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Privacy Notice (Updated)

Privacy Notice Updated September 25, 2020


Summersalt, Inc. (“Summersalt,” “we,” “us,” or “our”) recognizes that privacy is important and is committed to maintaining the privacy of information it collects. This Privacy Notice explains how we collect, use and share information through our website and services and through interactions with our users (collectively the “Services”) wherever this Notice is posted.

 

INFORMATION WE COLLECT


We collect information in multiple ways, including when you provide information directly to us and when we automatically collect information from or about you, such as from your browser or device.  We may combine all of the information we collect from or about you from these various sources and use it for all the purposes described below. 

 

Information You Provide Directly to Us

 

We may collect information that you provide when you use our services or otherwise communicate with us, such as during the following interactions:

 

  • When you create an account on the website;
  • When you make a purchase or register a product;
  • When you register for communications (including to receive emails and texts) or other subscriptions through this website, Twitter, Facebook, Instagram or any other digital media, or social media application;
  • When you make a request or an inquiry or contact customer support or provide feedback
  • When you participate in a contest, promotion, sweepstakes, survey or other promotion or marketing event;
  • When you connect with us on social media;
  • When you participate or comment in a blog or forum; and
  • When we conduct market research or when we meet you at a social or other event.


      In these instances, we collect the following types of information:

       

      • Contact information, such as your full name or company name, email address, phone number and physical mailing or shipping address;
      • Authentication Information, such as passwords and reminder questions/answers;
      • Order Information, including products purchased, style and usage preferences, sizing and measurement information, and shipping preferences;
      • Payment Information such as credit, debit, or other financial account information. This information goes to and is stored with our payment processors.  We do not store such information. 
      • Demographic Information, such as age, gender, pregnancy status, or other information you provide in response to surveys or in customer service interactions; and
      • Audio information (e.g., if you participate in a customer support call and do not opt out of call recording)

       

        Information We Collect Automatically

         

        Usage and Device Information. We may automatically collect certain information about you or the computer or devices you use.  For example, we may collect information that is automatically sent to us by your computer or mobile web browser or your internet service provider. This information typically includes your web request, IP address, browser type, domain name and settings, referring / exit pages and URLs, how you interact with links on the website(s), pages viewed, mobile carrier, mobile device identifiers and information about the device you are using to access the Services.

         

        Location Information.  We collect and process general information about the location of the device from which you are accessing the Services (e.g., precise or approximate geographic location inferred from an IP address).

         

        Cookies and Other Tracking Technologies. We and our service providers may also collect data about your use of the Services through Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website that enables us to: (a) recognize your computer; (b) understand the web pages of our website you have visited; (c) recognize repeat users; (d) facilitate the your ongoing access to and use of the Services (e) allow the Services to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising; (f) enhance your user experience by delivering content and advertisements specific to your inferred interests; (g) perform searches and analytics; and (h) assist with security administrative functions. You may be able to block these cookies on your browser. Please consult the "Help" section of your browser for more information (e.g., Internet ExplorerGoogle ChromeMozilla Firefox; or Apple Safari). However, note that by blocking any or all cookies, you may not have access to certain Services features or offerings.

         

        Tracking pixels or web beacons are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of a website and associated advertising, to access user cookies and for retargeting. We and our service providers may also include Web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we and our service providers adopt additional technologies, we may also gather additional information through other methods. 

         

        Information We Collect From Third Party Sources

         

        We may receive information about you from other sources, including data vendors, data co-ops, marketing partners, and anti-fraud services. We may add this information to the information we have already collected from you to use for all the purposes described in the privacy policy.

         

        Social Media Information.  If you interact with us through a social media service or log in using social media credentials, depending on your social media settings, we may have access to your information from that social network such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, your comments about our Services, and the people/sites you follow.

         

        HOW WE USE AND SHARE YOUR INFORMATION

         

        How We Use Your Information

         

        We and our service providers may use information we collect from and about you, for one or more of the following purposes:

         

        • Respond to your inquiries, collect your suggestions, and fulfill your requests, such as to send you email alerts, and contact you to answer any questions to the extent possible.
        • Send you important information regarding the website or terms, conditions, and policies and/or other administrative information. 
        • Complete and fulfill your purchase, request or inquiry, for example, to communicate with you regarding your order, your return or other answers to your questions, and provide you with related service and assistance, if any.
        • Send you marketing communications that we believe may be of interest to you, including information about upcoming opportunities, invitations, events, apps, and exclusive deals. 
        • Personalize your experience on the Services by presenting opportunities, products and offers tailored to you.
        • Create inference data about you and your interests based on purchases you have made and how you use the Services.
        • Allow you to participate in surveys, sweepstakes, offers, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your information, so we recommend that you read these rules carefully.
        • Allow you to communicate and interact with others through our website (for example, through a blog, message board, messaging functionality, chat functionality, profile or other social media).
        • Enable our business purposes, such as data analysis, audits, researching and developing new products and services, enhancing this website, improving our services, developing marketing events, identifying usage trends and determining the effectiveness of our promotional campaigns. We may analyze aggregated demographic information and information for historical, statistical, or scientific purposes, or we may store the information for your convenience should you return to this website in the future. 

