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TULA COOKIE POLICY

Last Updated: December 14, 2022

California Privacy Policy
European Privacy Policy

TULA Life, Inc. and its subsidiaries and affiliates (“TULA,” “we,” or “us”) respect your privacy. TULA owns, licenses, and operates certain websites, applications, and platforms (each a “Site”) that are primarily designed to sell beauty products, goods, and services (collectively, the “Services”). This Cookie Policy explains our use of “cookies” and other tracking technologies, including, but not limited to, web beacons, pixels, clear gifs, and other similar technologies (collectively, “Cookies and Other Tracking Technologies”) that are employed on our Sites

PLEASE READ THIS COOKIE POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SITE, YOU ARE CONSENTING TO THE TERMS OF THIS COOKIE POLICY AND TULA’S TERMS & CONDITIONS AND PRIVACY POLICY.

To prevent TULA FROM using certain Cookies and Other Online Tracking Technologies, YOU CAN CHANGE YOUR BROWSER SETTINGS IN ACCORDANCE WITH THE INSTRUCTIONS BELOW OR BY USING OUR COOKIE management TOOL AVAILABLE ON THE FOOTER OF OUR SITE.

What are Cookies and Other Online Tracking Technologies?

Cookies are small files that are downloaded to your device when you visit a website. The cookie then sends information back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Other types of tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Sites. Accordingly, Cookies and Other Tracking Technologies allow our Sites to recognize your device and track your activities and preferences, thereby allowing you to navigate between pages efficiently and to generally improve the user experience. The information provided below about cookies also applies to the other tracking technologies referenced above (i.e., web beacons, pixels, clear gifs, and other similar technologies). You can find more information about cookies at www.allaboutcookies.org.

Cookies are often categorized by function. We use four types of cookies by function on our Sites:

Name Description
Essential Cookies These are cookies that are strictly necessary for the functioning of a website or for performing services that an individual user has requested. For instance, these cookies are necessary to allow us to operate our Sites so you may access them as you have requested. These cookies let us recognize that you have created an account and have logged into that account to access the Sites. They also include cookies that enable us to remember your previous actions within the same browsing session.
Analytical/Performance Cookies These cookies collect information and statistics about how individuals use the Sites (e.g., which webpages or other portions of the Sites visitors go to most often). These cookies are used to improve how the Sites function.
Functional Cookies These cookies allow the Sites to remember choices users make and to provide enhanced, personalized features. For example, within our Sites, these cookies remember users’ language preferences.
Targeting/Advertising Cookies These cookies are used to deliver advertisements relevant to a specific user of the Sites. They remember that a user has visited a website and share this information with other organizations such as advertising vendors.

Cookies can also be categorized by how long they remain on your device and by who puts the cookie there. There are four broad categories of duration and placement cookies that we use on the Sites:

Name Description
Persistent Cookies Persistent cookies remain on your device until deleted manually or automatically.
Session Cookies Session cookies remain on your device until you close your browser, at which time they are automatically deleted.
First-Party Cookies These cookies are placed by the party operating the website or service. For example, any cookies we place on your computer from our Sites are first-party cookies.
Third-Party Cookies These cookies are placed on a website or service by a party that does not own or operate the website or service.

How do our Sites use Cookies and Other Tracking Technologies?

We use Cookies and Other Tracking Technologies to identify you and your interests, to remember your preferences, to facilitate our marketing, and to track your use of our Sites. We also use Cookies and Other Tracking Technologies to control access to certain content on our Sites, to protect the integrity and security of the Sites, to process any requests that you make of us, and as otherwise set forth herein and in TULA’s Privacy Policy. To administer our Sites and for research purposes, TULA may, from time to time, contract with third-party service providers to track and analyze statistical usage and volume information from our Sites. These third-party service providers use persistent cookies to help us improve the user experience, manage the content on our Sites, and analyze how users navigate and utilize the Sites. The Cookies and Other Tracking Technologies we use on the Sites are as follows:

