1. Policy Scope

This privacy policy applies to your use of the CPO Sites and CPO’s treatment of information collected by or on behalf of CPO through the CPO Sites. Your use of linked or associated websites, or websites to which you may be directed, may be subject to different or additional terms, notices and policies, and such terms, notices and policies shall control as to those websites. For information regarding the collection and use of information on any of those websites or other third party sites, please refer to the terms of use and policies provided by those websites.

2. Our Information Collection Practices

We collect information about you when you visit the CPO Sites. What types of information we collect depends on how you interact with us.

Automatically Collected Information. When you visit the CPO Sites, we may automatically collect and store the following types of information:

Information about your device and usage: We may collect information including your Internet protocol (IP) address, web browser type, operating system type, Internet service provider, name of the domain and host from which you access the CPO Sites, access date and time, information collected as server logs from information provided by your browser, click-through statistics, the type of device that you use, unique device identifiers, mobile carrier, the Internet address of the sites from which you linked directly to CPO Sites, information about the links you click and content you interact with on CPO Sites, the frequency and duration of your visits to CPO Sites, and the Internet addresses of sites you visited during your visit to and upon exiting CPO Sites.

Location information: We may use general location information for purposes such as to determine estimated shipping times. If you do not want to share your location, you can disable location sharing in the settings on your device. We may also collect general location information via your IP address.

Cookies and other electronic technologies: We may use cookies, pixel tags, and other electronic technologies that help the CPO Sites function, improve our advertising and services, and perform research and analytics.

Information from social media platforms: If you connect with us through social media by “liking” or “following” us on Facebook, Instagram, YouTube, or other social media platforms, we may collect information including your username, name, email address, and any comments or content you post on our social media pages.

Information Provided Directly by the User. In order to take advantage of the full capabilities of the CPO Sites and to obtain access to, and use of, many of the features found on the CPO Sites, you must provide certain information. The information you provide to us directly may include, without limitation, your:

• Contact information, such as name, mailing address, email address, telephone number, and fax number;
• Account information you provide when you register for an account with us, such as your email address and password;
• Preference information, such asInformation concerning your interests, occupation, product use and preferences.
• Customer service interaction information, such as messages submitted to us through online forms or email, and phone recordings from interactions with our customer service representatives.
• Information you provide in connection with surveys and sweepstakes, such as your interests, preferences, demographic data (e.g., gender), and information needed for you to participate and for us to fulfill your prize or participation incentives (if any).
• Affiliate Program. We partner with Commission Junction LLC, a third party, to offer our Affiliate Program. We may collect certain contact information from participants in our Affiliate Program. However, all payment information and other information collected as part of the program is directly collected by Commission Junction LLC and not shared with CPO. Please review Commission Junction LLC’s Privacy Policy for more information about its data collection and use practices.
• Other information you provide us in any medium, such as any information you include in emails to us or submissions made through our “contact us” page.

Information Obtained from Third Parties. We may receive information about you from other sources, such as business partners, marketers, public websites, survey administrators, social network services, and other parties, and combine this information with other information we have about you. We may also receive information about you through certain functionalities on the CPO Sites, such as the “Email This Page to a Friend” feature. Similarly, if a customer requests that an order or gift be sent directly to another individual, we may receive information about the recipient of the order or gift. This information may include name, address, phone number, fax number, email address, and other similar information.

4. Use of Information

We use information collected through the CPO Sites for business and commercial purposes, including:

• To process, confirm, and ship your orders, exchanges, and returns;
• To communicate with you, for example, by sending you updates about your purchases and shipments, updates to our site and services, and changes to our terms, conditions and policies;
• For marketing and advertising purposes, including providing you with the latest product announcements, promotions, and information about upcoming events;
• To personalize your experience and customize our site, such as customizing the site to your preferences and delivering relevant content;
• To improve our site, including bug detection and error reporting;
• To analyze how users interact with our site and our advertisements on our site and third-party platforms, improve usability and effectiveness of our site, perform research and analytics, and to test and create new features and services;
• For our business operations, including maintaining your account, reviewing and processing employment applications, and for security, fraud prevention, and legal compliance, such as detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. This may also Include exchanging information with other companies and organizations for credit fraud protection and risk reduction purposes;
• To recognize users across our and our affiliates’ websites, browsers, and devices (for example, by linking activity associated with the same username, IP address, and unique device identifiers) to provide you with a more seamless and personalized experience across these channels; and
• Other purposes for which we obtain your consent, in accordance with applicable law.

