Privacy Policy

This Privacy Policy explains how Kinbrae Inc. (“Kinbrae,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes personal information when you visit or use kinbrae.com, any club microsites or private-label storefronts that link to this Privacy Policy, communicate with us, create an account, place an order, request fittings or club services, join our mailing list, or otherwise interact with us online or offline (collectively, the “Services”).

This Privacy Policy is meant to be read together with any just-in-time notices we provide at the point of collection, our Cookie Policy, and any terms or disclosures that apply to a specific promotion, club program, or service.

Company details:
Kinbrae Inc.
15 E Putnam Avenue #368 Greenwich, CT 06830
203-275-9140
Privacy contact: Operations@Kinbrae.com
Customer care & Club services: Service@Kinbrae.com

Depending on how you interact with us, we may collect the following categories of personal information:

(a) Contact and account information, such as your name, shipping address, billing address, email address, telephone number, account credentials, and account preferences.
(b) Order and transaction information, such as products viewed or purchased, order number, club or program affiliation, gift messages, sizing selections, fitting notes, exchanges, returns, and customer-service history.
(c) Payment and fraud-prevention information, such as payment token data, billing details, payment status, transaction risk signals, and information from payment processors or fraud-prevention vendors. We typically do not store full payment-card numbers ourselves.
(d) Communications and inquiry information, such as the contents of emails, forms, chats, club inquiries, fitting requests, and responses to surveys, campaigns, or events.
(e) Device, browsing, and usage information, such as IP address, browser type, operating system, referral URLs, pages viewed, products clicked, timestamps, session behavior, approximate geolocation inferred from IP address, and interactions with emails or website features.
(f) Preference and profile information, such as wish-list data, saved sizes, material interests, club interests, appointment preferences, and marketing preferences.
(g) Information you choose to provide in connection with fittings or special requests, which may include garment measurements or style preferences.
(h) Inferences derived from the information above, such as likely product interests, preferred categories, or whether you may be interested in club, gifting, or partnership services.

We collect personal information:

• directly from you, such as when you place an order, submit a form, create an account, sign up for marketing, or contact us;
• automatically from your browser or device through cookies, pixels, server logs, and similar technologies;
• from our service providers, such as payment processors, fraud-prevention providers, shipping partners, customer-service platforms, analytics providers, and ecommerce infrastructure vendors; and
• from business or club partners where relevant to a club program, event, fitting, or private-label relationship.

We may use personal information for the following purposes:

• to operate the Services, maintain the website, and provide requested features;
• to process, fulfill, ship, track, exchange, refund, and service orders;
  to manage accounts, club inquiries, fittings, scripting requests, and customer support;
• to communicate with you about orders, service messages, product availability, appointments, policy changes, and operational notices;
• to send marketing emails or other promotional communications where permitted by law and in accordance with your choices;
• to personalize content, product recommendations, assortments, and outreach;
• to improve our products, services, website, product pages, sizing information, and customer experience;
• to detect, investigate, prevent, and address fraud, security incidents, unauthorized access, resale abuse, and other misuse;
• to comply with legal obligations, enforce contracts, protect rights and property, and respond to lawful requests; and
• to support corporate transactions such as financing, merger, acquisition, or sale of assets, subject to applicable law.

If data protection laws such as the GDPR or UK GDPR apply to our processing, we rely on one or more of the following legal bases, depending on the context:

• performance of a contract, such as processing orders, payments, returns, and account functions;
• legitimate interests, such as operating the business, preventing fraud, improving the Services, understanding customer demand, and managing club or partner relationships, provided those interests are not overridden by your rights;
• consent, where required, such as for certain marketing messages and non-essential cookies or similar technologies; and
• compliance with legal obligations, such as tax, accounting, consumer-protection, and recordkeeping obligations.

We may disclose personal information to the following categories of recipients:

• ecommerce platform, website hosting, and infrastructure providers;
• payment processors and fraud-prevention vendors;
• shipping, logistics, fulfillment, returns, and warehousing providers;
• customer-service, communications, CRM, and email-marketing providers;
• analytics, performance, and advertising partners, subject to your settings and applicable law;
• professional advisers such as lawyers, auditors, insurers, and accountants;
• governmental authorities, regulators, law enforcement, and other parties where required by law or necessary to protect rights and safety;
• a buyer, investor, lender, or successor entity in connection with a proposed or completed corporate transaction; and
• relevant clubs, event hosts, or program partners where reasonably necessary to administer a club-specific, private-label, invitation, gifting, or fitting program you request or participate in.

