In the preceding twelve (12) months, we have sold your personal information to the following categories of third parties:
- Automotive Companies
- Business Services/Agency
- Consumer Services Companies
- Consumer Packaged Goods Companies
- Educational Institutions & Companies
- Energy and Utility Companies
- Financial Services Companies
- Food & Beverage Companies
- Health Product Companies
- Insurance Companies
- Manufacturing Companies
- Marketing and Research Companies
- Media and Publishing Companies
- Not for Profit Organizations
- Public or Government Entities
- Public Institutions
- Retail Companies
- Technology/Computer Software Companies
- Telecommunications Companies
- Travel, Leisure & Entertainment Companies
- Other Companies not Categorized.
Hugo Dunhill aims to provide consumers with control over the collection and use of their personal information. Consistent with this goal, we will honor requests from consumers to “opt-out” of the collection and disclosure of their personal information. Your Rights and Choices section below provides instructions on how to opt-out of our collection and disclosure of personal information.
Your Rights and Choices
The CTDPA provides consumers (Connecticut residents) with specific rights regarding their personal information.
You have the right and choice to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- (1) The categories of personal information we collected about you.
- (2) The categories of sources for the personal information we collected about you.
- (3) Our business or commercial purpose for collecting or selling that personal information.
- (4) The categories of third parties with whom we share that personal information.
- (5) The specific pieces of personal information we collected about you.
You also have the right to request that we opt-out the sale or sharing of your personal information and delete all the personal information that we have collected and retained about you. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless a specific CTDPA exception applies. You have the right to correct inaccuracies in your personal information and the right to limit the use and disclosure of your personal information.
Exercising Access, Data Portability, Opt-Out, Correction, Limit the Use and Deletion Rights
To exercise the access, data portability, opt out, correction, limit and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person that you have designated as an authorized agent to act on your behalf may make a verifiable consumer request related to your personal information. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests (which we may ask to review) or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. As a parent or legal guardian, you may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability once within a 12 month period at no cost to you. The verifiable consumer request must:
- Provide all required information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with clear and precise detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response to you electronically (via email). Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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.
We will not discriminate against you for exercising any of your CTDPA rights or choices. Unless permitted by the CTDPA, we will not:
- (1) Deny you goods or services.
- (2) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- (3) Provide you a different level or quality of goods or services.
- (4) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Hugo Dunilll does NOT offer any financial incentives or payments to consumers as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information.
We do not knowingly collect, maintain or disclose identifiable information on anyone younger than 18 to third parties for use in marketing solicitations. Limited information related to minors younger than 18 is used in creating additional insights solely related to the adult parent in the household of the minor individual, however, we do not disclose any identifiable information about the minor as part of the insights created and included within the adult record (For example, we only create a flag that denotes “presence of children” and “child age ranges”).
We do not knowingly collect, maintain or sell personal information about consumers younger than 18 for the purpose of marketing or advertising directly to the minor. If we become aware that we have collected personal information from a child under the age of 18, we will delete that information from our records.
Changes to Our Privacy Notice
Hugo Dunill reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.
Right to Appeal
If you feel that we have not processed your request to your satisfaction, you may appeal our decision. Please provide any additional information concerning your request and email it to privacy@HDML.com
. Once we have received your appeal, we have 60 days to review it and respond. In the event the appeal is denied, you may contact the Connecticut Attorney General to file a compliant against us at: