PRIVACY AND SECURITY POLICY

This Privacy Policy describes the current policies and practices of Duluth Holdings Inc. d/b/a Duluth Trading Company (“DTC”) with regard to Personal Data collected by DTC on its website, www.duluthtrading.com (the “Website”). “Personal Data” refers to personally identifiable information about you (such as your full name, birth date, e-mail address or mailing address, phone number and any other information that can be used to identify or contact you).

This Privacy Policy is periodically updated. Please check back on a regular basis for any changes.

Effective Date: April 27, 2009

The only Personal Data DTC currently collects is the Personal Data that is voluntarily provided to DTC by users of DTC’s services. There are several places on the Website where you may enter Personal Data to receive products or services from DTC. For example:

Promotional Email Newsletters. You must enter your email address and first and last name to be added to our distribution list for promotional email newsletters.

Wish List. You must enter your email address and first and last name to create a “wish list” of items in our online store. You may also enter your postal address, city, state, zip and country in connection with the wish list feature, but you do not need to do so to use the wish list.

Catalog Request. You must enter your email address, first and last name, postal address, city, state, zip and country to request a catalog. You may also enter your company name and phone number.

Shipping Information. You must enter your first and last name, postal address, city, state, zip, country and phone number so that we may ship your order. You may also enter your company name and fax number.

Billing Information. You must enter your first and last name, postal address, city, state, zip, country and phone number so that we may process your order. You may also enter your company name and fax number.

Payment Information. You must enter your credit card number, the type of credit card you are using and the name on your credit card so that we may process payment for your order.

Other data that does not qualify as Personal Data because it cannot be used to contact or identify you (“Non-Personal Data”) may also be automatically collected. For example, DTC and its business partners may use technology to automatically collect Non-Personal Data about the use of the DTC Website. This technology is used to track how many users access the Website, the date and time of their visits, the length of their stays, and which pages they view. We may also use technology to determine which web browsers users use and the address from which they accessed the Website. The information collected using this technology does not identify any user personally and is thus all Non-Personal Data that simply enables DTC and its business partners to compile statistics about users and their use of the Website. We use this Non-Personal Data and may share it with third parties to improve the content and functionality of the websites, to better understand our customers and markets, and to improve our products and services.

3rd Party Advertising
We may use third party advertising companies to serve ads for us, using Non-Personal Data. These third parties may employ cookies and action tags (also known as single pixel gifs) to measure advertising effectiveness. They may also use this technology to serve specialized or relevant advertising content and/or recommendations to you on the Site or on a third party’s website. Any information that these third parties collect via cookies and action tags is completely anonymous and does not contain any personal contact information. If you would like more information about this practice and your choices, including how to opt-out, click here.

What is a "3rd party ad network?"
Many of the banner ads displayed on Web pages are not selected and delivered by the Website visited by a consumer, but by network advertising companies that manage and provide advertising for numerous unrelated Websites. These companies are referred to as "3rd party ad networks."

We use this Non-Personal Data and may share it with third parties to improve the content and functionality of the websites, to serve relevant advertising messages and measure advertising effectiveness, to better understand our customers and markets, and to improve our products and services. Authorized third parties are contractually bound to secure the data we transfer. We will never transfer any sensitive information.

We may store certain information from your web browser using “cookies.” A cookie is a piece of data stored on the user’s computer tied to information about the user. We may use session-ID cookies to confirm that registered users are logged in. These cookies would terminate once the user closes the web browser. We may also use persistent cookies that store certain Personal Data you already provided to us to make it easier for you to use certain features of the Website, such as the shopping cart. Cookies are used as a convenience feature for the user. You can remove or block cookies using the settings in your browser if you want to disable them.

DTC uses the Personal Data collected on the DTC Website to provide you with the requested services or products. For example, we use the shipping information to ship you the products you ordered and we use the billing and payment information to process the payment for your order. If you request a catalog or email newsletter subscription, we use the Personal Data you submit to mail or email the catalog or newsletter to you.

DTC may also use your Personal Data to contact you for a variety of reasons, such as but not limited to notifying you about upcoming events, offering you additional products or services, or requesting your feedback on our products or services. We also use the data you submit, other than your payment information, for internal marketing purposes such as customer segmentation and analysis so that we can continuously improve our products, services and marketing efforts.

DTC may disclose Personal Data to third parties under certain circumstances. DTC may disclose Personal Data to third parties if a user has requested that DTC do so, or if it is necessary to provide you with the services you requested.

We occasionally make the Personal Data collected for catalog requests, shipping and billing information (but not payment information) available to carefully screened companies and organizations whose products and activities might be of interest to you. If you prefer not to have your Personal Data shared with any other companies or organizations, just let us know. We will gladly accommodate your request. Send us an email at customerservice@duluthtrading.com, contact us by mail at 170 Countryside Dr., Belleville, WI 53508, or call 1-800-505-8888.

If DTC is acquired by or merged into another entity, or all or a portion of DTC’s assets are sold or otherwise transferred to another entity, DTC may disclose Personal Data to that entity. DTC may also disclose Personal Data if required or authorized to do so by law or an industry reporting authority.

DTC takes reasonable precautions to safeguard personal data from loss, misuse, tampering, destruction and unauthorized access. While such security measures provide reasonable protections against unauthorized access, they provide no guarantee that your Personal Data will not be compromised.

At your request, DTC will allow you to access or review your Personal Data and correct any errors. You may be required to provide identifying information and/or answer some security questions to verify your identity. DTC may charge a reasonable fee for access to your Personal Data.

DTC allows you to choose not to have your Personal Data disclosed to third parties or used for a purpose incompatible with the purpose for which it was originally collected. If you do not want your Personal Data disclosed to third parties or used for purposes other than providing you with the services you requested, you may contact us at customerservice@duluthtrading.com, contact us by mail at 170 Countryside Dr., Belleville, WI 53508, or call 1-800-505-8888.

This Privacy Policy applies only to Personal Data, as defined above. The DTC Website may contain hyperlinks to websites that are not operated or controlled by DTC. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. DTC does not control these websites and is not responsible for their data practices. We urge you to review the privacy policy posted on any website you visit before using the website or providing any Personal Data about yourself.

If you have any questions about this Privacy Policy or concerns about the way DTC processes your Personal Data, please email us at customerservice@duluthtrading.com, contact us by mail at 170 Countryside Dr., Belleville, WI 53508, or call 1-800-505-8888.