Last updated: April 5, 2022
Brandefy, Inc. ("Us" or "We") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website or our mobile application, including the products and services that we offer on them (collectively, the “Website”).
This policy applies to information we collect on the Website, in email, text and other electronic messages and communication with the Website, through downloads of the mobile app and/or desktop applications, when you interact with our advertising and applications on other third party websites (if such advertising includes links to this policy), and through any other interaction with us. This policy does not apply to information we collect offline or through other website operated by a third party or information collected by a third party that may link or be accessible from our Website.
Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13 do not use or provide any information on this Website register on the Website, make any purchases through the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org or call 804-690-3900.
California residents may have additional rights regarding the collection and sale of their personal information. Please see Your California Rights for more information.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information by which you may be personally identified such as name, address, email, account information, phone number and other identifying information (“personal information”), and other information that is about you but does not identify you such as your internet connection, purchase or browsing history and usage details (“non personal information”).
We collect this information directly when you provide it to us or automatically when you visit, browse or navigate the Website. Information we collect automatically may include usage details, IP addresses, and information collected through cookies.
Information You Provide to Us
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting reviews or other feedback or material, or requesting further services from us. We may also ask you for information when you participate in a promotion sponsored by us, or when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Website and/ or of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
You also may provide information to be published or displayed, such as Reviews (defined in the Terms of Service, feedback, comments or other content on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Content"). Your User Content is posted on and transmitted to others at your own risk.
Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users of the Website with who access your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our Website or app and other communication data and the resources that you access and use on the Website or app. We also may collect information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). This information helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it, such as when you request to receive newsletters, emails or other updates and marketing.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide through it.
- To allow you to participate in interactive features on our Website such as surveys.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
- Fulfill legal and regulatory requirements.
- Protect our rights or property or our Users.
We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please opt out of receiving such information either by hitting “unsubscribe” on our emails, contacting us at email@example.com or calling 804-690-3900.
Disclosure of Your Information
- To our parent company, subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
- To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, to enforce or apply our Terms or other agreements, including for billing and collection purposes. Further, if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us or others, we will disclose such information.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from Brandefy. If you do not wish to have your information used by us to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
California residents may have additional personal information rights and choices. Please see Your California Rights for more information.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at email@example.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our California Consumer Privacy Act (“CCPA”) Policy here:
A. Information We Collect. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”). We collect this information for “business purposes” which the CCPA defines as the use of personal information reasonably necessary to achieve a business’s operational purposes. The following categories of personal information are collected when you shop for products on Skincallco.com (“Website”).
- Identifiers such as name, address, email, phone number, your device’s IP address, software, and identification numbers associated with your device.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Protected classification characteristics such as gender.
- Commercial information such as your purchase history.
- Internet information regarding your browsing or search history, any webpages visited before the Website, the length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.
- Geolocation provided you have enabled your device to allow the Website to collect such information.
- Audio recordings of your voice provided you have called us, as permitted under applicable law.
- Professional and employment-related information.
- Inferences about your preferences, behaviors, and characteristics.
Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or other information excluded from the CCPA’s scope.
B. How We Use Your Information. We do not and will not, sell any of your personal information to any third party, however, we may use your personal information for the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a product or service, or to receive emails or marketing materials, we will use it to fulfill that purpose.
- To provide, support, personalize, and develop our websites, products, and services and to create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests.
- To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our customers is among the assets transferred.
- We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
C. How We Share Your Information. We may disclose your information to a third party for a “business purpose”. 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 performing the contract. We may also share your personal information with service providers or data aggregators.
In the preceding 12 months we have disclosed personal information for a business purpose to our parent company, Brandefy, Inc. and to data aggregators Specifically we have disclosed your email to our parent company for the business purposes of providing, supporting, personalizing, and developing our Websites, products, and services and creating, maintaining, customizing, and securing your account with us, personalizing your Website experience, and delivering content and product and service offerings relevant to your interests.
Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes
In the previous 12 months, we have not sold consumers’ personal information.
D. Your Rights. California residents have additional rights regarding their personal information under the CCPA including the rights of Access and Data Portability and Deletion.
Right of Access and Data Portability: You may request that we disclose information to you about our collection of personal information over the past 12 months. Once a request is received and we get verifiable confirmation of that request, we will disclose:
- What categories of personal information we collected
- The categories of sources of that personal information we collected
- The business or commercial purpose for collecting (or selling) that personal information
- The categories of third parties that we share the personal information with
- The specific kinds or pieces of information that we collected about you
- Whether we sold or disclosed your personal information for a business purpose, including two separate lists disclosing: 1) sales, identifying the personal information categories that each category of recipient purchased; and 2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights. You may request that we delete any of your personal information that we have collected and retained, with certain exceptions. Once we get a request and can obtain confirmation of that verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either calling us at 804-690-3900 or emailing us at firstname.lastname@example.org. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a consumer request to know twice within a 12-month period. Your request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
- You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
- We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
Timing. We make best efforts to respond to a verifiable consumer request within forty-five (45) days of such request. If we need additional time (up to a total of 90 days from when the request is received) we will communicate with you in writing regarding the reason for and the timing of the extension.
- Disclosures that we provide are only for twelve (12) months preceding the request of the verifiable consumer request. Any response we send will also provide an explanation if why we cannot accommodate a request. If you send us a data portability request, we will provide your personal information in a format that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
- There is no fee to process or respond to a verifiable consumer request unless we determine that it is excessive, repetitive or otherwise unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
E. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any such offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
F. Changes to Our Privacy Notice. We reserve the right to amend this policy at our discretion and at any time. When changes are made, we will post the updated notice on the Website as well as an updated effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.
G. Contact Information. If you have any questions or comments about this policy please contact us at email@example.com or call us at 804-690-3900.
Additionally, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our mobile app that 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 send an email to firstname.lastname@example.org.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
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