We may aggregate and de-identify information to use for any purpose and may share, sell and rent or trade such de-identified and aggregate information and statistical information derived therefrom with our marketing partners, advertisers, or other third parties.

5. Disclosure of Information

Service Providers and Vendors. We may share your information with certain third parties and affiliates that perform services for CPO. Those third parties may host the CPO Sites, operate certain features on the CPO Sites, print or send mailings, provide marketing materials for the CPO Sites, authorize and process your payments, provide customer service, analyze data and assist in fulfilling your orders, send e-mails on CPO’s behalf, or otherwise assist CPO with the operation of the CPO Sites. Those third parties are not authorized to use or disclose your information for any purpose other than to perform the services designated by CPO or as required under applicable law.

Advertising and Marketing Partners. We may allow third-party advertising and marketing technologies and parties that support our advertising and marketing efforts (e.g., ad networks, ad measurement services, advertising analytics providers, remarketing providers, etc.) on our Services that use cookies and similar technologies to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use.

Business Transfers. Information we collect may be transferred as an asset in connection with a merger or sale involving all or part of CPO or as part of a corporate reorganization, stock sale or other change of control.

Disclosures for Legal and Safety Purposes. CPO may also provide your information to a third party if CPO in good faith believes that access, use, preservation or disclosure is reasonably necessary to satisfy any applicable law, regulation, legal process or enforceable government request; to enforce our terms of service; or to protect the rights, property, or personal safety of CPO or others. For example, CPO may be required to disclose your information to respond to a subpoena, court order or other legal process.

6. International Users

Please note that CPO is located in the United States and processes your data in the United States. In addition, CPO may subcontract the processing of your data to, or otherwise disclose your data to, service providers and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of our products services to you, the processing of transactions, and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage, or use.

7. Notice for Parents

The CPO Sites are considered to be general audience sites and are not to be used by children. CPO does not sell products that are intended for children and does not intend to collect Personal Information (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)) from individuals under the age of eighteen (18). If you are the parent or guardian of a child who has provided Personal Information to us, please contact us as provided in Section 14 below, and we will make reasonable efforts to delete that Personal Information.

8. Use of Cookies

Cookies are pieces of information that are transferred from websites to your computer’s hard drive, and they may serve a variety of purposes. Web beacons, flash cookies and other similar technologies may also be used for these purposes. For example, cookies “remember” you when you return to a website and make your experience more user-friendly. Cookies identify which web pages are visited and how often. Cookies are also used to allow companies to better understand how their websites are used to improve their services.

CPO uses cookies to store information about your visit to the CPO Sites in order to enhance your experience. For example, we use cookies to store information that will allow us to, on occasion, customize account pages for you.

Types of cookies, how they’re used, and the potential impact if disabled:

Review your cookie use settings by visiting www.bigdeskdrawer.com and clicking the “Cookie Preferences” link at the bottom of the page.

In addition, we currently contract with several online partners to help manage and optimize the CPO Sites. We use the services of a marketing company to help us measure the effectiveness of our advertising and how visitors use our sites. To do this, we use Web beacons and cookies provided by our marketing company on the CPO Sites. The type of information we collect includes which pages are visited, which products are put into the shopping cart, which orders enter the checkout process, which checkouts are executed with payment, etc. By supplementing our records, this information helps us learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. Although our marketing company manages the information coming from our sites on our behalf, we control how that data may and may not be used. If you wish, you can opt-out of our ability to analyze such data by contacting us (see Section 10).

