California Consumer Privacy Act

Effective as of March 4, 2022.

This "Privacy Policy" describes the privacy practices of HBtowershop (collectively, "HBtowershop," "we," "us," or "our") with respect to, and our related services (together with the Site, the "Services"), and the rights and choices individuals have with respect to their information.

We provide important information for California residents in the "Notice to California Residents" section and for individuals in Europe in the "Notice to European Users" section below.

Personal Information We Collect
Personal information you provide to us. The personal information you provide to us through the Service or otherwise includes.

Contact data, personal or business contact information such as your first and last name, email and mailing address, telephone number, professional title and company name.
Registration data, such as information you provide to register for an account or sign up for an event, including your date and month of birth and the event for which you registered.
Data about other people for whom you purchase items or gifts, such as names, shipping addresses and telephone numbers. Please do not purchase gifts for others or share their contact information with us unless you have their permission to do so.
Personal information, such as the username and password you set up to create an online account with us, and your interests and preferences.
Communication data, such as questions, feedback, survey responses, or other information you provide when you contact us to correspond with us.
Marketing data, such as the email address or contact information we use to send marketing communications, and your preferences for receiving communications about our activities, events, sweepstakes and contests.
Purchase data, including your order history and information needed to process and fulfill your order, including order details, billing address and shipping address.
Other information we may collect that is not specifically listed here, but which we will use in accordance with this Privacy Policy or disclose separately at the time of collection.
Data from other sources.

We may also collect information about you from the following

Business partners, such as advertising and co-marketing partners.
Data providers, such as information services and data licensors.
Public sources, such as blogs, forums or social media platforms.
Information we obtain from third-party platforms.

If you choose to log into the Site through a third-party platform (such as Google or Facebook) or otherwise link your account on a third-party platform or network to your account through the Site, we may collect information from that platform or network. You may also have the opportunity to provide us with additional information through a third party platform or network, such as a list of your friends or connections and your email address. 

Automatic Collection. We and our service providers may automatically record information about you, your computer or mobile device, and your activities that occur on or through the Site, for example.

Device data, such as the type and version number of your computer or mobile device's operating system, make and model, browser type, screen resolution, IP address, the websites you visited prior to browsing our Site, and general location information, such as city, state or geographic area.
Online activity data, such as the pages or screens you view, how long you spend on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, time of visit, and duration of visit.
Cookies and similar technologies. Some of our automated data collection is conducted through cookies and similar technologies. See our Cookie Policy for more information.

Referrals. Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may submit a referral only if you have given us permission to provide us with their contact information so that we may contact them.

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

Service delivery. We may use your personal information to:

provide, operate and improve the Service, such as to enable you to make purchases of clothing and accessories that we have listed on the Sites;
establish and maintain your account on the Service;
communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;
provide customer support and maintenance for the Service;
facilitate your login to the Sites via third party platforms, such as Google and Facebook; and
enable security features of the Sites, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in.

Direct Marketing. If you are an existing customer of HBtowershop (for example, if you have placed an order with us), we may use the Personal Data you provided to send you marketing communications about HBtowershop products or services, where permitted by applicable law (unless you have opted out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us, as well as information from other HBtowershop products or services, such as your use of HBtowershop website , to personalize communications and advertisements regarding our products and services that may be of interest to you. For registered users, this may include data collected from your interactions with our website and/or apps that are associated with your account.. You will have the ability to opt-out of our marketing and promotional communications as described in the Your Choices section below.

For research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.

To create anonymous data. We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Interest-based advertising. We may contract with third-party advertising companies and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data, online activity data and/or geolocation data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. These ads are known as "interest-based advertisements." You can learn more about your choices for limiting interest-based advertising, in the Your Choices section below and our Cookie Policy

To comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber attacks and identity theft.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

We may share your personal information with the following third parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as order fulfillment, shipping, payment processing, customer support, hosting, analytics, email delivery, marketing, database management services, returns processing and risk and fraud mitigation).

Advertising partners. Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

Third party platforms. Social media and other third party platforms that you connect to the Service, such as when you use options to access the Service by logging into a social media platform. Please note, we do not control the third party’s use of your personal information.

