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Effective Date: 08/25/2022
When you use our Site or the Services, we may collect personal data from or about you.
When you open an account, place an order, opt-in to receive emails, complete a quiz, or interact with us on social media or through the Services, you may provide the following categories of personal data to us:
If you choose to use our refer-a-friend service to tell a friend about TULA, we may collect your friend's name and email address to send your friend an email and one follow-up reminder email inviting him or her to shop with us. We store information about the individuals you refer in order to send these emails and to administer and track the success of our referral program.
If you interact with us on social media, we will collect information about those interactions. The information we collect may include your name, photograph, and email address. We may also collect information about you from third parties, including mailing list providers, online advertising networks, analytics vendors, companies that co-sponsor promotions, publicly available sources, or friends that refer you to TULA.
As is true of most websites, we automatically gather information about you and your computer or mobile device when you access our Site. In compliance with applicable regulations, we may collect this information using cookies, web beacons, log files, and similar technologies. Please see the section on Cookies and Other Tracking Technologies for more information on how we use these digital technologies and how to manage your preferences. We may also collect information about your online activities over time and across third-party websites. The information we collect automatically may include:
We may associate this information with your TULA account if you have one, the device you use to connect to our Site, or email or social media accounts that you use to engage with TULA.
In compliance with applicable regulations, we may automatically gather information about you and your computer or mobile device when you access our Site using cookies, web beacons, log files, and similar technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “log file” tracks your actions on websites and may collect information related to your device, browser, internet service provider, and the time of your activity. A “web beacon,” also known as a pixel tag or clear GIF, is used to transmit information back to a web server.
We collect information using cookies. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when you revisit our Site; and (2) third-party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when visiting other websites.
Our Site uses the following types of cookies for the purposes set out below:
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site. Your choices for managing use of cookie include:
Our Site contains electronic images known as web beacons (sometimes called pixels or single-pixel gifs) which are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns and to understand and optimize how our Site is used.
Our site gathers certain browser details and site interaction data (i.e., when and how you interact with our site) automatically and stores it in log files to analyze trends, administer our Site, and track visitor movement for analytics and performance improvement.
This information may be used by TULA and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes, please visit the Google Ads Help page.
We and the service providers working on our behalf use personal data collected about you to for a variety of legitimate business purposes including:
If you reside in the United Kingdom, we are required to inform you of the legal bases of our processing of your personal data, which are described below:
We only use your personal data for purposes disclosed to you at the time of collection. We obtain proper consent where required by applicable law. We will not collect additional categories of personal data or use the personal data collected for materially different, unrelated, or incompatible purposes without first providing notice. We have set out below a description of the ways we plan to use your personal data and which of the legal bases we rely on to do so.
We will share your personal data with third parties only in the ways that are described in this Policy. We may provide your personal data to third parties that provide services in connection with our business activities and are authorized to use your personal data only as necessary to provide these services directed by us and in a manner consistent with this Policy.
Specifically, we may share your personal data:
When you provide a product review or other user content, that content may be publicly posted. Other users may be able to see your name or other information about you that you post. If you prefer that we not share your information with such third parties, you may opt out by emailing us at firstname.lastname@example.org.
Online payments made through our Site are handled by our third-party payment services provider. We do not process, record, or maintain your credit card or bank account information. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments and dealing with complaints and queries relating to such payments and refunds. If you have any questions about payments or would like to dispute a charge, you can contact us at email@example.com.
TULA is headquartered in the United States. We currently have operations, including offering our services and products, in the United States, Canada, and the United Kingdom. For information on how we handle the sharing or transfer of personal data, please refer to the International Transfers section below.
Our retention periods for personal data are based on business needs and legal requirements. We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.
You may review, update, or modify your personal data, including profile and contact information, at any time by logging into your TULA account. You may request deletion of your personal data or TULA account by emailing firstname.lastname@example.org or by completing our consumer rights webform.
You may unsubscribe from our promotional emails at any time by following the instructions included in those emails, emailing email@example.com, or by completing our consumer rights webform. If you opt out of receiving such communications, please note that we may continue to send you non-promotional emails (such as order confirmation emails or emails about changes to our legal terms).
Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) provides Canadian residents with specific rights regarding their personal data. If you reside in Canada, you or your authorized agent may request that we take the following actions in relation to your personal data:
The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal data. If you reside in California, you or your authorized agent may request that we take the following actions in relation to your personal data:
We may offer you various financial incentives such as special offers and discounts when you provide us with personal information, such as your name and contact information. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by opting out of marketing email or SMS (depending on the program you signed up for) or contacting us at firstname.lastname@example.org. Generally, we do not assign monetary or other value to personal information. However, California law requires that we assign such value in the context of financial incentives. We calculate this based on the cost of providing the financial incentive offered.
The United Kingdom’s Data Protection Act 2018 (“DPA”) and the UK General Data Protection Regulation (“UK GDPR”) provides UK residents with specific rights regarding their personal data. If you reside in the UK, you or your authorized agent may request that we take the following actions in relation to your personal data:
If you reside in the United States, Canada, or UK and you, or your authorized agent, would like to submit a request, you may do so by completing our webform, emailing us at email@example.com, or writing to us at our postal address provided below
We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. We will not discriminate against you based upon your exercise of any of these rights.
If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at firstname.lastname@example.org. You also have the right to file a complaint with the data protection regulatory authority in your country.
Our Services are not designed for children, and we do not knowingly collect personal data from visitors under the age of 16. If a child under 16 submits personal data to us and we learn that the personal data is the information of a child under 16, we will attempt to delete the information as soon as possible. If you have reason to believe that a child has provided personal data to us, please contact us at email@example.com, and we will delete that information from our databases.
We may provide links to third-party websites, services, and applications that are not operated or controlled by TULA. These third-party services may include, for example, an activity feed or social media buttons. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
TULA is headquartered in the United States and has affiliates and service providers in other countries. Your personal data may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your country. When TULA makes such transfers of personal data, it will take reasonable and adequate measures, in accordance with applicable data protection laws, designed to protect the personal data.
The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it. TULA has implemented appropriate technical, physical, and organizational measures designed to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
It is your responsibility to maintain the confidentiality of your password and for any unauthorized access to or use of our services using your password. If you suspect any unauthorized use of your password or account, or if you find any other security breach, please contact us immediately.
If you have any questions about security on our Site, you can contact us at firstname.lastname@example.org.
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements, or as otherwise required by applicable law. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
We may change this Policy from time to time. If we do so, we will post the updated policy on our Site and will indicate when the Policy was last revised. If we make any material changes, we will provide you with additional notice. You should periodically review our current Policy to stay informed of our personal data practices.
If you have questions or concerns regarding this Policy or would like to update your preferences or information that we have about you, please contact us our Privacy Office by writing or emailing us at the addresses listed below and we will take reasonable steps to respond to your request.
TULA Life, Inc.
Attn: Courtney Browne
228 Park Avenue South
New York, New York 10003-1502
Copyright © TULA Life, Inc. All rights reserved.
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