Privacy Policy

At Headquarters, we take your privacy seriously. This Privacy Policy describes the policies and procedures of Headquarters Products LLC and its affiliates (“Headquarters”, “we”, “our” or “us”) on the collection, use and disclosure of personal information from those who use or access, our branded pages on social media services, or any of the other sites, services, features, content, applications and products we offer in the United States (collectively, the “Services”). If you are using the Services outside of the United States, a location-specific privacy policy may apply to you instead, so please check the applicable country-specific website (if any). The Services are hosted and operated in the United States and are subject to United States law. By using the Services, you acknowledge and agree that any Personal Data (as defined below) that you provide to us is being provided to us in the United States and will be hosted on United States servers.

Please read this Privacy Policy to learn how we treat your personal information. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use and share your information in the ways described in this Privacy Policy.

Remember that your use of our Services is at all times subject to our Terms of Service , which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service.

You may access a printable copy of this Privacy Policy by clicking here . If you have a disability that prevents you from accessing this Privacy Policy via our website, please contact to access this Privacy Policy in an alternative format.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. This Privacy Policy applies only to Personal Data that we collect from you directly. Where we have collected Personal Data from third parties, you may need to contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

Sources of Personal Data

We collect Personal Data about you from:

  • You:

    • when you provide such information directly to us, including in the course of ordering any of our products
    • when Personal Data about you is automatically collected in connection with your use of our Services
  • Our affiliates (“Affiliates”), when they provide us with Personal Data about you
  • Third parties, when they provide us with Personal Data about you (“Third Parties”). Third Parties that share your Personal Data with us include:

    • Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or Third Parties may help us provide you with customer support.
    • Social networks connected to the Services. If you provide your social network account credentials to us or otherwise use Services through a third-party site or service, some content and/or information in those accounts may be transmitted to us.
    • Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.

Categories of Third Parties with Whom We Share Personal Data

We disclose your Personal Data to the following categories of service providers and other parties:

  • Service providers, including:

    • Payment processors
    • Shipping and logistics companies
    • Name and address verification providers
    • Ad networks
    • Security and fraud prevention providers
    • Hosting and other technology and communications providers
    • Analytics providers
    • Market research providers
    • Marketing service providers
    • Email distribution companies
    • Customer relationship management service providers
    • Staff augmentation and contract personnel
  • Our Affiliates
  • Parties who acquire your Personal Data through an acquisition or other change of control

    • Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part)
  • Data Cooperatives (as defined below)
  • Other parties at your direction, including:

    • Social media services (if you intentionally interact with them through your use of the Services)
    • Third-party business partners who you interact with through the Services
    • Other parties authorized by you

Categories of Personal Data That We Collect

The following chart details the categories of Personal Data that we collect and have collected over the past twelve (12) months. Throughout this Privacy Policy, we will refer back to the categories of Personal Data listed in this chart (for example, “Category A. Personal identifiers”).

Category of Personal Data Personal Data Collected What is the source of this Personal Data?
A. Personal identifiers -Real name
-Postal address
-Unique personal identifier
-Online identifier
-Internet Protocol address
-Email address
-Account name and password (if any)
You /
Affiliates /
Third Parties
B. Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e))) -Name
-Telephone number
-Credit card number
-Debit card number
You /
Affiliates /
Third Parties
C. Protected classification characteristics under state or federal law -Age (40 years or older)
-Marital status
You /
Affiliates /
Third Parties
D. Commercial information -Records of products or services purchased, obtained or considered
-Consuming histories and tendencies
You /
Affiliates /
Third Parties
E. Biometric information We do not collect this category of Personal Data n/a
F. Internet or other similar network activity information -Browsing history
-Search history
-Information on your interaction with our website or advertisements
You /
Affiliates /
Third Parties
G. Geolocation data -General location as enabled by cookies and IP address You /
Affiliates /
Third Parties
H. Sensory data We do not collect this category of Personal Data n/a
I. Professional or employment-related information We do not collect this category of Personal Data n/a
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) We do not collect this category of Personal Data n/a
K. Inferences drawn from other personal information -Profile reflecting personal preferences You /
Affiliates /
Third Parties
L. Age or date of birth -Age
-Date of birth
You /
Affiliates /
Third Parties
M. Personal Data about children under the age of 16 We do not knowingly collect this category of Personal Data n/a

The following sections provide additional information about how we collect your Personal Data.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to use our Services. We may also supplement the information that we collect from you with information received from Third Parties, including Third Parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services, such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services, what actions a visitor performs on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of Cookies by visiting the Google advertising opt-out page at or the Google Analytics Opt-out Browser Add-on at
  • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit .

Information about Interest-Based Advertisements

We serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of Third Parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at or .

How We Use Your Personal Data

We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:

  • To meet or fulfill the reason you provided the information to us
  • To communicate with you about the Services, including Service announcements, updates or offers
  • To provide support and assistance for the Services
  • To create and manage your Account with us, to the extent Account registration is available, or other user profiles
  • To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services
  • To process orders or other transactions
  • To respond to user inquiries and fulfill user requests
  • To improve and develop the Services, including testing, research, analysis and product development
  • To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services
  • To comply with our legal or contractual obligations, resolve disputes and enforce our Terms of Service
  • To respond to law enforcement requests and as required by applicable law, court order or governmental regulations
  • For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”)

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you choose to send us Personal Data by sending us an email, completing a survey or contacting our customer service department, we will keep a record of that communication and may collect and use Personal Data that you provide to us in accordance with this Privacy Policy. If we communicate with you via email, SMS, MMS or other text message (“Text Message”), we may collect information regarding such communications, such as confirmation when you open an email or read a Text Message. We use this information for purposes such as to operate and improve our Services, including our customer service, or as otherwise permitted by this Privacy Policy. If you opt to have promotional offers from us sent to your mobile device, we may send you Text Messages regarding such promotional offers to the telephone number you provided to us. To opt out of receiving promotional Text Messages from us, reply “STOP” to any such message.

