Effective as of May 5, 2020
At W3LL People, Inc. (“we” or “us”), we believe in being clear and open about how we collect and use personal information related to you. In the spirit of transparency, this Privacy Notice provides you with information about the types of personal information we collect, how we use such personal information and to whom and under what circumstances we may disclose it.
This Privacy Notice applies to personal information we collect from you, or that you provide to us, and communications from us, in connection with your use of www.w3llpeople.com, our mobile application (if any), promotions in which we are involved, and social media. Please read this notice carefully so that you understand your rights in relation to your personal information, and how we will collect, use, and process your personal information.
If you do not agree with this Privacy Notice in general or any part of it, you should not use our website, our mobile app, request marketing material from us, or take part in our promotions or social media activity, as applicable.
Who We Are
For purposes of data protection laws, regardless of where you reside, W3LL People, Inc. is the controller of the personal information you provide to us, or that is collected or processed by or for us. Contact information for W3LL People, Inc. can be found in the “Contact Us” section.
The address for W3LL People, Inc. is:
W3LL People, Inc.
570 10th Street, 3rd Floor
Oakland, CA 94607
How Do We Collect Your Personal Information and How Do We Use It?
We collect and use information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device (”personal information”). Whenever we use your personal information, we will have a reason to do this.
We may use or disclose the personal information we collect for one or more of the following business purposes:
- to fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;
- to provide, support, and develop our website, mobile app (if any), products, and services;
- 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, including to investigate and address your concerns and monitor and improve our responses;
- to personalize your website or mobile app (if any) experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website or mobile app (if any) and via email or text message (with your consent, where required by law);
- to help maintain the safety, security, and integrity of our website, mobile app (if any), products, and services, including to detect, prevent, or otherwise address fraud, security, or technical issues; and
- to evaluate or conduct 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 users 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.
In particular, in the table below, we explain:
- what activity or scenario you are involved in when we use or collect your personal information;
- what categories of personal information we have collected from consumers when you take part in a particular activity; and
- what we do with your personal information, and the purposes for collecting and using it.
What We Collect
How We Use It
Purchases and Order Management
Identifiers and commercial information that we collect, or you give us, when you place an order, including:
We use this information to:
Account Creation and Management
Identifiers and characteristics of protected classifications that we collect, or you give us, when you create an account, including:
We use this personal information to:
Marketing and Promotional Materials
Identifiers that we collect, or you give us, when you sign up for our marketing materials:
We use this personal information to:
Questions and Customer Service
Identifiers that we collect, or you give us, when you communicate with us whether in person, through our website, mobile app (if any), through via email, over the phone, through social media or via any other medium, including:
We use this personal information to:
Identifiers and internet or other electronic network activity that we collect through your use of our website (which may be through cookies), including:
For more personal information on cookies, see “Cookies and Traffic Data” Section.
We use this information to:
Identifiers and commercial information that we collect from third-parties, including:
We use this information to:
Use of Social Media (2)
Identifiers and internet or other electronic network activity information that we collect, or you give us, when you share or engage with our content through social media, including:
We use this information to:
Identifiers that we collect, or you give us, when you participate in a sweepstakes, contest, or other promotion, including:
We use this information to:
User Generated Content
Identifiers and other information that we collect, or you give us, when you submit content (for example images or ratings and reviews) on our website, mobile app (if any), or social media platforms, or accept our re-use of any content you posted on social media platforms:
We use this information to:
We obtain this all of the above personal information directly from you, except for personal information that we receive from payment processing companies and address update services, as indicated above.
Third-Party Collection, Processing and Storage of your Credit Card Information
We use a third-party payment processor to process credit card transactions. Our third-party payment processor will utilize a process known as “tokenization” in order to securely process credit card transactions when you provide your credit card data to us. Tokenization is the replacement of sensitive data with a unique identifier that cannot be mathematically reversed. These tokens take the place of sensitive credit card data.
When you submit your credit card data to us for one-time purchases or for saving in your account, that data is immediately encrypted and transmitted directly to our third-party payment processor for storing, processing, and token generation.
Your credit card data is not stored or retained by us in any circumstance.
We obtain contact details and other personal information regarding media contacts and influencers from a variety of sources including Cision. If you wish to know more about how such information is collected and used, please refer to Cision’s privacy notice at www.cision.com/us/legal/privacy-policy.
Cookies and Traffic Data
Certain cookies and web beacons that we employ are necessary for the operation of our website. Other cookies that we employ are not necessary for the operation of our website, but are employed to enhance your use of our website and shopping experience.
