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.
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.
- 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:
- 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/
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:
- 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 email@example.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 firstname.lastname@example.org 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.
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 email@example.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
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.
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
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 firstname.lastname@example.org.
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 email@example.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 NEED TO SET THIS MECHANISM UP]
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 firstname.lastname@example.org 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.
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 email@example.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 firstname.lastname@example.org. 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.