9. Retention of Your Information

We will store your information for as long as reasonably necessary for the purposes described in this privacy policy, to provide our services and to fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements, and for fraud prevention and related security purposes. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain your email address as an authentication credential (where applicable) as long as you have an account with us and for an additional period of time after that for our fraud and legal compliance purposes. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information.

10. Your Rights and Choices

Marketing Email, Texts, and Mail. You may opt-out of receiving future marketing emails from us by clicking the “unsubscribe” link at the bottom of any email that you receive from us, or by contacting us (see Section 14). You may opt out of receiving future marketing mailings from us by contacting us (see Section 14). You may stop marketing texts by replying “STOP.” Please note that removal of your information from our records or opting-out of receiving future communications will not stop (i) marketing or advertising content that is ready to be mailed or is queued for transmission to you prior to the time when we can implement your request, or (ii) the use of your information by third parties with whom CPO may have already shared your information.

Requests Concerning Your Personal Information. Depending on your state of residence, you may have the right to make certain requests regarding your “personal information” or “personal data” and (as such terms are defined under applicable law, and collectively referred to in this Policy as “personal information”). Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

You may also have the right to opt out of “sales” of your information and “processing of your information for targeted advertising” as described below. If you are a California resident, please see Section 13 below for more information about your rights.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address.

If you would like to exercise your rights to make these requests, please fill out the form linked here: Consumer Requests. Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision in our communications with you. To exercise such an appeal right, please email us at privacyteam@cpocommerce.com.

Opt Out of Sales of Personal Information and Processing of Personal Information for Targeted Advertising Purposes. Depending on your state of residence, you may also have the right to opt out of “sales” of your information and “sharing/use of your information for targeted advertising.”

As explained in the “Disclosure of Information” section above, we may provide personal information to third-party advertising and marketing partners so that we and our partners can provide you with more relevant and tailored ads and engage in analysis to support our advertising efforts. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or “processing of your personal information for targeted advertising purposes” under applicable law.

If you would like to opt out of such “sales” or “processing for targeted advertising purposes,” please visit this page: Do Not Sell/Share My Personal Information. We do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization. Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

Do Not Track. Some browsers have a “Do Not Track” feature that lets you send a request to websites to not track your online activities. We, like many other retailers, do not honor those requests.

11. Security

CPO and authorized third parties employ a variety of administrative, technical, and physical measures, to protect your information from unauthorized access, loss, alteration, use or disclosure. In addition, we use reasonable measures to limit the disclosure of your information consistent with this privacy policy. However, your information can never be 100% secure: information may be transmitted over networks without appropriate security measures and may be accessed, deleted, altered, used or disclosed by unauthorized persons. You can help us to protect your information by (i) not sharing your password or other account information with others, (ii) using a secure web browser, and (iii) changing your password frequently.

12. Updates and Changes to Policies

CPO may change this privacy policy from time to time by posting updated versions of the privacy policy here. As we may make changes to this privacy policy at any time without notifying you, we suggest that you review this privacy policy each time you access or use the CPO Sites. If we make material changes to this policy, we will notify you as required by law. Please note that our rights to use your information will be based on the privacy policy in effect at the time the information is collected. By continuing to use the CPO Sites, you are agreeing to be bound by any changes or revisions made to this privacy policy.

13. State-Specific Disclosures

a. Nevada Residents

Under Nevada SB 220, Nevada residents have the right to opt-out of the sale of Personally Identifiable Information—which includes first and last name, address, email address, phone number, Social Security Number, and any other identifier that allows a specific person to be contacted either physically or online— collected through a website or online service. If you are a Nevada resident and wish to opt-out of the sale of your Personally Identifiable Information, you may submit your request to Opt-Out of the sale of Personal Information to Third Parties by submitting an online request at: Do Not Sell My Personal Information

b. California Residents

1. California Shine the Light Law

Under California Civil Code sections 1798.83–1798.84 California residents may, free of charge, request the names and addresses of affiliated companies to whom we have disclosed their Personal Information (as defined by Cal. Civil Code section 1798.83(e)(6)(A)) for direct marketing purposes in the prior calendar year, as well as the categories of Personal Information we have disclosed, once per year. If you are a California resident and would like to make such a request, please contact us as provided in Section 14.

