Effective January 1, 2020
Soon Skincare (herein, “we,” “us” or “Soon Skincare”) provides this privacy policy to describe how we use Personal Information (defined below) that you provide through www.soonskincare.com, blog and other locations where this policy is posted (herein, the “Site”). Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personal Information.
What Personal Information do we collect via the Site?
We collect “Personal Information,” which is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, to an individual or household. When you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers on Stripe and PayPal), email address, and phone number. We refer to this information as “Order Information.” The Personal Information we have collected from visitors to our Site in the last 12 months are presented below.
- Identifiers, which may include name, address, online identifier or username, Internet Protocol address, or email address. These are sourced directly from you or indirectly from you (e.g., from observing your actions on the Site). They are used to fulfill or meet the reason you provided the information, to contact you in relation to our Site, to respond to an inquiry, for product and service improvement, to screen for potential risk or fraud, or to process an order. For example, when you create an account, you provide your first and last name, email address, and other identifying information. We disclose this information for business purposes to internet service providers, administrative service providers, and payment processors.
- Personal information categories contained in customer records, which may include name, address, telephone number, bank account number, credit card number, debit card number, or any other payment and financial information. We source this information directly from you. We use this information to fulfill or meet the reason you provided the information, to contact you in relation to our Site, to respond to an inquiry, to screen for potential risk or fraud, or process an order. For example, we need your payment information when you purchase services from us. We disclose this information for business purposes to internet service providers, administrative service providers, and payment processors.
- Characteristics of protected classifications, such as age or gender. We source this information directly from you. We use this information to fulfill or meet the reason you provided the information or to provide relevant services. For example, we may use this information for targeted advertising. We do not disclose this information to third parties.
- Commercial information, which may include records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We source this information directly from you. We use this information to fulfill or meet the reason you provided the information, to contact you in relation to our Site, to screen for potential risk or fraud, and to respond to an inquiry or process an order. For example, we keep track of your purchases to create a purchase history. We disclose this information for business purposes to internet service providers, administrative service providers, and payment processors.
- Internet, technical or other similar network activity, which may include usage and browsing history; device information, including device properties; search history; information on your interaction with our Site; and error logs. We source this information directly or indirectly from you (e.g., from observing your actions on our Site). We use this information to fulfill or meet the reason you provided the information, to screen for potential risk or fraud, or to improve our Site. We disclose this information for business purposes to administrative service providers, data analytics providers, and internet service providers. Please see our Cookie Notice by clicking here for more information on our collection, use, and opt-out options.
- Inferences drawn from other Personal Information, which may include a profile reflecting a person’s preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We source this information directly or indirectly from you, (e.g., from observing your actions on our Site). We use this information to fulfill or meet the reason you provided the information. We do not disclose this information to third parties.
We have sold the following categories of Personal Information in the preceding 12 months: Identifiers; Personal Information categories contained in customer records; Commercial Information; and Internet, technical or other similar network activity.
We have disclosed the following categories of Personal Information for a business purpose in the preceding 12 months: Identifiers; Personal Information categories contained in customer records; Commercial Information; and Internet, technical or other similar network activity.
We collect
- First and last name
- Email address
- Mailing address
- Phone number
- Date of birth
- Credit card information
- Billing information
- IP address
- Data collected via cookies, web beacons or other technical mechanisms, such as the products or services that you view
- Demographic information, such as your gender, age, zip code and interests
- Geolocation data, if you choose to allow our Site to track your location or if your Personal Information indicates a certain geographic location
Your decision to provide any Personal Information is voluntary. However, please note that, if you do not provide certain Personal Information, we may not be able to accomplish some purposes outlined in this Privacy Statement and you may not be able to use or access certain services on our Site.
When do we collect Personal Information?
We collect Personal Information from you when you navigate our Site, register on our Site, place an order, subscribe to a newsletter, respond to a survey, fill out a form, Use Live Chat, Open a Support Ticket or enter information on our Site. Some specific examples of when we collect Personal Information include the following:
- When ordering or registering for an account on our Site, as appropriate, you may be asked to enter your name, email address, phone number or other details to help you with your experience.
- When you sign up for newsletters.
- When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
- When you provide us with feedback on our products or services.
- We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
- Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”.