Cookie Description Duration Type
iplocate This cookie assists in identifying general location of user of the Site for compliance purposes. Session Functional
__cf_bm This cookie, set by Cloudflare, is used to support Cloudflare Bot Management. 29 minutes Functional
_gcl_au Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services. 3 months Analytics
test_cookie The test_cookie is set by doubleclick.net and is used to determine if the user's browser supports cookies. 14 minutes Advertisement
ad-id The ad-id cookie is provided by Amazon Advertising for tallying user actions by tracking ad clicks on other websites, to provide targeted content. 7 months 18 days Analytics
_ga The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. 2 years Analytics
_gid Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously. 1 day Analytics
ad-privacy Provided by amazon-adsystem to make advertising messages more relevant to the users and their interests. 5 years 1 month 20 days Advertisement
_ga_0SNN48HE0B This cookie is installed by Google Analytics. 2 years Analytics
c This cookie is set by Rubicon Project to control synchronization of user identification and exchange of user data between various ad services. 1 year Advertisement
checkForPermission This cookie is set by Beeswax to determine whether the user has accepted the cookie consent box. 9 minutes Necessary
CMID Casale Media sets this cookie to collect information on user behavior, for targeted advertising. 1 year Advertisement
CMPS CMPS cookie is set by CasaleMedia for anonymous user tracking based on user's website visits, for displaying targeted ads. 3 months Advertisement
CMPRO CMPRO cookie is set by CasaleMedia for anonymous user tracking, and for targeted advertising. 3 months Advertisement
uuid2 The uuid2 cookie is set by AppNexus and records information that helps in differentiating between devices and browsers. This information is used to pick out ads delivered by the platform and assess the ad performance and its attribute payment. 3 months Advertisement
bku Bluekai uses this cookie to build an anonymous user profile with data like the user's online behaviour and interests. 6 months Advertisement
bkpa Set by Bluekai, this cookie stores anonymized data about the users' web usage in an aggregate form to build a profile for targeted advertising. 6 months Advertisement
bito This cookie is set by Beeswax for advertisement purposes. 1 year 1 month Advertisement
bitoIsSecure Beeswax sets this cookie for targeting and advertising. The cookie is used to serve the user with relevant advertisements based on real time bidding. 1 year 1 month Advertisement
UID Scorecard Research sets this cookie for browser behaviour research. 1 month Analytics
tuuid The tuuid cookie, set by BidSwitch, stores an unique ID to determine what adverts the users have seen if they have visited any of the advertiser's websites. The information is used to decide when and how often users will see a certain banner. 1 year Advertisement
c This cookie is set by Rubicon Project to control synchronization of user identification and exchange of user data between various ad services. 1 year Advertisement
tuuid The tuuid cookie, set by BidSwitch, stores an unique ID to determine what adverts the users have seen if they have visited any of the advertiser's websites. The information is used to decide when and how often users will see a certain banner. 2 years Advertisement
c This cookie is set by Rubicon Project to control synchronization of user identification and exchange of user data between various ad services. 2 years Advertisement
A3 No description 1 year Other
ab Owned by agkn, this cookie is used for targeting and advertising purposes. 1 year Advertisement
anj AppNexus sets the anj cookie that contains data stating whether a cookie ID is synced with partners. 3 months Advertisement
tuuid_lu This cookie, set by BidSwitch, stores a unique ID to determine what adverts the users have seen while visiting an advertiser's website. This information is then used to understand when and how often users will see a certain banner. 2 years Advertisement
tuuid_lu This cookie, set by BidSwitch, stores a unique ID to determine what adverts the users have seen while visiting an advertiser's website. This information is then used to understand when and how often users will see a certain banner. 1 year Advertisement
IDSYNC This cookie is set by Yahoo to store information on how users behave on multiple websites so that relevant ads can be displayed to them. 1 year Advertisement
tuuid_li This cookie, set by BidSwitch, stores a unique ID to determine what adverts the users have seen while visiting an advertiser's website. This information is then used to understand when and how often users will see a certain banner. 3 months Advertisement
um Set by AddThis for registering the user's sharing of content through social media. 3 months Advertisement
umeh This cookie is set by Improve Digital to track visitors on multiple websites, in order to present relevant advertisements based on the visitor's preferences. 3 months Advertisement
demdex The demdex cookie, set under the domain demdex.net, is used by Adobe Audience Manager to help identify a unique visitor across domains. 5 months 27 days Analytics
id Set by Google DoubleClick, this cookie is used to create user profiles to display relevant ads. 1 year 1 month Advertisement
mdata This cookie is used by Media Innovation group and registers a unique ID to identify a visitor on their revisit, in order to show them relevant ads. 1 year 1 month Advertisement
ov This cookie is set by the provider mookie1.com. This cookie is used for serving the user with relevant content and advertisement. 1 year 1 month Advertisement
dpm The dpm cookie, set under the Demdex domain, assigns a unique ID to each visiting user, hence allowing third-party advertisers to target these users with relevant ads. 5 months 27 days Advertisement
sambapxid This cookie is set by the provider Samba TV. This cookie is used for tracking the visitor across multiple devices including TV inorder to retarget the visitor through multiple channels. 1 year 1 month Other
audience SpotXchange sets this cookie as a unique ID that tracks audiences internally. The cookie is used to limit the number of repetitive ads shown to the user. 1 month Advertisement
_uid AddThis sets this cookie to enable the visitors to share the web pages on social platforms via sharing buttons on the website. 5 months 27 days Functional
test_cookie The test_cookie is set by doubleclick.net and is used to determine if the user's browser supports cookies. 14 minutes Advertisement
UID Scorecard Research sets this cookie for browser behaviour research. 2 years Analytics
bku Bluekai uses this cookie to build an anonymous user profile with data like the user's online behaviour and interests. 6 months Advertisement
bkpa Set by Bluekai, this cookie stores anonymized data about the users' web usage in an aggregate form to build a profile for targeted advertising. 6 months Advertisement
uid This is a Google UserID cookie that tracks users across various website segments. 2 months Analytics
IDE Google DoubleClick IDE cookies are used to store information about how the user uses the website to present them with relevant ads and according to the user profile. 1 year 24 days Advertisement
PugT PubMatic sets this cookie to check when the cookies were updated on the browser in order to limit the number of calls to the server-side cookie store. 1 month Functional
SEUNCY This cookie is used for registering a unique ID to identify the visitor's device on their revisit to the website. 1 year Analytics
pt No description available. 2 years Other
KADUSERCOOKIE The cookie, set by PubMatic, registers a unique ID that identifies a returning user's device across websites that use the same ad network. The ID is used for targeted ads. 3 months Advertisement
ndat This cookie is set by the Ninthdecimal. This cookie is used for tracking the visitor across multiple devices. This tracking helps to retarget the visitor through multiple channels. 5 months 27 days Other
uid This is a Google UserID cookie that tracks users across various website segments. 1 year Analytics
MUID Bing sets this cookie to recognize unique web browsers visiting Microsoft sites. This cookie is used for advertising, site analytics, and other operations. 1 year 24 days Advertisement
_rxuuid Unruly Media sets this cookie to store information on how the end user uses the website and any advertising that the end user may have seen before visiting the said website. 1 year Advertisement
_uetsid Bing Ads sets this cookie to engage with a user that has previously visited the website. 1 day Performance
_uetvid Bing Ads sets this cookie to engage with a user that has previously visited the website. 1 year 24 days Performance
_rxuuid Unruly Media sets this cookie to store information on how the end user uses the website and any advertising that the end user may have seen before visiting the said website. 1 year Advertisement
sp This cookie is set by the host c.jabmo.app. This cookie is used to serve the content based on user interest and improve content creation. 1 year Advertisement
uid_bam No description available. 1 year 6 months Other
uuid MediaMath sets this cookie to avoid the same ads from being shown repeatedly and for relevant advertising. 1 month Advertisement
OptanonConsent OneTrust sets this cookie to store details about the site's cookie category and check whether visitors have given or withdrawn consent from the use of each category. 1 year Necessary
_pin_unauth This cookie is placed by Pinterest Tag when the user cannot be matched. It contains a unique UUID to group actions across pages. 1 year Other
_fbp This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website. 3 months Advertisement
_pinterest_ct_ua This cookie is set by Pinterest to assess our online targeted advertising success. 1 year Advertisement
_hjFirstSeen Hotjar sets this cookie to identify a new user’s first session. It stores a true/false value, indicating whether it was the first time Hotjar saw this user. 30 minutes Analytics
secure_customer_sig Shopify sets this cookie to be used in connection with customer login. 1 year Necessary
cart_currency Shopify sets this cookie to remember the user’s country of origin and populate the correct transaction currency. 14 days Necessary
_y This cookie is associated with Shopify's analytics suite. 1 year Analytics
_s This cookie is associated with Shopify's analytics suite. 30 minutes Analytics
_shopify_y This cookie is associated with Shopify's analytics suite. 1 year Analytics
_shopify_s This cookie is associated with Shopify's analytics suite. 30 minutes Analytics
_hjIncludedInSessionSample This cookie is associated with Shopify's analytics suite. 2 minutes Analytics
_hjIncludedInPageviewSample Hotjar sets this cookie to know whether a user is included in the data sampling defined by the site's pageview limit. 2 minutes Analytics
_hjAbsoluteSessionInProgress Hotjar sets this cookie to detect the first pageview session of a user. This is a True/False flag set by the cookie. 30 minutes Analytics
io_token_7c6a6574-f011-4c9a-abdd-9894a102ccef This cookie is set by the provider mpsnare.iesnare.com. This cookie is used to provide the webservices to the visitors in a safe and secure environment. 1 year Other
AWSALBCORS This cookie is managed by Amazon Web Services and is used for load balancing. 7 days Necessary
pixel This cookie is used to present the visitor with relevant content and advertisement. 1 year Advertisement
ABTasty This cookie set by the provider AB Tasty. This cookie is used for sending all test data(visitor ID, test and variants IDs, timestamps). 1 year 22 days Other
ABTastySession This cookie is set by the AB Tasty. This is a functional cookie used for website optimization. It is utilised in enabling A/B testing within the website. 30 minutes Functional
AWSALBCORS This cookie is managed by Amazon Web Services and is used for load balancing. 7 days Necessary
_gat_UA-47011405-1 A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to. 1 minute Analytics
u2 The domain of the cookie is owned by Sizmek. This cookie is used for advertising purposes. 3 months Advertisement
AWSALB AWSALB is an application load balancer cookie set by Amazon Web Services to map the session to the target. 7 days Performance

