients (excluding service providers and affiliates) |
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Identifiers, including:
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Commercial information, including:
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Same purposes as noted for “Identifiers” |
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Internet or other electronic network activity information, including:
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Same purposes as noted for “Identifiers” |
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Geolocation data, including:
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Same purposes as noted for “Identifiers” |
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Financial data, including:
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N/A |
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Audio, electronic, visual, or similar information, including:
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Same purposes as noted for “Identifiers” |
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Characteristics of protected
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Inferences about you using any of the above |
Same purposes as noted for “Identifiers” |
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Because of the overlapping nature of certain of the categories of personal data identified above, some of the personal data we collect may be reasonably classified under multiple categories.
2. Sources of Personal Data
We may collect personal data about you from the following categories of sources:
Directly from you.
Through cookies and other tracking technologies, as discussed in more detail in Cookies and Other Tracking Technologies.
From our service providers, including those providing hosting, analytics, customer and technical support, email, mailing, and text services, data enrichment, and other services. For example, we may collect personal data if you use a chatbot on our Site, which is provided by our third-party service provider, Gorgias.
From third-party data providers, business and marketing partners, partners that we work with to provide promotions and cashback rewards (“Affiliate Partners”), joint marketing campaign partners, ad network providers, advertisers, and data sharing partners, which may include data sharing cooperatives and similar entities (“Dating Sharing Partners”).
From social media and other content platforms, such as Instagram, Facebook, Pinterest, and TikTok, if you interact with us on these platforms.
3. Disclosure of Personal Data
We may disclose personal data that we collect to the following:
Our service providers. We disclose personal data with our service providers to provide services on our behalf, such as email, mailing, and text services; payment processing; analytics; advertising; hosting, marketing; customer and technical support; and other services. For example, if you use a chatbot on our Site, the information provided may be recorded and stored by our third-party provider, Gorgias, on our behalf.
Advertising platforms. We may share your information with third-party platform providers, including advertising, social media, and analytics companies, who assist us in serving advertising regarding the Services to others who may be interested. We also partner with third parties who use cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.
Affiliate Partners. We may share your information with Affiliate Partners who provide you with cashback rewards and other offers. For example, if you make a purchase through an Affiliate Partner link, we may share your order with the Affiliate Partner to confirm your purchase and process the reward.
Other Third Parties. We may share your information with other third parties including joint marketing campaign partners, Third-Party Businesses, and Data Sharing Partners
Compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.
Business transfers and transactions. If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal data may be transferred to the acquiring or surviving entity.
We may combine the personal data we receive from these third parties with personal data we otherwise collect about you through your use of our Services.
4. Cookies & Other Tracking Technologies
We use cookies and similar tracking technologies and analytics services to track activity on and gauge the effectiveness of our Site. Cookies are files with a small amount of data which may include unique identifier. Cookies are sent to your browser from a website or mobile application and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
A. Examples of cookies we use
Cookies on our Site generally fall into the following categories:
Strictly Necessary. We may use cookies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, and improve security.
Performance/Analytics. We may use cookies that are useful to assess the performance of our Site, including as part of our analytic practices or otherwise to improve our Site.
Functionality. We may use cookies that are required to offer you enhanced functionality when accessing our Site, including identifying you when you sign in to our website or keeping track of your specified preferences, including in terms of the presentation of content on our Site.
Targeting or Advertising. We may use cookies to deliver content, including advertisements, relevant to your interests on our Site based on how you interact with advertisements or content. We do not use your information for targeted advertising on third-party platforms.
B. Analytics Information
We may use Google Analytics or other service providers for analytics services. These analytics services may use cookies to help us analyze how users use the Service. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Service’s activity, and providing other services relating to Services activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
C. Third-Party Ad Networks.
Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program here. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members' ad networks. You can learn more about opting out of such targeted advertising and using the NAI tool here.
Please be aware that even if you opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Opting out of one or more NAI or DAA members only means that those selected members should no longer deliver certain targeted ads to you. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access (e.g., mobile app), your NAI/DAA browser-based opt-out may not be effective. Mobile device opt-outs will not affect browser-based Interest-based Ads even on the same device, and you must opt-out separately for each device. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
5. Legal Bases for Processing
We rely on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our Terms of Use; (ii) as necessary to pursue our legitimate business interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.
We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.
