Privacy Policy

PURPOSE OF THIS PRIVACY POLICY

Ulla Johnson Inc. (“Company”, “us”, or “we”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. The purpose of this Privacy Policy is to describe to you the types of information we may collect from you or that you may provide when you visit or interact with our website www.ullajohnson.com (“Site”), and what our practices are for collecting, using, maintaining, protecting, and disclosing your information. This Privacy Policy is a part of and is incorporated into our UllaJohnson.com Terms and Conditions of Use.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT CONSTITUTES A BINDING AGREEMENT BETWEEN OUR COMPANY AND YOU. BY USING OUR SITE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. BY CONTINUING TO USE OUR SITE AFTER WE HAVE UPDATED THIS PRIVACY POLICY WILL ALSO CONSTITUTE YOUR AGREEMENT TO THE UPDATED VERSION. WE THEREFORE ENCOURAGE YOU TO PERIODICALLY CHECK THIS PRIVACY POLICY TO SEE IF IT HAS BEEN UPDATED. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR ANY UPDATED VERSIONS, YOUR ONLY CHOICE IS NOT TO USE OUR SITE.

BY USING OUR SITE OR PROVIDING ANY INFORMATION TO US THROUGH OUR SITE, YOU REPRESENT THAT YOU ARE AT LEAST THE AGE OF MAJORITY IN YOUR STATE OR PROVINCE OF RESIDENCE.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy was last updated on March 9, 2020.

We may periodically update this Privacy Policy. We will post any updated versions of this Privacy Policy on our Site. If we make material changes to how we treat our users’ personal information, we may also post a notice on our Site’s home page. The date this Privacy Policy was last revised is identified above. You are responsible for ensuring that you periodically visit our Site and this Privacy Policy page to check for any changes.

WHAT DOES THIS PRIVACY POLICY APPLY TO

This Privacy Policy applies to information we collect through our Site, such as when you submit messages or emails through our Site, when you make a purchase on our Site, call our customer service line or enter a contest or promotion. This Privacy Policy does not apply to: any other website operated by us or any third party; or (ii) information collected by any third party, including through any application or content that may link to or be accessible from or on our Site.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Site, including information:

• by which you may be personally identified, such as your name, postal address, e-mail address, geographic location, payment information, telephone number, user name, password, security questions and answers, biometrics, date of birth, age, age range, gender, favorite hobbies, interests, product purchase history, browsing history or any other identifier by which you may be contacted online or offline (collectively, “Personal Information”) (this could also include information you give us about someone else (i.e. if you choose to ship a product to a friend or relative); and
• that is about you but does not specifically identify you, such as what type of web browser you are using to visit our Site, the type of computer operating system application software, and peripherals you are using, the domain name of the website from which you linked to our Site, the IP address and the website usage (including, but not limited to, the links you click on and the pages you review) (“Non-Personal Data”).

We collect this information:

• Directly from you when you provide it to us through our Site when you make a purchase; call our customer service hotline, email us an inquiry or enter a contest or a promotion;
• Automatically as you navigate through our Site such as information that may include your usage details, and information collected through cookies and other tracking technologies (described further below in “Our Cookies Policy”).
• From communications you generate and send to us by e-mail, through our Facebook page, Instagram site, the Site or other means. Examples include, but are not limited to photos, videos or testimonials.
• From a third party social network (such as Facebook) that is part of your profile and that you allow the third party site to share with us or any information you post publically. This could include, but is not limited to, basic account information for the third party site, user ID, geographic location (city, state, and country), profile picture and list of connections/friends and/or any other information that you allow the third party site to share with us. For further information concerning what information could be shared with us, please visit the third party’s website.
• On occasion from other sources. For example, we may hire a third party aggregator to provide us with further information about our customers, including from your profile or posting on third party social networking sites. We may also receive additional information by acquiring new companies or methods not inconsistent with this Privacy Policy.
• Finally, we note that we strive to limit the amount of Personal Information we collect and store to that only necessary to deliver the relevant goods and services.
• The information we collect on or through our Site may include:
• Information that you provide by filling in forms on our Site. This includes information provided at the time you create an account through our Site, subscribe to our newsletters, send us any inquiries, or request further products or services;
• Records and copies of your correspondence (including email addresses), if you contact us or provide any comments to us in connection with orders you place through our Site, or enter search terms on our Site;
• Details of transactions you carry out through our Site and of the fulfillment of any orders you place through our Site. You may be required to provide financial information before placing an order through our Site such as your credit card information; and/or
• Information we collect through automatic data collection technologies such as the type of device you are using (e.g., mobile device or desktop computer), open and click rate for newsletters we send to you, web pages viewed on our Site, pages you click on our Site, time spent viewing web pages, frequency of your visits, search terms you may use, and the date(s) and time(s) of you visits to our Site.