Google Ads and Analytics

We use “Google Analytics” to collect information about the use of our Sites. Google Analytics collects information such as how often users visit the Sites, what pages they visit when they do so, and what other sites they used prior to coming to the Sites. We use the information we get from Google Analytics only to improve our Sites. Google Analytics collects only the IP address assigned to your device on the date you visit our Sites rather than your name or other personal information. We do not combine the information collected through the use of Google Analytics with other personal information. Although Google Analytics plants a cookie on your web browser to identify you as a unique user the next time you visit our Sites, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Sites by disabling cookies on your browser. Along with cookies, Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) to compile aggregated statistics to analyze how our Sites are used. You can find additional information on how to install a browser add-on to prevent your data from being used by Google Analytics at tools.google.com/dlpage/gaoptout.

Service Providers

We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions (including rebates and returns), tracking and responding to consumer questions or complaints, and performing analyses to improve the quality of our Services.

Pinterest

We use Pinterest “tags” which means your information may be shared with Pinterest for online behavioral advertising. You can opt out of online behavioral advertising through their  Pinterest personalization settings.

How do we use and share information?

The information and data we gather from our Cookies and Other Tracking Technologies will be used, retained, and shared in accordance with this Cookie Policy and TULA’s Privacy Policy.

To prevent TULA FROM using certain Cookies and Other Online Tracking Technologies, YOU CAN CHANGE YOUR BROWSER SETTINGS IN ACCORDANCE WITH THE INSTRUCTIONS BELOW OR BY USING OUR COOKIE MANAGEMENT TOOL AVAILABLE ON THE FOOTER OF OUR SITE.