Our legitimate interests generally include:
Providing, improving, and developing our Services, including to deliver your requested services, send you messages and provide user support, customize the Services to better fit your needs as a user, develop new products and services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
Protecting you and others and creating and maintaining a trusted environment, such as to comply with our legal obligations, to ensure compliance with our agreements with you and other third parties, to ensure safe, secure, and reliable Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions on various Services, content you submit to the Services, and information obtained from third parties.
Providing, personalizing, measuring, and improving our marketing, including sending you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.
6. Data Security
The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal data against unauthorized access, destruction, loss, alteration, disclosure or misuse. We encourage you to secure your account with a strong password and to keep your password private.
7. Data Retention
We will retain your personal only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal data for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable given our legal position, including regard to applicable statutes of limitations, litigation, or regulatory investigations.
8. International Transfers of Data
We may transfer, store, and use information we collect and maintain about you, including personal data outside of your state, province, country or other governmental jurisdiction. For example, if you are located outside United States and choose to provide information to us, please note that we transfer personal data to United States and process it there.
The data protection laws in the jurisdiction in which we process personal data may differ from those of your jurisdiction, and in certain circumstances, your personal data may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.
9. Children’s Privacy
Our Services are not directed to or intended for children. We do not knowingly collect any personal data from anyone under the age of 18. If you become aware that a child has provided us with personal data, we strongly encourage you to Contact Us, and we will do our best to promptly remove such information from our records.
10. Your Privacy Choices & Rights
You may have certain choices and rights regarding our collection, use, and disclosure of your personal data, based on your location or place of residency.
A. Opting out of promotional electronic communications from us.
You may opt-out of any emails that we send for promotional purposes by clicking the “unsubscribe” links provided at the bottom of those emails. If you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required to provide you with our Site or services or for other reasons disclosed in this Privacy Policy. This means you will continue to receive these emails even if you unsubscribe from our optional communications.
Note that when you visit our Site, cookies and similar tracking technologies may be used by our marketing partners to associate your activity on your Site with other personal data that they or others have about you, including by association with your email address. We may then send marketing emails to you. You may opt out of receiving this type of advertising by visiting https://app.retention.com/optout.
Additionally, with your consent, we may send you SMS messages for promotional purposes, internal business purposes, internal user research, and to provide customer service, including troubleshooting. To cancel the SMS service at any time, text “STOP” to any text message you receive or Contact Us. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have unsubscribed. After this, you will no longer receive SMS messages from us. If you are experiencing issues with the messaging program you can text “HELP” for more assistance, or you can Contact Us.
B. Mail preferences. To ensure that you receive only the catalogs you enjoy, please fill out this form if your address has changed or you no longer wish to receive White & Warren catalogs. Please note that our mail files are prepared 45 days in advance of a mailing date, so it may take up to 2 months to stop receiving catalogs.
C. Additional rights available in certain states and jurisdictions.
Certain jurisdictions provide individuals with certain rights with respect to their personal data or personal data as defined under applicable law. These rights are subject to the specific laws of that jurisdiction and that certain other rights might apply. Please review our Nevada Privacy Notice; California Privacy Notice; Privacy Notice for Residents of Other States; Privacy Notice for Individuals in the EEA and UK; Privacy Notice for Individuals in Canada; and Privacy Notice for Individuals in Australia for more information on rights and terms specific to your location or place of residence. If any of the jurisdictional notices below apply to you, please use the following information to exercise your rights.
Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.
Please send your request(s) using one of the following methods:
Email: privacy@whiteandwarren.com.
Submit a request via Your Privacy Choices.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Depending on applicable law, you may be limited in how many verifiable or authenticated consumer requests you make within a twelve (12) month period. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity.
Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
You are not required to create an account with us to submit a verifiable or authenticated consumer request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal data associated with that specific account. We will only use personal data provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
If you are a visually impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at privacy@whiteandwarren.com.
11. Nevada Privacy Notice
We may “sell” personal data as that term is defined under Nevada law. Nevada residents have the right to opt out of any future sale of their personal data under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please follow the instructions in Your Privacy Choices & Rights. You must include your full name, email address, and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal data after the receipt of your request, we will make reasonable efforts to comply with your request.
12. California Privacy Notice
This California Privacy Notice supplements the information contained in the rest of our Privacy Policy and is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy. For the purposes of this California Privacy Notice, except where a different definition is noted, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal data does not include publicly available information, information that has been de-identified or aggregated, or other information subject to certain federal and state regulations.