OUR COOKIES POLICY

The technologies we use for automatic data collection may include:

• Cookies are small text files that are saved to your computer or device by our Site or third party sites that enable certain features or functionality. Cookies can be “first party” cookies, which are cookies sent by our Site, or “third party” cookies, which are sent by third-party sites or service providers. We or our service providers may use cookies or similar technologies in combination with your account information to help authenticate you when you use our Site, to remember your preferences and registration information, to enable or store items in a shopping cart, to enhance and personalize your experience on the Site, including to operate and improve offerings, and to present and help measure and research the usage of our Site. By accessing and using our Site, you consent to our use of cookies. Most browsers are initially set up to accept cookies; however, you can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to disable your cookies setting or refuse to accept a cookie, you may not be able to access all areas of our Site. To learn more about cookies and how they work, see www.allaboutcookies.org.
• We may use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the Site. Google Analytics collects information including, but not limited to, the time of each of your visits to the Site, whether you have visited the Site before, what website referred you to the Site, and what pages you viewed on the Site. If you wish to learn more about Google Analytics and how it collects and processes data, please visit the following link: https://www.google.com/policies/privacy/partners/

THIRD-PARTY USE OF COOKIES

Some other third parties may also use cookies to collect information about you when you use our Site. They may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Site and its contents to you and market our products on our Site to visitors;
• To provide you with information, products, or services that you request from us, or send you marketing communications;
• To respond to your inquiries and send you newsletters you requested;
• To provide you with notices about your account or transactions you conduct through our Site such as confirmation emails for purchases you make;
• To notify you about changes to our Site or any products or services we offer or provide though it;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To conduct research and analyze data to improve our Site, products, or services;
• To conduct account maintenance, customer service, contests and promotions, website security and internal research.
• For any other purpose with your consent or any other purpose for which you provided your information.
• You can remove your e-mail address from our mailing list at any time by following the procedures set from the Opt-Out Procedures listed below or by clicking on the “unsubscribe” link in every Ulla Johnson e-mail.

Information obtained through our Site may be intermingled with and used in connection with information obtained through sources other than our Site, including both offline and online sources.

DISCLOSURE OF YOUR INFORMATION

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties who we use to support our business and who are required to use such information only for the purposes for which we disclose it to them.  For example, we may provide email lists to MailChimp, an email marketing company with whom we may contract with, to send marketing emails to you regarding our products, services, or Site;
• To third parties to analyze data regarding our Site, or with third parties who may assist us in servicing, maintaining, or troubleshooting our Site and who are under the same obligations of confidentiality with us or our subsidiaries and affiliates and who only have access to the personal information as it is needed to perform their stated functions;
• To a buyer or other successor to our business in the event of 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 Site users is among the assets transferred;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms and Conditions, including for billing and collection purposes; or
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our Site, our users or customers, or others.  This may include exchanging information with other companies, organizations, or law enforcement for the purposes of fraud protection.
• We do not distribute, sell, rent, or trade or otherwise disclose your information to third parties, except to service providers we have retained to perform services on our behalf. We use Shopify to power its online store—please see https://www.shopify.com/legal/privacy to learn more about how Shopify uses your Personal Information. Shopify also uses Google Analytics to help us understand how our customers use the Site –please see https://www.google.com/intl/en/policies/privacy/ to read about how Google uses your Personal Information. You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We aim to provide you with choices regarding the personal information you provide to us.  We have created mechanisms to provide you with the following control over your information:

• Cookies and Tracking Technologies.  You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  You should also have a feature in your web browser to flush or delete all cookies, or a "Do Not Track" feature.  However, if you disable or refuse cookies, please note that some parts or certain features or functionality of our Site may then be inaccessible or not function properly.
• Marketing Communications From Our Company – Opt Out Procedure.  If you do not wish to have your contact information used by us to promote our products or services, you can opt-out by either checking the relevant box located on the form on which we collect your data or at any other time by logging into the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to orders@ullajohnson.com.  We will make all reasonably commercial efforts to process your opt-out requests within forty-eight (48) hours of receiving them during normal business hours.

ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your personal information by logging into the Site and visiting your account profile page. You may also send us an email at orders@ullajohnson.com to request access to or correction of any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. If you wish to delete your account, you must contact us at the above email address. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a user name and/or password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. If you use a shared computer, never choose to have the computer save or remember your password and make sure to log out when you are finished using the Site. If your password is compromised, please immediately contact orders@ullajohnson.com.

Unfortunately, the transmission of information over the Internet is not completely secure at all times. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site and will not be liable for any disclosure or loss of your information during transmission over the Internet. Any transmission of personal information is therefore at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

LINKS TO THIRD PARTY SITES

This Privacy Policy applies only to our Site. Our Site may contain links to other websites that are not operated by us such as links to social media sites such as Instagram, Facebook, Twitter, or Pinterest. These third party links are provided for your reference and convenience only and do not imply any endorsement by us of the activities or content of these third-parties’ websites or any association with their company or operation. We do not control these third party websites and are therefore not responsible for their privacy or data practices. These third party websites may have their own privacy policies and any information you provide to these other sites will be governed by their privacy policies and not ours. We urge you to review the privacy policy posted on any website you visit before using that website or providing any personal data about yourself to that website.

TRANSFER OF DATA TO FOREIGN COUNTRIES

Please note that any information you provide to us through your use of our Site may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal data as the country in which you reside and may therefore be subject to further disclosure as required by applicable law.

By registering to use our Site, you consent to the transfer of your personal information to or from the United States, or to any other country in which we, our affiliates, or our service providers may have facilities, where your information may be further processed, and the use and disclosure of your personal information as described in this Privacy Policy or as may be required by applicable law.

ULLA JOHNSON COMPLIES WITH THE EU-US PRIVACY SHIELD FRAMEWORK.

When we transfer personal information from the European Union ("EU Data") to the U.S., we adhere to the EU-U.S. Privacy Shield Framework Principles of notice; choice; onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability designed by the U.S. Department of Commerce and the European Commission (the "Principles"). For more information about Ulla Johnson’s certification and the Principles, please visit the U.S. Department of Commerce's Privacy Shield website.

Please direct any inquiries or complaints regarding our compliance with the Principles to the point of contact listed in the "Contact Us" section below. If we do not resolve your complaint, you may submit your complaint free of charge to JAMS (https://www.jamsadr.com/eu-us-privacy-shield) our designated Privacy Shield dispute resolution provider. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. Ulla Johnson is subject to the investigatory and enforcement powers of the FTC. If Ulla Johnson shares EU Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party's processing of EU Data in violation of the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

GOVERNING LAW AND JURISDICTION; LIMITATIONS ON USE; WAIVER OF JURY

This Privacy Policy and your use and access of the Site is governed by, construed, and enforced in accordance with the laws of the State of New York, without reference to its conflict of law principles or rules. You agree that any action at law or in equity arising out of or relating to this Privacy Policy or your use of our Site shall be filed only in the state and federal courts located in New York, New York and you hereby irrevocably and unconditionally consent and submit to the exclusive jurisdiction of such courts over any suit, action or proceeding arising out of this Privacy Policy, your use of our Site, or any purchase you make from our Site. BY YOUR USE OF OUR SITE YOU ALSO HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO THIS PRIVACY POLICY TO THE FULLEST EXTENT PERMITTED BY LAW.

CHILDREN UNDER THE AGE OF 13

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to us through our Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through our Site, register for an account on the Site, make any purchases through the Site, use any of the interactive features of the Site, or provide any information about yourself to us, including but not limited to, your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information as soon as practicable. If you believe we might have any information from or about a child under 13, please contact us at orders@ullajohnson.com.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at: inquiries@ullajohnson.com. Additoinally you can reach us at our corporate address, 270 Lafayette Street, New York, NY 100012. Telephone: 212-965-5050.

CALIFORNIA PRIVACY RIGHTS AND THE CALIFORNIA CONSUMER PRIVACY ACT

If you are a resident of California, the following sections are intended to provide certain information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”). These sections apply to personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Personal information does not include publicly-available information and certain other information that is regulated by other applicable laws.