         

        How We Share and Disclose Your Information

         

        We and our service providers will share the information we collect from and about you for the following business and operational purposes:

         

        • Service Providers: We may provide access to or share your information with third parties who perform services on our behalf, such as sales, marketing, product content and features, advertising, research, customer service, delivery, data storage, security, fraud prevention, payment processing and order fulfillment and legal services. We also use third-party web analytics services on our website to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; and provide certain features to you.
        • Affiliates: We provide access to or share your information with current or future affiliates for the purposes described in this Privacy Notice.
        • Third Party Partners for Direct Marketing: We may share your information with third party partners to provide you with information, including marketing, about services that we think you might want. You may at any time opt-out of receiving promotional communications from Summersalt or sent by Summersalt on behalf of third parties by contacting us at the email address below. Please note that if you decide to opt-out of receiving promotional information or other communications after you have previously opted-in, your change in preference will only affect future contacts; if the information already has been provided to third parties, they may continue to use it. We may still contact you as necessary regarding Summersalt, any request you have made for services or products from Summersalt, changes to this Privacy Notice and other transactional matters. 
        • Third Party Partners to Provide Co-Branded or Jointly Offered Products and Services: We may from time to time partner with another brand or retailer or other third party to offer services, products, events and promotions on a co-branded or cross-promotional basis. The information you provide in connection with our Services may be collected directly by, or shared with the third party, as well as with any participating sponsors or advertisers of such services. You can opt-out of these disclosures under the Opt-Out section of this Privacy Policy below. 
        • Protection of Summersalt and Others & Legal Compliance: We may access, retain and disclose the information we collect and maintain about you if required to do so by law or on a good faith belief that such access, retention, or disclosure is reasonably necessary to: (i) comply with law or legal process (e.g., a subpoena or court order) and requests from public or governmental authorities; (ii) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (iii) respond to your requests for customer service; and/or (iv) protect the rights, property or personal safety of Summersalt, its agents and affiliates, its users, and/or the public; (v) investigate security breaches; and (vi) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
        • Business Transfers: We may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.

         

        Aggregated or De-Identified Information.

         

        We may aggregate, de-identify, and/or anonymize any information collected through the Services in such a way that we cannot reasonably link information to you or your device. For example, we may use the information to calculate the percentage of Summersalt users who have a particular telephone area code or who use an Android device or an iOS device.

        Because this type of information cannot be reasonably linked to you, we may use and disclose this information for any purpose.

         

        Online Advertising and Direct Marketing


        We may use all information collected through the Services for direct marketing and e-marketing purposes including the sharing of the information with our affiliates or third parties unless you specifically request that it not be used for that purpose.

         

        Online Advertising.  We may use your information to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and any of our partners, on and off the Services.  Third-party networks and advertising technologies allow for the delivery of advertising from us on other websites you visit. If you are interested in more information about how you can generally limit cookies from being put on your computer to deliver certain types of advertising, please visit  http://networkadvertising.org/optout_nonppii.asp and www.aboutads.info/choices.to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

         

        Text Marketing

        By signing up via text, you agree to receive recurring automated promotional and personalized marketing text messages (e.g. cart reminders) from Summersalt at the cell number used when signing up. Reply HELP for help and STOP to cancel. Msg frequency varies. Msg & data rates may apply. View Terms & Privacy.

         

        Links to Other Sites


        For your convenience, our website may contain certain hyperlinks to other websites as well as to third party websites. This Privacy Notice applies only to information collected on this website and not to information collected on linked sites. We encourage you to be aware when you leave this website and to read the privacy statements of each and every linked site that collects your information.


        Children's Information

        We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities. We do not target our websites to children less than 16 years of age or knowingly collect information from children for the purpose of selling products or services.

         

        Privacy Information for California Residents

         

        California Consumer Privacy Act. If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

         

        Categories of Personal Information We Collect.  Throughout this Privacy Notice, we discuss information we collect from and about users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect.  Depending upon the types of services you use, the categories we collect are:

         

         

        • Customer Records Information, including personal and online identifiers (such as name, address, email address, device ID, physical characteristics or description);
        • Commercial information (such as purchase history);
        • Financial data (such as payment information);
        • Internet or other network or device activity (such as information related to your browsing history and the device(s) you use to access the website);
        • Geolocation information (e.g., your city and state inferred from IP address);
        • Demographic information (e.g., such as age, gender, and pregnancy status).
        • Audio information (e.g., if you participate in a customer support call and do not opt out of call recording);
        • Inference data about you and your interests based on purchases you have made and how you use the website; and
        • Other information that identifies or can be reasonably associated with you.