If you are a visually impaired customer, a customer who has another disability or a customer who seeks support in another language, you may access this California Privacy Notice by emailing us at privacy@whiteandwarren.com.
A. Personal data we collect.
We have collected the following categories of personal data from consumers within the last twelve (12) months:
Identifiers
Commercial information
Internet or other electronic network activity information
Geolocation data
Financial data
Audio, electronic, visual, or similar information
Characteristics of protected classifications
Inferences
We do not collect sensitive personal data.
B. Use of personal data.
We may use or disclose the personal data we collect for one or more of the following purposes:
Provide, operate, maintain, improve, personalize, and expand our Services
Provide customer service and support
Facilitate orders
Develop new features and functionalities
Communicate with you in accordance with your preferences to provide you updates and other information relating to our Site and our policies, and for marketing and promotional purposes
Perform internal analytics
For systems and data security, including to prevent unauthorized, improper, or illegal activities on our Site
For internal business purposes, including general business administration
Market our products and services
Market the products and services of others
For targeted advertising
Comply with our legal obligations, including responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims
Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about the users of our Services is among the assets transferred
For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy or for any other legal purpose not inconsistent with this Privacy Policy
Any other purpose consistent with your consent and expressed preferences
C. Disclosure of personal data.
We limit our disclosure of the categories of personal data above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal data for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal data was collected.
We may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms; joint marketing partners; and Third-Party Businesses.
In the last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of personal data:
Identifiers
Commercial information
Internet or other electronic network activity information
Geolocation data
Audio, electronic, visual, or similar information
Characteristics of protected classifications
Inferences
D. Retention of personal data.
Your personal data will be retained by us for as long as necessary for the purposes outlined in this Privacy Policy. This information will be used and retained to the extent necessary to comply with any legal obligations or policies, to resolve disputes, and/or enforce legal agreements. Personal data may also be retained for internal analytic purposes. This information is retained for a shorter period, unless it used to enhance security features or improve the functionality of our Services. Our determination of precise retention periods will be based on (1) the length of time we have an ongoing relationship with you; (2) whether there is a legal obligation to which we are subject; and (3) whether retention is advisable considering our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.
E. Your privacy rights.
The CCPA provides California residents with specific rights regarding their personal data. If you are a California resident, you may have the following rights under applicable California law:
Right to know and access. You have the right to know what personal data we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
Right to correct inaccurate personal data. You have the right to request the correction of inaccurate personal data.
Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
Right to opt out of sale and/or sharing. You have the right to opt-out of the sale and/or sharing of your personal data by a business.
Right to limit use and disclosure. You have the right to limit the use or disclosure of your sensitive personal data to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal data after you have exercised your right, unless you subsequently provide consent for the use of your sensitive personal data for additional purposes. As noted above, we do not collect sensitive personal data.
Sharing with third parties for their own direct marketing purposes. You have the right to request information regarding third parties to whom we have disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes under California’s “Shine the Light” law (Cal. Civ. Code §1798.83). If you wish to request information regarding such practices, please Contact Us. You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond. California’s “Shine the Light” law also provides you the right to opt-out of such disclosures on a going forward basis. You may exercise this right as referenced above under “Right to Opt Out of Sale/Sharing.”
F. How to exercise your rights.
You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices & Rights.
G. Notice of right to opt-out of sale/sharing.
California residents may opt out of the “sale” or “sharing” of their personal data. As noted above, we may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms. We may also “sell” and/or “share” personal data with other third parties including joint marketing campaign partners; and Third-Party Businesses. You may opt out by following the instructions in Your Privacy Choices & Rights.
We do not knowingly sell or share the personal data of minors under 16 years of age without legally required affirmative authorization. If you are a parent or guardian and you believe that your child has provided us with information without your consent, please review the Children’s Privacy section and contact us by email at privacy@whiteandwarren.com. You can also opt out of such sale or sharing by clicking the Your Privacy Choices link at the bottom of our Site and selecting your preferences.
H. Notice of financial incentives.
We may provide programs and offers, such as promotional campaigns, email newsletters, and referral programs. When you sign up for one of these programs, we typically ask you to provide your email address, first and last name, and phone number. Because these programs involve the collection of personal data and offering of certain benefits, they might be interpreted as a “financial incentive” program under California law. Such programs may include:
Email Newsletter. When you subscribe to our newsletter, we may offer you special savings in the form of digital coupons for free or discounted products and announcements of sweepstakes, contests, and giveaways. To receive the newsletter, you must provide a valid email address. To opt out of our newsletter, please click “unsubscribe” located at the bottom of any email newsletter.
