Collecting Personal Information
- Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
- Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
- Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
- Disclosure for a business purpose: shared with our processor Shopify, our marketing partner Klaviyo and our advertising networks Facebook and Google.
- Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
- Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
- Source of collection: collected from you.
- Disclosure for a business purpose: shared with our processor Shopify, marketing partner Klaviyo, pay-over-time partners Klaviyo and Afterpay and order management tool Shipstation.
Customer support information
- Examples of Personal Information collected: name, billing address, shipping address, payment and order information.
- Purpose of collection: to provide customer support.
- Source of collection: collected from you.
The Site is not intended for individuals under the age of 13. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.
Sharing Personal Information
We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:
- We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
- We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
- We share your personal information with the following services:
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
- We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with Klaviyo, our marketing partner.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- FACEBOOK - https://www.facebook.com/settings/?tab=ads
- GOOGLE - https://www.google.com/settings/ads/anonymous
- BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Third Party Pixels and Cookies
When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
Using Personal Information
We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.
Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:
- Your consent;
- The performance of the contract between you and the Site;
- Compliance with our legal obligations;
- To protect your vital interests;
- To perform a task carried out in the public interest;
- For our legitimate interests, which do not override your fundamental rights and freedoms.
When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.
If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.
We do engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.
Services that include elements of automated decision-making include:
- Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
- Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.
If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.
Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.
If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.
If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.
A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.
We use the following cookies to optimize your experience on our Site and to provide our services.
Cookies Necessary for the Functioning of the Store
|_ab||Used in connection with access to admin.|
|_secure_session_id||Used in connection with navigation through a storefront.|
|cart||Used in connection with shopping cart.|
|cart_sig||Used in connection with checkout.|
|cart_ts||Used in connection with checkout.|
|checkout_token||Used in connection with checkout.|
|secret||Used in connection with checkout.|
|secure_customer_sig||Used in connection with customer login.|
|storefront_digest||Used in connection with customer login.|
|_shopify_u||Used to facilitate updating customer account information.|
|PHPSESSID||Bold Shopify Apps|
|_ga||Bold Shopify Apps|
Reporting and Analytics
|_landing_page||Track landing pages|
|_orig_referrer||Track landing pages|
|_shopify_sa_p||Shopify analytics relating to marketing & referrals.|
|_shopify_sa_t||Shopify analytics relating to marketing & referrals.|
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.
Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.
Do Not Track
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email address] or by mail using the details provided below:
Living Well Solutions, LLC, 7316 Santa Monica Boulevard, #424, West Hollywood CA 90046, United StatesLast updated: 11/13/2020
If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://oag.ca.gov/privacy/ccpa
NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT
In the below tables and sections, we describe (as required by the CCPA):
- Our Collection of Personal Information— the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
- Our Disclosure and Sale of Personal Information— the types of recipients to whom we disclose or sell Personal Information.
- Our Business Purposes — our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
- Your California Privacy Rights and Choices— what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:
- OUR COLLECTION OF PERSONAL INFORMATION
Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
|Category||Categories of Sources|
|Identifiers, e.g., name; alias; postal address; mobile ad or cookie identifiers; IP address; telephone number; email address; social network handles||Data compilers and consumer data resellers, informational and retail websites (“Commercial Source Categories”)Public records and other publicly available sourcesGovernment entitiesSocial networks|
|Commercial or transactions informationE.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Commercial Source CategoriesPublic records and other publicly available sources|
|Internet or other electronic network activity informationE.g., browsing history; online interests.||Commercial Source Categories|
|Professional or employment-related informationE.g., current or past job history or job title.||Public records and other publicly available sourcesCommercial Source Categories|
|Inference DataE.g., consumer information or preferences.||Commercial Source Categories|
- OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.