The public. Other users of the Service and the public, when you disclose personal information for public use. For instance, you may be able review a product that you purchased, and we will display your name along with the content you submit. We do not control how other users or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.

Professional advisors. Professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.

Business transferees. We may sell, transfer, or otherwise share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of an insolvency, bankruptcy, or receivership.

In this section, we describe the rights and choices available to all users.

Access or update your account information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions located at the bottom of the email. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. 

Advertising Choices. You may opt-out of interest-based advertising. 
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit

Privacy settings and location data. Users of our App can disable our access to their device’s precise geolocation in their mobile device settings.

Choosing not to share your personal information. If you do not provide information that we need to provide the Service, we may not be able to provide you with the Service or certain features. We will tell you what information you must provide to receive the Service when we request it.

Third-party platforms or social media networks. If you choose to create an account through or connect the Service with another third-party platform, you may have the ability to limit the information that we may obtain from the third-party at the time you log in to the Service using the third-party’s authentication service or otherwise connect your account. You may also be able to control your settings through the third-party’s platform or service after you have connected your accounts.

Other websites, mobile applications and services
This website may contain links to other websites and online services operated by third parties. These links do not constitute an endorsement by us of any third party or an association with any third party. In addition, our content may be included on pages or online services that are not affiliated with us. We do not control third party websites or online services and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of other websites and online services that you use.

Security Practices
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards to protect the personal information we collect. However, security risks are inherent to all Internet and information technology and we cannot guarantee the security of your personal information.

The Service is not intended for use by children under the age of 16, and we do not knowingly collect information from children under the age of 16 through the Service. If we learn that we have legally collected personal information from a child without the consent of the child's parent or guardian, we will delete that information.

Changes to this Privacy Policy
We reserve the right to change this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. If required by law, we may also provide notice of changes in another way that we believe is likely to reach you, such as by email or by other means through the Services.

Any changes to this Privacy Policy will be effective when we post the revised version (or as otherwise noted at the time of posting). In any event, your continued use of the Service following the posting of any revised Privacy Policy indicates your acceptance of the terms of the revised Privacy Policy.

How to Contact Us
Any questions or comments about this policy or privacy practices should be directed to You may also email us.

notice to california residents
These Terms are effective as of March 4, 2022

As required by the California Consumer Privacy Act of 2018 ("CCPA"), we explain to California residents how we collect, use, and share their personal information, and the rights and choices we provide to California residents in connection with that personal information. 

Personal Information We Collect, Use and Share. We do not sell personal information. As we explain in this Privacy Policy, we use cookies and other tracking tools to analyze website traffic and to promote advertising. We also work with third party advertising and social media companies (such as Google and Facebook) to collect data about your device and personal online activity when visiting our website to help deliver interest-based advertising to you, please refer to the Interest-Based Advertising section above and our Cookie Policy for more information.

The chart below outlines how we collect, use and share personal information with reference to the categories set forth in the CCPA.

Category of personal information (PI)
 PI we collect in this category Source of PI
  • Contact data
  • Registration data
  • Data about others
  • Profile data
  • Communications
  • Marketing data
  • Purchase data
  • You
  • Business partners
  • Data providers
  • Public sources
  • Third party platforms
Commercial Information
  • Contact data
  • Registration data
  • Purchase data
  • Communications
  • Marketing data
  • Device data
  • Online activity data
  • You
  • Business partners
  • Data providers
  • Public sources
  • Automatic collection
Financial Information
  • Purchase data
  • You
  • Business partners
Online Identifiers
  • Device data
  • Online activity data
  • Automatic collection
Internet or Network Information
  • Device data
  • Online activity data
  • Automatic collection

May be derived from your:

  • Device data
  • Online activity data
Protected Classification Characteristics We do not intentionally collect this information but it may be revealed in profile data or other information we collect.  
Sensory Information Security data, such as security camera footage collected at our retail stores and office locations
  • Automatic collection

Your California Privacy Rights The CCPA gives California residents the following rights. However, these rights are not absolute, and in some cases we may deny your request to the extent permitted by law.