Referral Program. We may offer digital coupons for free or discounted products, store credit to our online store, or gift cards through our Referral Program. When you sign up for our Referral Program, you will be asked for personal data such as your first and last name, valid email address, and phone number to participate in the program. When you sign up for our Referral Program, you may also be given the opportunity to sign up for our promotional emails. To opt out of these emails, please click “unsubscribe” located at the bottom of any email.
The value we place on personal data collected for these promotions varies, but we estimate it equals the additional spending per promotion participant, compared to individuals for whom we do not have email addresses or other collected information.
13. Privacy Notice for Residents of Other States
This section contains additional information for residents of Colorado, Connecticut, Delaware, Indiana (beginning January 2026), Iowa, Kentucky (beginning January 2026), Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island (beginning January 1, 2026), Tennessee, Texas, Utah, and Virginia about personal data that we collect, how we use it, what sources it is derived from, and who we disclose it to, and provides information regarding your rights, and our responsibilities, under applicable laws and regulations.
The provisions contained within this section, in addition to the disclosures throughout the rest of this Privacy Policy, are intended to provide notices in compliance with the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Indiana Consumer Data Protection Act (beginning January 1, 2026), the Iowa Consumer Data Protection Act, the Kentucky Data Protection Act (beginning January 1, 2026), the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Data Privacy Act, the New Jersey Privacy Act, the Oregon Consumer Data Privacy Act, the Rhode Island Data Transparency and Privacy Protection Act (beginning January 1, 2026), the Tennessee Information Protection Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”).
This section does not apply to certain personal data that is collected from an individual in a business-to-business or employment context.
Please note that we are providing the following disclosures and rights in this section in the interest of transparency. Such disclosures and rights are not intended to waive any applicable exemptions under state and federal law.
A. Our personal data practices.
The State Privacy Laws provide rights to residents of those states to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data. More detail about what kinds of personal data we may collect or have collected, how we collect it, why we collect it, and who we may disclose it to is found in the Personal Data We May Collect, Use, and Disclose; Sources of Personal Data; and Disclosure of Personal Data sections of this Privacy Policy. As noted above, we do not collect sensitive personal data.
We may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms. We may also “sell” and/or “share” personal data with other third parties including joint marketing campaign partners; and Third-Party Businesses.
B. Your privacy rights.
If you are a Colorado, Connecticut, Delaware, Indiana (beginning January 2026), Iowa, Kentucky (beginning January 2026), Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island (beginning January 1, 2026), Texas, Utah, or Virginia resident, you have the following rights under applicable law in relation to your personal data, subject to certain exceptions:
Right to know and access. You have the right to know what personal data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
Right to correct inaccurate personal data. If you are a resident of Connecticut, Colorado, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Rhode Island, Tennessee, Texas, or Virginia, you have the right to request the correction of inaccurate personal data.
Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
Right to opt out. You have the right to opt-out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.
Rights concerning sensitive personal data. If you are a Connecticut, Colorado, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Rhode Island, Tennessee, Texas, or Virginia resident, we cannot process your sensitive data or your sensitive data inferences, or use your personal data for certain purposes without your affirmative consent. If you are an Iowa or Utah resident, you have the right to opt out of having your sensitive personal data processed. As noted above, we do not collect sensitive personal data.
C. How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices & Rights.
D. How to appeal decisions about your rights. Colorado, Connecticut, Delaware, Indiana (beginning January 2026), Iowa, Kentucky (beginning January 2026), Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island (beginning January 1, 2026), Texas, and Virginia residents can appeal our decisions concerning privacy rights requests, as follows:
Colorado residents. If you are a Colorado resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Colorado’s Office of the Attorney General by phone at (720) 508-6000 or by submitting a form here.
Connecticut residents. If you are a Connecticut resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.
Delaware residents. If you are a Delaware resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Delaware’s Department of Justice by phone at (302) 683-8800 or by submitting a form here.
Indiana residents. If you are an Indiana resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Indiana’s Office of the Attorney General by phone at (800) 457-8283 or by submitting a form here.
Iowa residents. If you are an Iowa resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Iowa’s Office of the Attorney General by phone at (888) 777-4590 or by submitting a form here.
