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Effective Date: 04/06/2022
This Privacy Policy (the “Policy”) describes how TULA Life, Inc. and its subsidiaries and affiliates (“TULA,” “we,” “us,” and/or “our”) collects, uses, discloses, and otherwise processes personal information collected on our sites (www.Tula.com, www.TulaSkincare.ca) or through offline activities that reference this policy (e.g., your interaction with our customer support channels, retail locations where our products are sold, and in-person promotional activities) (collectively, the “Services”). This Policy also describes the choices available to you regarding your personal information and how you can access and update this information.
When you use our Site or the Services, we may collect personal information from or about you.
When you open an account, place an order, opt-in to receive emails, or interact with us on social media or through the Services, you may provide the following categories of personal information 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. To collect this information, we may use 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. 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.
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.
We may allow third parties to provide analytics services and serve advertisements on our behalf across the internet and in mobile applications. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Site, our Services and other applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. 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 information collected about you to:
We only use your personal information for the purposes disclosed to you at the time we collect your personal information and obtain proper consent, where required.
We will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without first providing notice.
We will share your personal information with third parties only in the ways that are described in this Policy. We may provide your personal information to third parties that provide services in connection with our business activities and are authorized to use your personal information only as necessary to provide these services directed by us and in a manner consistent with this Policy.
Specifically, we may share your personal information:
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 privacy@tula.com.
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 help@tula.com.
TULA is headquartered in the United States. We currently have operations, including offering our services and products, in the United States and Canada. For information on how we handle the sharing or transfer of personal information, please refer to the International Transfers section below.
Our retention periods for personal information are based on business needs and legal requirements. We will retain your personal information 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 information (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 information, including profile and contact information, at any time by logging into your TULA account. You may request deletion of your personal information by completing the webform below or delete your TULA account by emailing privacy@tula.com.
You may unsubscribe from our promotional emails at any time by completing our webform, following the instructions included in our emails, or by emailing privacy@tula.com. 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 information. If you reside in Canada, you or your authorized agent may request that we take the following actions in relation to your personal information:
The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. If you reside in California, you or your authorized agent may request that we take the following actions in relation to your personal information:
If you reside in the United States or Canada and you, or your authorized agent, would like to submit a request, you may do so by completing our webform, emailing us at privacy@tula.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 privacy@tula.com. 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 information from visitors under the age of 16. If a child under 16 submits personal information to us and we learn that the personal information 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 information to us, please contact us at privacy@tula.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.
When you click on a link to these other websites or locations, you will leave our Site, and another entity may collect personal information from you. Please be aware that the terms of this Policy do not apply to these third-party websites or content, or to any collection of your personal information after you click on links to such third-party websites. Your interactions with these features are governed by the privacy policy of the third-party service that provides the feature. We have no control over, do not review, and are not responsible for these websites or their content. We encourage you to review the privacy policies of any third-party service before providing any information to or through them.
TULA is headquartered in the United States and has affiliates and service providers in other countries. Your personal information 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 information, it will take reasonable and adequate measures, in accordance with applicable data protection laws, designed to protect the personal information.
The security of your personal information is important to us. TULA has implemented technical, physical, and organizational measures designed to protect personal information 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. If you have any questions about security on our Site, you can contact us at privacy@tula.com.
We will only 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, 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 information 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 our Privacy Officer 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
PMB 23606
New York, New York 10003-1502
privacy@tula.com
Copyright © TULA Life, Inc. All rights reserved.