How do we use your Personal Information?
We may use the Personal Information collected on the Site primarily for the following purposes:
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To use for account purposes.
- To allow us to better service you in responding to your customer service requests.
- To quickly process your transactions.
- To send periodic emails regarding your order or other products and services.
- To follow up after correspondence (live chat, email or phone inquiries).
- To keep track of any purchase made by you, or to otherwise deliver products that you purchase;
- To alert you to special offers, updated information and other new services from Soon Skincare, or other third parties, or to forward promotional materials;
- To complete a transaction or service requested by you;
- To market products or services that we believe may be of interest to you, or which may be available in your area of residence;
- To conduct marketing analysis and deliver you with content or features that we believe may assist you or otherwise be of interest to you;
- To provide you with recommendations for products or services that are based on your interests, your age or your location;
- To fulfill the terms of a promotion (e.g., contests, sweepstakes, etc.);
- To ensure the Site is relevant to your needs;
- To help us create and publish content most relevant to you;
- To administer our Site, or anticipate and resolve problems with the Site;
- To notify you about a material change to this privacy policy or the Terms of Use Agreement, if necessary;
- Screen for potential risk or fraud;
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services;
- To protect and improve our Site;
- To allow you access to limited-entry areas of the Site; and
- To contact you in response or if you inquire about the status of an order.
We will not collect additional Personal Information or use the Personal Information we have collected for materially different, unrelated, or incompatible purposes without providing you notice. This privacy policy in no way restricts or limits our collection and use of information that does not constitute Personal Information, nor does it restrict or limit our collection and use of aggregate data or de-identified information, and we may share it with third parties for a variety of purposes, including to help us better understand our customer needs, and to improve our Site and services for advertising and marketing purposes.
How do we protect your Personal Information?
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any Personal Information you transmit to us and you understand that any Personal Information that you transfer is done at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use firewalls to protect your Personal Information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such Personal Information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing Personal Information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of this Site. We may post a notice on our Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Do we use 'cookies'?
Yes, as noted above, we collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Additionally, we utilize Google Analytics. Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. Please see more information about Google Analytics in the Third Party Advertising section below.
We use Google AdSense Advertising on our website.
Google, as a third-party vendor, uses cookies to serve ads on our Site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our Site and other Sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.
You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We have implemented the following:
- Remarketing with Google AdSense
- Google Display Network Impression Reporting
- Demographics and Interests Reporting
- DoubleClick Platform Integration
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, some features will be disabled that make your Site experience more efficient and may not function properly.
However, you will still be able to place orders.
Third Party Advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We use advertisers, third party ad networks and other advertising companies to serve advertisements on and off our websites. These third parties use cookies and similar technologies to collect or receive Personal Information from our websites and elsewhere on the Internet and use that Personal Information to provide you with targeted ads. The Network Advertising Initiative offers a means to opt-out of a number of advertising cookies. Please visit http://optout.networkadvertising.org/?c=1 to learn more.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
We use Facebook Analytics to measure your use of our Sites, tailor our Sites to your interests, and improve our products and services. Please note, Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at Facebook.com/about/privacy/. Please click here if you would like to withdraw your consent.
To help facilitate the delivery of relevant content, we use Google Analytics. Google Analytics uses cookies to report on user interactions on our and others' websites. We use the data collected for optimizing marketing, refining advertising and/or programming strategies, and generally improving user experience. For more information about Google Analytics and how it collects and processes data, please visit: https://policies.google.com/technologies/partner-sites and instructions on opting out of Google Analytics using a specific plug-in is available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt-out is specific to Google activities and does not affect the activities of other ad networks or analytics providers that we may use.
International Transfer of Personal Information
If you choose to provide us with Personal Information, we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information to the United States which does not have the same data protection laws as the EU and by providing your Personal Information you consent to:
- the use of your Personal Information for the uses identified above in accordance with this privacy policy; and
- the transfer of your Personal Information to the United States as indicated above.
Do we share your Personal Information?
When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performance of the contract. We may share or disclose your Personal Information to the following categories of third parties in the following instances:
- To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your Personal Information for research, administrative and/or internal business purposes. These parties may use this Personal Information to contact you with an offer or advertisement related to a product or service, or they may use such Personal Information for their own research, administration or business purposes. When we share your Personal Information with these parties, we seek to ensure that the party with whom we share the Personal Information will maintain it securely and in accordance with the applicable laws.