Our cookies may be session cookies (temporary cookies that identify and track users within our website which are deleted when you close your browser or leave your session) or persistent cookies (cookies which enable our website to “remember” who you are and to remember your preferences within our website and which will stay on your computer or device after you close your browser or leave your session).
We use the following different types of cookies:
These are cookies which are needed for our website to function properly, for example, these cookies allow you to access secure areas of our website or to remember what you have put into your shopping basket.
These cookies allow us to keep a record of traffic data, count visits, traffic sources, access rates, page hits and page views so we can measure and improve the performance of our website. They help us know which pages are the most and least popular and see how visitors move to and from and around our website.
These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies allow the provision of enhance functionality and personalization, such as chats. They may be set by us or by third party providers whose services we have added to our pages.
These cookies are set through our website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other websites. They record a user’s visit to a website, the pages a user has visited and the links a user have followed. Companies will use this information to make the website more relevant to users. Companies may also share this information with third parties for this purpose.
You can find more general information about cookies and generally how to manage them at www.allaboutcookies.org.
For more information on opting-out of cookie and web beacon tracking, please see the “Opting Out of Cookie Tracking” section.
We use Google Analytics, which is a web analytics tool that helps us understand how users engage with our website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect details about how users use our website. This information is used to compile reports and to help us improve our website. The reports disclose trends without identifying individual visitors.
You can opt out of Google Analytics without affecting how you visit our website – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
How We Share Your Personal Information
For Business Purposes
We share the following categories of personal information for a business purpose, as we have in the preceding 12 months:
- identifiers, including your first and last name, billing address, mailing address, email address, and internet protocol address;
- commercial information, including purchase and order management information;
- internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with our website; and
- protected classification characteristics under California or federal law.
We disclose your personal information for a business purpose to the following categories of service providers/third parties:
- order management and shipping processors;
- payment processors;
- customer service providers;
- shopping experience service providers;
- marketing service providers (including for purposes of targeted advertising);
- loyalty program providers; and
- product review program providers.
We sell, for the purposes of the California Consumer Privacy Act (the “CCPA”), the following categories of personal information with advertisers, advertising publishers, and other third parties to serve you targeted advertising, as we have in the preceding 12 months:
- email address and IP address.
With Your Consent
We may disclose personal information collected from, and about, you (including your personal information) with companies, organizations or individuals with your express consent.
For Legal Reasons
We may also share personal information collected from, and about you with third-parties if we are legally required to do so, or if we have a good-faith belief that access, use, preservation or disclosure of the personal information is reasonably necessary to:
- comply with any applicable federal, state, or local law, regulation, civil, criminal or regulatory inquiry, investigation legal process or enforceable governmental request;
- respond to legal process (such as a search warrant, subpoena, summons or court order);
- cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believes may violate federal, state, or local law; or
- exercise or defend legal claims, protect against harm to our rights, property or safety or the rights, property or safety of third-parties, our consumers, or the public as required or permitted by law.
In Connection with a Sale or Merger
If we directly or indirectly undergo a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets, we may disclose or transfer personal information collected from, and about, you (including your personal information), to the successor organization in the transition. We will make reasonable efforts to let you and others know (in the way described in the “Changes to This Privacy Notice” section) if your personal information has been disclosed or transferred in connection with a business transition.
Aggregated, Non-Personally Identifiable Information
We share aggregate, non-personally identifiable information with our service providers in order for those service providers to enhance and optimize their services and for statistical analysis, research, and other purposes.
How Long We Keep Your Personal Information
How long we retain your personal information depends on why and how we collected it and how we use it. We will keep your personal information for as long as we need it to provide you with your requested service(s) or to meet our commercial or legal obligations.
Unless our legal obligations require otherwise, we will keep your personal information collected by, or provided to us:
- in connection with orders for seven years (though some of your personal information may be deleted earlier); and
- in connection with your online browsing, for three years (though some of your personal information may be deleted earlier).
To determine the retention period of your personal information, we consider several criteria to make sure that we do not keep your personal information for longer than is necessary or appropriate. These criteria include:
- the purpose for which we hold your personal information;
- our legal and regulatory obligations in relation to that personal information, for example any financial reporting obligations;
- whether our relationship with you is ongoing;
- any specific requests from you in relation to the deletion of your personal information; and
- our legitimate business interests in relation to managing our own rights, for example the defense of any claims.
When we no longer need to retain your personal information, it will be deleted or be anonymized so that you can no longer be identified from it.