Kentucky residents. If you are a Kentucky resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Kentucky’s Office of the Attorney General by phone at (888) 432-9257or by submitting a form here.
Maryland residents. If you are a Maryland resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Maryland’s Office of the Attorney General by phone at (888) 743-0023 or by submitting a form here.
Minnesota residents. If you are a Minnesota resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Minnesota’s Office of the Attorney General by phone at (800) 657-3787 or by submitting a form here.
Montana residents. If you are a Montana resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Montana’s Office of the Attorney General by phone at (406) 444-4500 or by submitting a form here.
Nebraska residents. If you are a Nebraska resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Nebraska’s Office of the Attorney General by phone at (402) 471-2683 or by submitting a form here.
New Hampshire residents. If you are a New Hampshire resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Hampshire’s Office of the Attorney General by phone at (603) 271-3658 or by submitting a form here.
New Jersey residents. If you are a New Jersey resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Jersey’s Office of the Attorney General by phone at (800) 242-5846 or by submitting a form here.
Oregon residents. If you are an Oregon resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Oregon’s Office of the Attorney General by phone at (877) 877-9392 or by submitting a form here.
Rhode Island residents. If you are a Rhode Island resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an Rhode Island’s Office of the Attorney General by phone at (401) 274-4400 or by submitting a form here.
Tennessee residents. If you are a Tennessee resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Tennessee’s Office of the Attorney General by phone at (615) 741-3491 or by submitting a form here.
Texas residents. If you are a Texas resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Texas’ Office of the Attorney General by phone at (800) 621-0508 or by submitting a form here.
Virginia residents. If you are a Virginia resident and want to appeal our decision about a request that you have previously made, please Contact Us or notify the Office of the Attorney General of Virginia online here. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Virginia’s Office of the Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or online here.
14. Privacy Notice for Individuals in the EEA and UK
This Notice applies to any individuals located within the European Economic Area (“EEA”) and the United Kingdom (“UK”) about whom we may have collected personal data from any source, including through your use of the Site. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”) and the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states (collectively, “European Privacy Laws”).
Please note that we are providing the following disclosures and rights in this Privacy Policy in the interest of transparency. Such disclosures and rights are not intended to waive any applicable exemptions under state and federal law.
In certain circumstances, individuals located within the EEA and UK are entitled to the following privacy rights:
Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
Right to Erasure. You have the right to request that we erase your personal data in certain circumstances provided by law.
Right to Rectification. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
Right to Object to Processing. You have the right to object to our processing of your personal data.
Right to Restrict Processing. You have the right to request that we restrict the processing of your personal data.
Right to Data Portability. You have the right to request that we provide you with a copy of your personal data in a structured, machine-readable and commonly used format.
Right to Withdraw Consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal data.
Right to Lodge Complaint. You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
A list of EU supervisory authorities is available here.
The relevant UK supervisory authority is the UK Information Commissioner’s Officer.
To exercise your privacy rights described above, please email us at privacy@whiteandwarren.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.
15. Privacy Notice for Individuals in Canada
This Notice applies to individuals in Canada about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and/or provincial privacy laws.
For the purposes of this Notice, "personal data" means information about an identifiable individual. Personal data does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work email address. Personal data also does not include information that has been de-identified, anonymized, or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other available information.
Please note that we are providing the following disclosures and rights in this Privacy Policy in the interest of transparency. Such disclosures and rights are not intended to waive any applicable exemptions under state and federal law.
In certain circumstances, individuals in Canada are entitled to the following privacy rights:
Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
Right to Withdraw Consent. If you have already consented to the collection, use, and/or disclosure of your personal data, you may subsequently withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.
To exercise your privacy rights described above, please email privacy@whiteandwarren.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you have any questions or concerns about our privacy practices, please email us at privacy@whiteandwarren.com.
You may also contact the Office of the Privacy Commissioner by calling (800) 282-1376 if you are unsatisfied with our response to your privacy concern.
16. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will let you know about material changes via email and/or a prominent notice on our Services, prior to the changes becoming effective and will update the “Effective Date” at the top of this Privacy Policy. Changes to this Policy are effective when they are posted on this page.
17. Contact Us
If you have any questions about this Privacy Policy, please email us at privacy@whiteandwarren.com; call us at 877-887-7707; or write to us at White & Warren 80 W 40th St. New York, NY 10018.