Information. You may request information about how we have collected, used, and shared and used your personal information in the past 12 months.
Categories of Personal Information We Collect.
The categories of sources from which we collect personal information.
The business or commercial purposes for which personal information is collected and/or sold.
The categories of third parties with whom we share personal information.
Whether we disclose your personal information for business purposes and, if so, the categories of personal information received by each category of third-party recipient.
Whether we sold your personal information and, if so, the categories of personal information received by each type of third party recipient.
Access. You may request a copy of the personal information we have collected about you in the past 12 months.
Deletion. You may request that we delete the personal information we have collected from you.
You have the right to exercise the above rights without discrimination that is prohibited by law from increasing prices or reducing the quality of our services.

We provide additional information about how you can choose not to have your information used for interest-based advertising in the "Your Choices" section of our Cookie Policy.

How to Exercise Your California Rights. You may exercise your California privacy rights as described above in the following manner.

Right to  Information, access and deletion. You may request to exercise your information, access and deletion rights by clicking here, We reserve the right to confirm your residence in California in order to process your request and will need to confirm your identity in order to process your request to exercise your information, access and deletion rights. Government identification may be required as part of this process. Under California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, valid government-issued identification of the requester, and valid government-issued identification of the authorized agent. If you do not provide us with sufficient details to enable us to understand and respond to your request, we will not be able to process it.
Request a list of third party marketers. California's "Shine the Light" law (California Civil Code Section 1798.83) allows California residents to request certain information from companies with which they have formed business relationships primarily for personal, family or household purposes about certain personal information, if any, that those companies have shared with third parties for their direct marketing purposes in the previous year. You can  email submits such requests by indicating "Shine the Light" in the subject line. The request must include your current name, street address, city, state and zip code, and attest to the fact that you are a California resident.
If you do not provide us with sufficient details to enable us to understand and respond to your request, we will not be able to process your request.

Notice to Users in Europe
The information provided in this "Notice to European Users" section applies only to individuals in the European Union, the European Economic Area, or the United Kingdom (collectively, "Europe").

Personal Information. Unless otherwise specified, references in this Privacy Policy to "personal information" are equivalent to "personal data" as governed by European data protection laws.

Legal Basis for Processing. The legal basis for our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases on which we generally rely are set out in the table below. We will only rely on our legitimate interests as our legal basis if those interests are not outweighed by the impact on you (unless we have your consent or our processing is required or permitted by law). If you have questions about the legal basis for how we process your personal information, please contact us at

Processing purpose (click link for details regarding processing purposes) Legal basis
Service delivery Processing is necessary to perform the contract governing our operation of the Sites or the provision of the Service, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.


Internet-based advertising

Processing is based on your consent where that consent is required by applicable law.

Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business, and showing you tailored relevant content.

For research and development

To create anonymous data

For compliance, fraud prevention and safety

These activities constitute our legitimate interests.
To comply with laws and regulations Processing is necessary to comply with our legal obligations.
With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.


Use for New Purposes. Where permitted by law, we may use your personal information for a reason not described in this Privacy Policy and that reason is consistent with the purpose for which we collected the information. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive Personal Information. Unless we specifically request otherwise, we ask that you not provide us with any sensitive personal information on or through the Service (for example, information relating to racial or ethnic origin, political opinions, religious or other beliefs, health, biometric or genetic characteristics, criminal background or union membership).

Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collect it, including for the purpose of satisfying any legal, accounting or reporting requirements, establishing or defending legal claims, or for the purpose of preventing fraud. When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it or, if this is not possible (for example, because your personal information is already stored in a backup archive), then we will store your personal information securely and isolate it from any further processing until possible deletion.

Your rights. European data protection law gives you certain rights in relation to your personal information. You may request that we take the following actions with respect to the personal information we hold about you.

Access. To provide you with information about our processing of your personal information and to allow you access to your personal information.
Correction. To update or correct any inaccuracies in your personal information.
Delete. To delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or to a third party of your choice.
Restrict. Restrict the processing of your personal information.
Objection. To object to our processing of your personal information on the basis of our legitimate interests affecting your rights.
You may submit these requests by email to to the postal address we have provided above. We may ask you to provide specific information to help us confirm your identity and process your request. Applicable law may require or allow us to deny your request. If we deny your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your request for personal information, you may contact us or submit a complaint to the data protection supervisory authority in your jurisdiction.