2. California Consumer Privacy Act of 2018

Information Rights. California residents have the following rights with regard to their Personal Information, as that term is defined in the California Consumer Privacy Act (“CCPA”):

1. The right to know i.e., our disclosure of categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.)
2. The right to access specific pieces of Personal Information we maintain about you
3. The right to deletion of Personal Information
4. The right to correct inaccurate Personal Information we maintain about you

Note: Employees of CPO who are California residents and who wish to make a request to exercise their rights with respect to their employment-related data may submit requests here: CA Employee Privacy Rights Request.

We will take reasonable steps to verify your identity prior to fulfilling the above requests, such as by verifying your name and email address. If we are able to verify your identity, we will respond to your request to the extent we are able to and as required by law. If we cannot verify your identity, we may request additional information from you or we may deny your request. If we are unable to fulfill your request(s) in their entirety, we will provide further information to you about the reasons that we could not comply with your request.

Certain personal information may be exempt from such requests under applicable law. In addition, we need certain types of personal information so that we can provide products and services to you. If you ask us to delete it, you may no longer be able to access our products and services. We do not discriminate against any consumer for exercising their rights under the CCPA.

Opt-Out Rights. As explained in the “Disclosure of Information” section above, we may provide Personal Information to third-party advertising and marketing partners so that we and our partners can provide you with more relevant and tailored ads and engage in analysis to support our advertising efforts. The disclosure of your Personal Information to these third parties to assist us in providing these services may be considered a “sale” of personal information or “sharing” of your Personal Information for cross-context behavioral advertising purposes under applicable law.

If you would like to opt out of such “sales” or “sharing,” please visit this page: Do Not Sell/Share My Personal Information. We do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization. Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law. We will take reasonable steps to verify your identity prior to fulfilling the above requests. We do not discriminate against any consumer for exercising their rights under the CCPA.

Authorized Agents. Authorized Agents may submit requests on behalf of a California resident using the above processes and providing the appropriate documentation.

Privacy Disclosures. The CCPA also requires us to disclose certain information about how we collect, use and disclose categories of Personal Information defined by California law. The following section, which supplements the information provided in the main Privacy Policy above, provides this information in the form required by California law.

Notice of Financial Incentives. We may offer opportunities to receive certain benefits, such as rewards, discounts, or other similar incentives, which may require the provision of personal information, such as answering surveys or signing up to receive marketing communications from us (each, an “Incentive Program”). Your participation in Incentive Programs is purely voluntary. When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and may revoke your participation depending on the Incentive Program. The monetary value of the reward, discount, or incentive is a reasonable approximation of the monetary value of participation in the Incentive Program. We have arrived at this estimate based on consideration of multiple factors, including the following: (1) revenue generated by CPO in connection with the Incentive Program; (2) expenses incurred by CPO in operating the Incentive Program; and (3) improvement of products and services based on information obtained through the Incentive Program.

14. Rakuten

Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercials purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.

Privacy policy: https://rakutenadvertising.com/legal-notices/services-privacy-policy

Your rights : https://rakutenadvertising.com/legal-notices/service-privacy-rights-request-form/

15. Contact CPO

If you have questions regarding the CPO Sites, the privacy policy or your privacy on the CPO Sites, you can send a request with any further questions to our Customer Service Department by e-mail to privacyteam@cpocommerce.com,

by mail at:

or by phone at: 1-866-577-6004

Upon receiving a written request, we will contact you directly, investigate your request, and work to address your concerns. We will respond to your request without undue delay. We reserve the right to take reasonable steps to verify your identity prior to granting access or processing changes or corrections.

Privacy Notice Updates

This Privacy Statement may change from time to time, and we will post on our websites any updated Privacy Notice. version of this Privacy Notice will be identified by its effective date displayed at the top of this Privacy Notice.