You can stop cookies from being downloaded on your device by selecting the appropriate settings on your browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to access or take full advantage of the Sites. Most browsers allow users to use a “private mode” by which cookies are deleted after your website visit. Please read the help section of your browser to learn more about how to activate the “private mode.” You could still visit our Sites if your browser is in “private mode”; however, the user experience may not be optimal, and some features may not work.

  • Click here to learn more about the “Private Browsing” setting and managing cookie settings in Firefox.
  • Click here to learn more about “Incognito” and managing cookie settings in Chrome.
  • Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer.
  • Click here to learn more about “Private Browsing” and managing cookie settings in Safari.

If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Sites from placing further cookies on your device unless and until you adjust your browser setting as described above.

More Information

You can find more information about cookies, behavioral advertising, and online privacy at www.allaboutcookies.org. For some of our service providers that participate in the Digital Advertising Alliance (DAA), you can exercise your choice to opt out of interest-based advertising at http://optout.aboutads.info. You may also opt out of receiving interest-based ads from many third-party websites and applications through the Network Advertising Initiative’s (NAI) Opt Out Tool, which is available at http://www.networkadvertising.org/choices. Certain types of mobile devices have an identifier that provides organizations with the ability to serve targeted advertising directly to a specific mobile device, and you may (depending on the device) be able to limit advertising, reset the advertising identifier, and turn off your device’s tracking features within your device’s settings. For more information see http://youradchoices.com/appchoices.

Canada Privacy Rights

Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”) will be collected, stored, used and/or processed by TULA in accordance with this Privacy Policy and TULA’s obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to these Canadian laws, you have a right to request access to your personal information and to request that inaccurate personal information be corrected. If you have submitted personal information to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal information, we will require that you verify our request via email, and we will request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee to access your personal information, provided that we advise you of any such fee in advance. Your right to access personal information is not absolute, and we may not be able to allow you to access certain personal information in certain circumstances (e.g., if the information contains personal information of other persons or it is subject to legal privilege). In the event that we cannot provide you with access to, or the ability to correct, your personal information, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or email), please contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

California Privacy Rights

Data Privacy Rights

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents are entitled to certain data privacy rights:

  • Right to Know (Specific Pieces of Personal Information). You have the right to know the specific pieces of your personal information that we have collected about you.
  • Right to Know (Categories of Personal Information). You have the right to know (i) the categories of personal information we have collected from you; (ii) the categories of sources from which the personal information is collected; (iii) the categories of your personal information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling your personal information.
  • Right to Delete. You have the right to request that we delete your personal information that we have collected and retain.
  • Right to Correct. You have the right to request that we correct inaccurate personal information that we have collected and retain.
  • Nondiscrimination. You have the right not to be subject to discrimination for asserting your rights under the CCPA.

Submit a Privacy Request

To submit a privacy request, complete our privacy webform or contact us using any of the following means: (email) privacy@tula.com, (mail) TULA Life, Inc, ATTN: DATA PRIVACY, 228 Park Avenue South, PMB 23606, New York, New York 10003-1502. An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process

If you (or your authorized agent) make any request related to your personal information, TULA will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, TULA will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information

California residents have the right to opt out of the “sale” of their personal information. However, TULA does not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Do Not Share My Personal Information

California residents have the right to opt out of the “sharing” of their personal information. TULA uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.

Children

The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore TULA does not knowingly sell or share the personal information of minors under sixteen (16) years of age.

Limit Use of Sensitive Personal Information

TULA does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.

Virginia Privacy Rights

Data Privacy Rights

Pursuant to the Virginia Consumer Protection Act, Virginia residents are entitled to certain data privacy rights:

  • To confirm whether or not TULA is processing your personal information, and to access such personal information.
  • To request TULA correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
  • To request TULA delete your personal information.
  • To obtain a copy of the personal information that you previously provided TULA in a portable and, to the extent technically feasible, readily usable format that allows it to be transmitted to another entity without hindrance, where the processing is carried out by automated means.