Please note, that, other than in response to a request to delete your personal information, we have no obligations to notify you when deleting your personal information and can do it at our sole discretion.
How to Opt-Out of Certain Features
Opting Out of Promotional Emails
If you do not wish to receive communications from us about special offers and promotions, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those service or administrative communications.
Opting Out of Third-Party Tailored Advertising
If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising, you may visit the following websites:
- Network Advertising Initiative Consumer Opt-Out Page; and
- Digital Advertising Alliance Opt-Out Page for U.S.-based advertising.
These opt-out tools are provided by third parties (and not by us). We do not control or operate these tools or the choices that advertisers and others provide through these tools.
Opting Out of Cookie Tracking
You can your browser to reject cookies, warn you about attempts to place cookies on your computer or device, or limit the type of cookies you allow. You can also manually delete individual or all the cookies on your computer or device by following your browser’s or device’s help file directions. Please note that browser- and device-management tools for cookies are outside of our control and we cannot guarantee their effectiveness. Please also note that flash cookies operate differently than browser cookies and cookie management tools available may not remove flash cookies.
Please note that if you turn off cookies that are not necessary for the operation of our website, your browser or device is set to reject cookies, or you manually delete cookies, some or all the features and functionality of our website may not function properly (including features we may add to our website in the future).
Security of Your Personal Information
We maintain reasonable and appropriate measures designed to maintain personal information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure the personal information we collect. Even though we follow reasonable procedures to try to protect the personal information in our possession, no security system is perfect, and we cannot promise, and you should not expect, that your personal information will be secure in all circumstances. Please note that any transmission of personal information to us is at your own risk.
We are transparent about the ways in which we collect and use personal information and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below.
To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to complain to a supervisory authority in the country where you reside. Within the United States, you may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.
California Privacy Rights
California law permits our consumers who are California residents to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year.
If you are under 18 years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted information that you publicly post on our website or mobile app (if any). To request removal of such information, please contact us using the contact information detailed in the “Exercising Your California Privacy Rights” section. Upon receiving such a request, we will make sure that the information is not publicly available on our website or mobile app (if any), but the information may not be completely or comprehensively removed from our systems and databases.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Cecause there is no standard interpretation or practice for Do Not Track signals, we don’t support Do Not Track requests at this time. However, to opt-out of cookie and web beacon tracking, please see the “Opting Out of Cookie Tracking” section, or to opt-out of website-based third-party interest-based or online behavioral advertising, please see the “Opting Out of Third-Party Tailored Advertising” section.
Exercising Your California Privacy Rights
To make any of the requests or exercise any of your California privacy rights, please contact us using one of following methods.
By mail. If you wish to exercise any of your California privacy rights, you may write to us at the following address. Please include your full name, mailing address, and any email address associated with your activity with us (for example, the email you used to receive marketing emails or order confirmations, or the email you have used in connection with your account (if you have an account)) and let us know which California privacy right you are exercising so that we can process your request or exercising of your rights in an efficient manner.
W3LL People, Inc.
570 10th Street
Oakland, CA 94607, 3rd Floor
ATTN: Legal Department
RE: California Privacy Info
By telephone. If you wish to exercise your right to access or your right to deletion via telephone, please call us at the following toll-free number: (888) 315 9814. When you call us, please let us know that you are exercising your California privacy rights and let us know which California privacy right you are exercising so that we can process your request or exercising of your rights in an efficient manner.
Interest Based Advertising
We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These companies may collect personal information about your visits to our website and other websites/applications and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on non-affiliated websites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on personal information collected about your visits to our website and elsewhere over time. Other companies may also use such technology to advertise on our website.
Our Policies Concerning Children
Our website or mobile app (if any) is not directed to children, nor do we knowingly collect any personal information from, children under the age of 13 without verifiable parental or legal guardian consent. If you believe that a child has provided personal information to us, please promptly contact us using the contact information detailed in the “Contact Us” section below, and we will endeavor to investigate and delete such personal information from our systems.
Third Party Websites
Changes to This Privacy Notice
We may change this Privacy Notice from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on the applicable page of our website. If we change this Privacy Notice in a material manner, we will provide appropriate notice to you. If you wish to review a copy of the privacy notice effective prior to the effective date of this Privacy Notice, please contact us using the contact information detailed in the “Contact Us” section.
If you have questions or concerns about this Privacy Notice or how we collect and use the information of our consumers, please contact us.
If we need, or are required, to contact you concerning any event that involves your personal information, we may do so by email, telephone, or mail.