|Category||Categories of Third Parties We Share With||Whether We “Sold” This Category of Personal Information in the Last 12 Months|
|Identifiers, e.g., name; alias; postal address; mobile ad identifiers; IP address; telephone number; email address; social network handles||Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, content publishers, non-profit organizations, business-to-business services and organizations, consumer surveys and survey companies, affiliate networks (“Commercial Recipient Categories”)Advertising networks and media platforms, political campaigns, internet service providers, data analytics providersSocial networks||Yes|
|Commercial or transactions informationE.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Commercial Recipient CategoriesAdvertising networks and media platforms, political campaigns, internet service providers, data analytics providersSocial networks||Yes|
|Internet or other electronic network activity informationE.g., browsing history; online interests.||Commercial Recipient CategoriesAdvertising networks and media platforms, political campaigns, internet service providers, data analytics providers, and social networks||Yes|
|Inference DataE.g., consumer information or preferences.||Commercial Recipient CategoriesAdvertising networks and media platforms, political campaigns, internet service providers, data analytics providersSocial networks||Yes|
|Inference DataE.g., consumer information or preferences.||Commercial Recipient Categories Advertising networks and media platforms, political campaigns, internet service providers, data analytics providersSocial networks||Yes|
We also may share any of the personal information we collect as follows:
Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, at our discretion.
- OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION
|Our Purposes for collecting, using and sharing Personal Information|
|Creating “identity” graphs or associations between data points, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, cookie or device identifiers, email address).|
|Additional marketing services, for example (which may overlap with “data marketing services” above):Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile, and social media marketing.Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.Providing “hygiene” or “verification” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect, or outdated information.|
|Operating our Services, for example: Testing, improving, updating and verifying our own database.Developing new products.Operating, analyzing, improving, and securing our Services.|
|Other internal purposes, for example:For internal operations, auditing, research, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.We sometimes use the information collected from our own website, from social networks, from other “business to business” interactions (such as information we collect at trade shows) or from data compilers for the above, as well as for our own marketing purposes.|
- YOUR CALIFORNIA RIGHTS AND CHOICES
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests (to the extent permitted by applicable law, we may charge a reasonable fee to comply with your request).
Sometimes, we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing or other data management services), in which case any consumer requests for opt-out, deletion or access to data must be made through that client: we therefore will forward any such requests to a named client, as feasible, such as where a client has been identified.
1. Right to request that we “do not sell” your personal information
You may request that we not “sell” your personal information. If you wish to make such a “do not sell” (also called an “opt out” request), please go to our “Do Not Sell” web form located at https://app.retention.com/ccpa_details. Alternatively, you may contact us by email at privacy[at]retention.com. When you make such a request, we will retain your information on an internal “suppression” list, so that we may remove your data from our active database in the event we obtain it again at a later date.
2. Right to request deletion of your personal information
You may request that we delete any personal information that we collected from you, such as if you have been a customer of ours (Note that this is different from your right to “opt out” of us selling your personal information, which is described above; also note that we do not generally collect personal information directly from consumers). You may make a deletion request by emailing us at support[at]retention.com. In our discretion, we may interpret your “deletion” request as a “Do Not Sell” request (and thus place it on a suppression list, as described above), if we in good faith believe that is what you are requesting.
However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
3. Right to request access to your personal information
California residents also have the right to request that we disclose what categories of your personal information that we collect, use, or sell. As a California resident, you may also request the specific pieces of personal information that we have collected from you. You may make such an “access” or “right to know” request here: https://app.retention.com/request_my_data. We may withhold some personal information where the risk to you or to others’ privacy rights is too great to disclose the information.
For security purposes (and as required under California law), we will verify your identity — in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, if you request specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) that reasonably confirms you are the person you claim to be.
4. Right to nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
5. Right to “opt-out” of the sale of your personal information
California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” — including in the definition making available a wide variety of information in exchange for “valuable consideration.”
6. Information about persons under the age of 16
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).
7. Authorized agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a legally sufficient power of attorney. We likewise may require that you verify your own identity, depending on the type of request you make.