         

        Use of Personal Information. 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 make a purchase or ask a question about our products or services, we will use that personal information to respond to your inquiry. We may also save your information to facilitate new product orders or process returns.
        • To provide, support, personalize, and develop our website, 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.
        • To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
        • To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
        • For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
        • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
        • As described to you when collecting your personal information or when we notify you of other uses at the time of collection, or as otherwise set forth in the CCPA.
        • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Summersalt’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Summersalt is among the assets transferred.

         

        We may share or disclose such aggregate or anonymous information with any third party, including advertisers and affiliates.

         

         

        Depending on the circumstances, we may share any of the above categories of information we collect with: business partners to provide you with services that you request; service providers; other parties, including government entities, when required by law or to protect our users and services; or in connection with a corporate transaction. In addition, we may share commercial information and financial data, including your payment information, with payment processors, and we share device information and identifiers and internet or other network or device activity with entities that provide content, advertising, and functionality.  See the How We Use Your Information and How We Share and Disclose Your Information sections for more information.

         

         

        Notice of Right to Opt Out of Sale of Personal Information

         

        California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include when we share your information with third parties to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies IP address and/ or browsing behavior, to deliver targeted advertising on our site or on other services.

         

        We may provide the following categories of information to third parties for these purposes:

        • For online targeted advertising purposes: demographic and statistical information, user-generated content, customer records information, device information and identifiers, connection and usage data, geolocation, and social media information.
        • For sharing with third parties to send you relevant offers and promotions: contact and account registration information; customer records information; demographic and statistical information, user-generated content, and geolocation.

         

        If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined on the following page: Do Not Sell My Personal Information . You can also submit a sale opt-out request by emailing us at privacy@summersalt.com.

         

        Your California Privacy Rights

         

        If you are a California resident, the CCPA provides you with certain rights regarding the information we have about you.  Specifically, the CCPA allows you to request:

        • Information about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Privacy Notice.
        • Provide access to and/or a copy of certain information we hold about you.
        • Delete certain information we have about you.
        • Provide you with information about the financial incentives that we offer to you, if any.

         

        The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

         

        We will consider all requests and respond during the applicable time period. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information or to comply with a legal obligation. Depending on the sensitivity of the information sought, we also may take steps to verify your identity before responding to a request, which might include, at a minimum, verifying your name, email address, and date of birth. You are also permitted to designate an authorized agent to submit certain requests on your behalf. An authorized agent must have a signed, written permission from you or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

         

        Additionally, exercising your deletion rights may mean that you may no longer be able to use portions of Summersalt’s service that require personal information to function (e.g., if you register for an account, you cannot delete your username and password if you want to maintain your account).

         

        If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at privacy@summersalt.com or via our California Consumer Rights Request Form.

         

        Shine the Light Disclosures. If you reside in California, you may request certain general information regarding our disclosure of personal information during the preceding year to third parties for their direct marketing purposes. To make such a request, please write to us at privacy@summersalt.com.

         

        Privacy Information for Nevada Residents

         

        Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons.  In some circumstances, we may share your information with certain third parties that we believe can provide you with offers and promotions for products and services of interest to you.  This sharing may qualify as a sale under Nevada law. If you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of “sales” activity emailing us at privacy@summersalt.com.   Please note we may take reasonable steps to verify your identity and the authenticity of the request.

         

        Do Not Track


        Our systems do not recognize "Do Not Track" signals, but several of the third party companies who use cookies or beacons on our web sites enable you to opt out of certain behavioral advertising. We also provide you with additional tools to opt out of marketing from us or certain transfers of your information. You can learn about this in the "Opt Out" section of this Privacy Notice.

         

        Retention Period


        We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.


        The criteria used to determine our retention periods include:

        • The length of time we have an ongoing relationship with you and provide requested services to you;
        • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);or
        • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

         

        Information Security

         

        We use commercially reasonable methods consistent with industry practice to protect your personal information from unauthorized access or disclosure. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is completely secure so there is still some risk that your personal information may be accessed or misappropriated. Therefore, we cannot guarantee the absolute security of your personal information. If you have any questions about security on our site, you can send an email to us at email address specified below.

         

        Changes in this Privacy Notice


        We reserve the right to modify this Privacy Notice at any time, so please review it frequently. If we make material changes to this notice, we will notify you here, by e-mail, or by means of a notice on our home page.

         

        Opt Out


        If you do not want us to disclose your personal information as described in this statement, or to market to you directly, please contact us at privacy@summersalt.com.

         

         

        Contact Us


        If you have any questions, comments, or would like to request access to your account  information, you may contact us at hello@summersalt.com


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