When we disclose personal information, we do so subject to appropriate contractual, legal, or operational safeguards as applicable.

We and our service providers may use cookies, pixels, tags, SDKs, session replay tools, server logs, and similar technologies to operate the Services, remember preferences, analyze traffic, prevent fraud, understand engagement, and, where permitted, support marketing and advertising.

Some cookies are strictly necessary for the site to function. Other cookies—such as analytics, personalization, and advertising cookies—may be used only with consent where required by law. For more detail, please see our Cookie Policy and the cookie settings tools made available on the Site.

We do not sell personal information for money.

However, certain data-sharing practices involving cookies, pixels, and advertising technologies may be considered a “sale,” “sharing,” or targeted advertising under some privacy laws even when no money changes hands. If we engage in those activities, we will provide any opt-out rights required by applicable law, such as a “Your Privacy Choices” link, a cookie settings tool, or recognition of eligible browser-based preference signals where required.

When you shop through a club microsite, request club services, participate in a club-specific program, or purchase club-branded merchandise, we may share limited personal information with the relevant club or club operator only as necessary to verify eligibility, personalize club-branded goods, coordinate fittings or member services, fulfill orders, and provide customer support. Depending on the service, this may include your name, contact information, club affiliation or eligibility status, order details, and sizing or fitting information. We do not share payment card numbers with clubs. Clubs may use this information only for those purposes unless you separately consent to additional uses.

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, complete transactions, maintain records, resolve disputes, enforce agreements, comply with legal obligations, and protect our business.

Retention periods vary based on the type of information and the context in which it was collected. For example, we may retain:

• transaction and tax records for 7 years;
• account records for as long as your account remains active and for a reasonable period afterward;
• customer-service and inquiry records for 7 years;
• marketing records until you opt out, withdraw consent, or after a defined inactivity period; and
• cookie-level data for the duration stated in our cookie tools or cookie inventory, unless deleted earlier.

We may process and store personal information in the United States and other countries where we or our service providers operate. Those countries may not provide the same level of data protection as your home jurisdiction.

Where required by law, we use recognized transfer mechanisms or other appropriate safeguards for cross-border transfers and make information about those safeguards available upon request.

We use administrative, technical, and physical safeguards designed to protect personal information. However, no website, ecommerce environment, transmission method, or storage system can be guaranteed to be completely secure. You should use a strong password, protect your credentials, and notify us promptly if you suspect unauthorized activity in your account or communications with us.

Depending on where you live, you may have some or all of the following rights, subject to legal exceptions:

• to know or access the personal information we hold about you;
• to request correction of inaccurate information;
• to request deletion of certain personal information;
• to obtain a portable copy of certain information;
• to withdraw consent where processing is based on consent;
• to object to or restrict certain processing;
• to opt out of targeted advertising, certain profiling, or the sale / sharing of personal information where applicable;
• to appeal a denial of certain privacy requests where applicable; and
• to designate an authorized agent where applicable law permits.

California residents may also have rights regarding categories of personal information collected, sources, business purposes, categories of recipients, correction, deletion, opt-out, and non-discrimination, subject to applicable law.

To exercise rights, contact us at Operations@Kinbrae.com or use Kinbrae.com/Privacy-Policy. We may need to verify your identity before processing a request. You will not be discriminated against for exercising privacy rights that apply to you.

You can opt out of promotional emails by using the unsubscribe link in the email or by contacting us. Opting out of marketing communications will not stop transactional or service-related messages, such as order confirmations, shipping updates, policy notices, or communications regarding an active account, inquiry, or return.

Where required by law, we obtain consent before sending certain marketing communications. You may also manage cookie-based advertising preferences through the cookie settings tools provided on the Site.

The Services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13 without appropriate consent. If you believe a child has provided personal information to us in violation of this Policy, please contact us so that we can investigate and, where appropriate, delete the information.

If you operate the Services in jurisdictions with different children’s privacy thresholds, update this section accordingly.

The Services may link to third-party websites, applications, payment pages, club pages, social-media platforms, or other services that we do not control. Their privacy practices are governed by their own policies, not this Privacy Policy. We encourage you to review those policies before providing personal information to them.

We may update this Privacy Policy from time to time to reflect changes in law, technology, our practices, or the Services. When we do, we will revise the “Last Updated” date and, where required, provide additional notice. Your continued use of the Services after an updated version becomes effective is subject to the revised Privacy Policy.

If you have questions about this Privacy Policy or would like to exercise privacy rights, contact:
Kinbrae Inc.
203-275-9140
Service@Kinbrae.com