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Privacy Notice Updated January 1, 2023
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:
In these instances, we collect the following types of information:
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).
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.
European Users: If our site detects that you are visiting from a European IP address, we will seek your prior consent before deploying cookies for web analytics or advertising, or for other purposes that require consent under European law. To revoke your consent to cookies or to manage your cookie preferences, please visit our Privacy Center.
Information We Collect From Third Party Sources
HOW WE USE AND DISCLOSE YOUR INFORMATION
How We Use Your Information
We and our service providers may use the information we collect from and about you, for one or more of the following purposes:
How We Disclose Your Information
We and our service providers will disclose the information we collect from and about you for the following business and operational purposes:
Legal Bases for Processing (European Operations)
Under the General Data Protection Regulation (“GDPR”), our legal grounds for processing personal information in connection with our European operations are as follows:
We may also process personal information for the same legitimate interests of business partners and organizations with whom we work.
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 Choices
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 and share 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. You have choices about how your information is collected and used for online advertising:
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 Notice.
Privacy Settings. You may request deletion or correction of your Personal Information. To do so, please visit our Privacy Center to request deletion and contact us at email@example.com regarding correction requests.
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. If we learn that we have received personal information through our services regarding a child, we will delete it where legally required.
Special Privacy Information for Certain U.S. Residents
If you are a resident of California or Virginia, applicable law requires us to provide you with some additional information regarding how we collect, use, disclose, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”), as amended by the CPRA, or your "personal data" as defined in the VCDPA, as applicable. For the purposes of this Privacy Notice, "personal information" includes, but is not limited to, all information protected as "personal information" under the CPRA and "personal data" under the VCDPA.
Categories of Personal Information We Collect. Throughout this Privacy Notice, we discuss information we collect from and about users. Under applicable law, 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:
We do not collect or process any information that constitutes "sensitive personal information" under the CCPA, as amended by the CPRA, or "sensitive data" under VCDPA from consumers.
Use and Disclosure of Personal Information. We may use, or disclose the personal information we collect for one or more of the following business purposes:
When we disclose your personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may disclose aggregate or anonymous information with any third party, including advertisers and affiliates.
Depending on the circumstances, we may disclose some or all 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 disclose commercial information and financial data, including your payment information, with payment processors, and we disclose 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 Disclose Your Information sections for more information.
Notice of Right to Opt Out of Sales or Sharing of Personal Information We sell and share your personal information, including identifiers, commercial information internet or other network or device information, geolocation, demographic information, and inferences with our third party advertising and co-branded or jointly branded partners for these purposes:
Applicable law prohibits third parties who purchase or receive the personal information from reselling or resharing it unless you have received explicit notice and an opportunity to opt-out of further sales or sharing.
We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not and will not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales or sharing may opt-out of future sales or sharing at any time.
Pursuant to applicable law, California and Virginia residents have the right to direct us to not sell or share your Personal Data at any time. To exercise the right to opt-out of the sale, sharing or targeted advertising, you (or your authorized agent) may submit a request to us by visiting the following page: Do Not Sell or Share My Personal Information or our Privacy Center.
Your State Privacy Rights
If you are a California or Virginia resident, applicable law provides you with certain rights regarding the personal information we have about you. Specifically, you may request:
Non-Discrimination. We will not discriminate against you for exercising any of your rights. Unless permitted by applicable laws, in connection with you exercising your rights, we will not:
However, we may offer you certain financial incentives permitted by applicable laws that can result in different prices, rates, or quality levels. Any legally-permitted financial incentive we offer will reasonably relate to your personal information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
We will consider all requests and respond within the time period required by law. 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.
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 or Virginia law or would like to exercise any of them, please contact us at firstname.lastname@example.org or via our Privacy Center. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
To exercise your opt-out rights, you (or your authorized agent) may submit a request to us by visiting the following page: Do Not Sell or Share My Personal Information or our Privacy Center.
An authorized agent may make a request on your behalf. If you use an authorized agent to submit a consumer rights request, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request.
You may only make a consumer rights request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.If we deny your request, Virginia residents have the right to appeal our decision. Further, if you appeal and your appeal is denied, you may the right to complain to your state’s attorney general. You may appeal your decision by contacting us at email@example.com via our Privacy Center.
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 firstname.lastname@example.org.
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 email@example.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request.
International Privacy Rights
Depending on the laws of your local jurisdiction, you may have certain rights and additional choices with respect to your information. For example, laws outside the United States (e.g., the United Kingdom, France, Germany and other EU countries) provide individuals in such locations the right to ask us to:
For example, individuals whose personal information is subject to the General Data Protection Regulation (“GDPR”) have an absolute right to opt out of our handling of their personal information for direct marketing purposes.
Many of the rights described above are subject to limitations or exceptions under applicable law.
To exercise these rights, except for the right to correct your personal information, please visit our Privacy Center. If you wish to exercise your right to correct your personal information, or raise a complaint on how we have handled your personal information, please contact us at firstname.lastname@example.org. Individuals also have a right to file a complaint with the relevant supervisory authority, but we invite you to kindly first give us an opportunity to address your concern.
Do Not Track
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:
We use safeguards 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.
International Data Transfer
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.
If you have any questions, comments, or would like to request access to your account information, you may contact us at email@example.com.
© 2023. Summersalt, Inc. All rights reserved.
We took over 1.5 million body measurements from over
10,000 women to inform the Summersalt fit.
Using soft measuring tape, measure completely around the fullest part of the bust. Take a deep breath in and out to make sure the tape isn’t too tight or too loose.
Measure the narrowest part of the waist.
Measure the circumference of the hips 6" up from the crotch.
Stand with your feet together, and identify the point of your hip that is level with your crotch. Measure the circumference of this area.
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