You have the Right to Know and to request that we disclose certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

-        The categories of personal information we have collected about you 

-        The categories of sources from which we have collected your personal information

-        Our business or commercial purpose(s) for collecting your personal information

-        The categories of third parties with whom we have shared your personal information

-        The specific pieces of personal information we have collected about you

We do not sell any Personal Information to third parties.

You have the right at any time to request that we delete your personal information. However, in some cases we may not be able to delete all or some of your personal information as required or permitted by applicable laws. Or we may need to delay a deletion, for instance, to process transactions you authorize such as a purchase of our products.

We do not sell, rent, or otherwise share your data to any third-party for a business or commercial purpose under any circumstances. However, we are required to let you know that you have the right to opt-out of the sale of your personal information if we ever notify you that we engage in such activity.

We will not discriminate against you for exercising your rights under the CCPA.

To submit a request to exercise any of your rights provided in this notice, please email inquiries@ullajohnson.com, or submit your request by phone by calling us at 212-965-5050. We will evaluate the request and take action where required to do so. Depending on the nature of your request, we may have to verify your identity when you contact us. We do this by asking you to provide us with certain pieces of personal information which we will match with information we have in our possession to verify your identity. 

We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provides written proof that he/she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please contact us at inquiries@ullajohnson.com or submit your request by phone by calling us at 212-965-5050. We are not able to respond to more than one “Right to Know” request from a consumer in any 12-month period.

Depending on your specific personal interaction with us or by using this website, we may have collected the following categories of personal information from consumers in the last twelve (12) months: identifiers (e.g. real name, address, email address); characteristics of protected classification under California or Federal law; commercial information (e.g. products purchased, obtained, or considered, or other purchasing or consuming histories); internet or other electronic network activity (e.g. browsing history, search history, or a consumer’s interaction with a website); geolocation data; audio, visual, and similar information; professional or employment related information; inferences drawn from any of the information above to create a profile about a consumer (reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and attitudes); or any other category of information consistent with this Privacy Policy.

Our sources for this information include: information we receive directly from you; information we may have licensed data from third-party data providers; information received from our third-party advertising partners; information received through third party social networks (such as Facebook); or any other sources consistent with this Privacy Policy.

Our business purposes for collecting this information include: to fulfill our contractual obligations with you; to improve our website and our services; to send you updates about our company; to send targeted marketing campaigns; or any other purpose consistent with this Privacy Policy.

As discussed above, we do not sell, rent, or otherwise share your data to any third-party for a business or commercial purpose under any circumstances. However, we may share your data with third-party vendors or service providers engaged by us to help provide the services permitted by the Privacy Policy. Each third-party vendor or service provider is obligated to only use your personal information to provide the contracted services and for no other purpose. Further, each third-party vendor or service provider must contractually agree to robust privacy and security obligation prior to engagement, including the secure deletion of your data upon the termination of our agreement.

 

CALIFORNIA “DO NOT TRACK” NOTICE:

We do not currently recognize and process “do not track” signals from different web browsers. For more information on “do not track” please visit https://allaboutdnt.com/.

CALIFORNIA SHINE THE LIGHT:

California law permits California residents to request notice of how their personal information is shared with third parties for direct marketing purposes. If you are a California resident and would like a copy of this notice, please contact us at inquiries@ullajohnson.com.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA ("EEA")

Ulla Johnson provides our services to you and is responsible for your personal information when you use our services. [IS THIS ACCURATE OR WILL IT BE ANOTHER ENTITY IN THE EU?]

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

We process your personal information described above:

As necessary to fulfill our responsibilities under our contract with you (e.g., processing payments for and providing the products you have ordered);

As necessary for our legitimate interests, including our interest in providing relevant and secure services, and improving our services and products;

As necessary to comply with our legal obligations; or

As consistent with your consent, which you may revoke at any time.

EXERCISING YOUR RIGHTS

You have the right to access personal information we hold about you and to ask that your personal information be corrected or erased and to port your personal information. You may also have the right to object to, or request that we restrict, certain processing or to withdraw consent you have previously provided. If you would like to exercise any of these rights, you may contact us at inquiries@ullajohnson.com. If you have an Ulla Johnson account, you may also review, update and delete certain personal information or adjust your marketing preferences by opting out of emails in the My Account section of the website.

QUESTIONS OR COMPLAINTS

If you have a concern about our processing of your personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. For contact details of your relevant local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.