Submit a Privacy Request

To submit a privacy request, complete our privacy webform or contact us using any of the following means: (email) privacy@tula.com, (mail) TULA Life, Inc, ATTN: DATA PRIVACY, 228 Park Avenue South, PMB 23606, New York, New York 10003-1502.

Privacy Request Verification Process

If you make any request related to your personal information, TULA will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, TULA will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. None of Virginia’s privacy rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the Virginia Consumer Protection Act, please see: https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.

Privacy Requests Appeals Process

If you would like to appeal a decision TULA has made with respect to your privacy request, please email privacy@tula.com with the subject line “PRIVACY REQUEST: APPEALS” and describe the nature of your request, and the reason requesting an appellate review.

Opt-Out Rights / The Sale of Personal Information

Virginia residents have the right to opt out of the “sale” of their personal information. However, TULA does not sell your personal information to third parties for or monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising

Virginia residents have the right to opt out of having their personal information used for targeted advertising purposes. TULA uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences.

Opt-Out Rights / Profiling

Virginia residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, TULA does not engage in such activities.

European Union (EU), Switzerland, and United Kingdom (UK)

Data Protection Rights

If you are located in the EU, Switzerland, or the UK, you have the following data protection rights:

  • Right to Know: The right to know about what personal information TULA collects and processes about you, including the types and categories of personal information we collect and process, the sources of such personal information, our retention criteria, with whom we share your personal information, cross-border data transfers, and how to file complaints and inquiries. The personal information that we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information, among other issues, are set forth in this Cookie Policy and in our Privacy Policy.
  • Access Rights. You may ask us whether we process any of your personal information and, if so, receive access to such personal information. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned as well as any other information necessary for you to exercise the essence of this right.
  • Rectification. You have the right to have your personal information corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, update any incomplete personal information, which may include the provision of a supplementary statement.
  • Erasure. You have the right to have your personal information erased, which means the deletion of your personal information by us and, where possible, any other controller to whom your data has previously been disclosed. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your personal information is no longer necessary in relation to the initial purposes for which it was processed, your personal information was processed unlawfully).
  • Restriction of Processing. You have the right to obtain the restriction of the processing of your personal information, which means that we suspend the processing of your personal information for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal information is contested, but we need time to verify the inaccuracy (if any) of your personal information.
  • Data Portability. You have the right to request us to provide you with your personal information in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible.
  • Right to Object. You have the right to object to the processing of your personal information, which means you may request us to no longer process your personal information. This only applies in case the “legitimate interests” ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”). However, at any time (and free of charge) you can object to having your personal information processed for direct marketing purposes.
  • Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your personal information. However, this will not impact our legal basis to process such personal information prior to the withdrawal of your consent.
  • Automated Decision Making. TULA does not engage in any activity that subjects our customers, Site users, survey participants, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significantly results, impacting them.

Legal Basis for Processing. We process your personal information in accordance with the legal bases set forth in law. For example, our processing of personal information (as described herein) is justified based on the following legal grounds:

  • Consent: You may consent to our use of non-essential cookies.
  • Legitimate Interests. We process essential cookies to host, maintain, and secure our Site.

Complaints

In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority. For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.

We reserve the right to amend this Cookie Policy at any time. We will notify you if this Cookie Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Cookie Policy to determine whether any amendments have been made hereto. Your use of the Sites, and continued use of the Sites after any amendments are made to this Cookie Policy, signifies your consent to this Cookie Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Cookie Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review this Cookie Policy to determine whether any amendments have been made hereto.

Contact Us

To prevent TULA FROM using certain Cookies and Other Online Tracking Technologies, YOU CAN CHANGE YOUR BROWSER SETTINGS IN ACCORDANCE WITH THE INSTRUCTIONS BELOW OR BY USING OUR COOKIE management TOOL AVAILABLE ON THE FOOTER OF OUR SITE.

If you have questions regarding this Cookie Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact our Privacy Office at the following:

privacy@tula.com
TULA Life, Inc
ATTN: DATA PRIVACY
228 Park Avenue South
PMB 23606
New York, New York 10003-1502.

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