- To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Site and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the Personal Information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Site will have access to users' Personal Information, if you do not wish for our unaffiliated third-party service providers to have access to your Personal Information, please do not register or submit any Personal Information to us.
- To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, or act in urgent circumstances to protect the personal safety of our end users.
- To third parties as part of any direct or indirect corporate reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or a part of our assets.
- To track and analyze non-identifying and aggregate usage and volume statistical Personal Information from our visitors and customers and provide such Personal Information to third party data analytics providers.
- To protect against potential fraud, we may verify with third parties the information collected from the Site. In the course of such verification, we may receive Personal Information about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen.
- For direct or indirect reorganization. We may share or transfer your information in the course of any direct or indirect reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or a part of our assets. Your information may be shared following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, your information would remain subject to this privacy policy or a privacy policy that, at a minimum, protects your privacy to an equal degree as this privacy policy.
Except as described in this privacy policy or at the time we request the Personal Information, we do not otherwise use, share or otherwise disclose your Personal Information to any third parties.
Some specific examples of where we may disclose Personal Information include:
- We use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
- We use services provided by Google as described in this policy.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for Personal Information we receive, or to otherwise protect our rights.
Third-party links
Occasionally, at our discretion, we may include or offer third-party products or services on our Site, which may contain links to other web sites. These third-party web sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked web sites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these web sites.
Changes to this Policy
We reserve the right to change this privacy policy from time to time. When we do, we will also revise the “effective” date at the top of this privacy policy. For any material changes to this privacy policy, we will attempt to provide more prominent notice and/or obtain your consent before implementing the change by sending a notice to the primary email address specified in your account and/or by placing a prominent notice on the Site.
Your California Privacy Rights
From January 1, 2020, California consumers have the following rights:
• Right to know
You have the right to request information about the categories and specific pieces of Personal Information we have collected about you, as well as the categories of sources from which such Personal Information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such Personal Information. You have the right to request information about our sale or disclosure for business purposes of your Personal Information to third parties in the preceding 12 months.
• Right to delete
You have the right to request the deletion of your Personal Information.
• Right to opt-out of sale
You have the right to opt out of the sale of your Personal Information to third parties. We do sell Personal Information, but we do not knowingly sell the Personal Information of minors under 16 years of age. You may opt-out of the sale of your Personal Information by using our webform here.
• Right to non-discrimination
You have the right to not be discriminated against for exercising any of these rights.
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below and put “Shine the Light” in the subject line of your request.
If you would like to exercise one or more of the rights above, please contact us using the contact information provided below. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
We may need to confirm your verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
How does our Site handle Do Not Track signals?
The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.
Children
We do not knowingly collect Personal Information from children under the age of 13. If we learn we have such information in our files, we will delete it.
We do not specifically market to children under the age of 13 years old. Additionally, we do not sell the Personal Information of minors under the age of 16.
Communications & Opt-Outs
We may send you communications or data regarding the Site, including but not limited to (i) notices about your use of the Site, including any notices concerning violations of use, (ii) updates, and (iii) information or materials regarding transactions, products and/or services purchased or selected by you. By using and/or registering with the Site, you agree to receive this type of transactional communication from us. To remove yourself from our email list, please email hello@soonskincare.com or select “Unsubscribe” in footer of the marketing email
Note however, that this opt-out option is for those email messages that may be more commercial in nature, as they may advertise a feature of our Site or services, a product or service we believe that you may be interested in, or otherwise discuss a marketing campaign or promotion offered by us. We give you the opportunity to opt-out of receiving these commercial emails from us by following the opt-out instructions provided in the message. You may not, however, opt-out of transactional messages tied to your orders and specific requests.
Data retention
When you place an order provide Personal Information through the Site, we will maintain your Personal Information for our records only for as long as necessary to fulfill the purpose for which it is collected.
Contacting Us
If there are any questions regarding this privacy policy, you may contact us using the information below.
Soon Skincare, ATTN: Privacy Compliance Officer
PO Box 80491
Rancho Santa Margarita, CA 92688
hello@soonskincare.com