How We Share Your Personal Data

Disclosures of Personal Data for a Business Purpose

We disclose your Personal Data to service providers and other parties for the following business purposes:

  • Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance with this specification and other standards
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality
  • Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction
  • Performing services on our behalf, including maintaining or servicing any accounts you may be able to register with us, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services or providing similar services on behalf of the business or service provider
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture or control, or that was manufactured for us

We disclose, and over the past twelve months have disclosed, the following categories of Personal Data to service providers or other parties for the business purposes listed above:

  • Category A. Personal identifiers
  • Category B. Customer records identified by state law
  • Category C. Protected classification characteristics under state or federal law
  • Category D. Commercial information
  • Category F. Internet or other similar network activity information
  • Category G. Geolocation data
  • Category K. Inferences drawn from other Personal Data
  • Category L. Age or date of birth

Sales of Personal Data

In this section, we use the term ‘sell’ as it is defined in the CCPA. We sell your Personal Data, subject to your right to opt out of these sales (see the “Exercising Your Rights” section below for information about how to opt out).

As described above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section.

We may sell your Personal Data to the following categories of third parties:

  • Data Cooperatives:

    • We may share your name and shipping address, along with certain information regarding your transactions with us (including transaction date, value, amount, type and order ID) with providers of data cooperative and marketing services that serve members-only groups of retailers (such services, “Data Cooperatives”, and such members, the “Data Cooperative Members”). Through the Data Cooperatives, lists of prospective customers are shared with their respective Data Cooperative Members. No individual transactional information is shared with Data Cooperative Members. We may engage Data Cooperatives for the commercial purpose of better marketing to existing and prospective customers. More specifically, we may share this information with Data Cooperatives so that they can analyze your buying patterns and determine what sort of products are likely to appeal to you, and Data Cooperatives share your name and shipping address with Data Cooperative Members who may offer such products.
    • You may receive information and materials regarding products offered by Data Cooperative Members. The list of retailers in such Data Cooperatives changes frequently, but includes retailers in the clothing, collectables, food and wine, gardening, gadgets and entertainment, health and beauty, household goods and/or home interiors categories. You agree to the sharing of the above-described information with Data Cooperatives and Data Cooperative Members and to be eligible to receive such materials if you are able to, and do, register an account with us.
    • If you decide you would like to stop sharing this information and receiving materials, you can email us at
  • Advertisers

We sell, and over the past twelve months have sold, the following categories of your Personal Data to third parties:

  • Category A. Personal identifiers
  • Category B. Customer records identified by state law
  • Category D. Commercial information
  • Category F. Internet or other similar network activity information

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, all credit card information and shipping information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to one or more third party Payment Processor(s). Your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information) is used and stored by the applicable Payment Processor, and use and storage of that information by the Payment Processors is governed by each such Payment Processors’ applicable terms of service and privacy policy. Currently, we use Stripe, Inc. as a Payment Processor, and you may access Stripe’s Terms of Service at and their Privacy Policy at , or any of its successor sites. To the extent you are able to and do have an Account, you should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism, limiting access to your computer or device and browser, and signing off after you have finished accessing your Account. Although we work to protect the security of all data that we hold in our records (including, to the extent we offer users the opportunity to register an Account with us, the security of such Account), please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as you have an open Account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from individuals under 18 years of age, and we do not allow individuals under 18 years of age to use the Services without the consent of their respective parents or legal guardians; if you are an individual under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data without the consent of your parent or legal guardian. If we learn that we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided us with Personal Data, please contact us at

California Resident Rights Under the CCPA

If you are a California resident, you have the rights set forth in this section under the CCPA. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at


You have the right to request certain information about our collection and use of your Personal Data during the 12 month-period prior to such request. Upon any such request, we will provide you with the following information:

  • The categories of Personal Data that we have collected about you
  • The categories of sources from which that Personal Data was collected
  • The business or commercial purpose for collecting or selling your Personal Data
  • The categories of third parties with whom we have shared your Personal Data
  • The specific pieces of Personal Data that we have collected about you

If we have disclosed or sold your Personal Data to any third parties for a business purpose during the 12-month period prior to your request, we will identify the categories of Personal Data shared with or sold to each category of third party recipient.


You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action that you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf.

Personal Data Sales Opt-Out

You have the right to opt out of the sale of your Personal Data. You can opt out using the following methods:

  • Submitting an Opt-Out Form
  • Emailing us at

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

We do not knowingly sell the Personal Data of minors under 16 years of age, with or without affirmative authorization. If you believe that a child under 16 years of age may have provided us with Personal Data to sell, please contact us at

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at with the subject line “Nevada Do Not Sell Request” and providing us with your name and, to the extent you have provided us with your email address through use of the Services or, if available, registration of an account with us, such email address.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time in connection with any such improvements, but we will alert you to any such changes by placing a notice on , by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

  • 75 Varick St., Floor 9, New York, NY 10013

Effective Date: January 23, 2021