Privacy Notice Updated September 2021
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. Some cookies may assist in performing essential functions of the Services, such as processing your orders and to enable any purchasing capabilities. These Cookies also may be required for the Services’ functionality, including for system administration, security and fraud prevention. For more information about how to manage your cookie preferences, please see the “Online Advertising and Direct Marketing Choices” section below.
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 https://privacy.summersalt.com.
Information We Collect From Third Party Sources
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.
- For any other purpose, with your consent where appropriate.
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 as described in the “Information We Collect Automatically” section above; 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 opt out of such sharing by visiting our Privacy Center. You may also visit our Privacy Center at any time to opt-out of receiving promotional communications from Summersalt. 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.
- 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.
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:
- Legitimate interests: In many cases, we handle personal information on the ground that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Provision of our Services;
- Customer support;
- Non-marketing communication, and some marketing communication;
- Protecting our customers, personnel and others; and
- Analyzing and improving our business.
We may also process personal information for the same legitimate interests of business partners and organizations with whom we work.
- Consent: Where required by law, and in some other cases, we process personal information on the basis of consent. For example, we may send certain marketing emails to individuals who have requested them.
- To honor our contractual commitments to an individual: Some of our processing of personal information is done to meet our contractual obligations to the individuals to whom the personal information relates, or to take steps at their request in anticipation of entering into a contract with them. For example, when an individual places an order, we can process their payment information on this basis.
- Legal compliance: We need to use and disclose personal information in certain ways to comply with our legal obligations.
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 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:
- 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 http://www.aboutads.info/choicesto 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.
- You may be able to block cookies on your browser. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). However, note that by blocking any or all cookies, you may not have access to certain Services features or offerings.
- You may also manage your cookie preferences on our site here.
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.
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.
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.
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 or our Privacy Center.
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 firstname.lastname@example.org or 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 email@example.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 firstname.lastname@example.org. 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:
- obtain confirmation of whether we hold personal information about them, and receive information about how it is used and disclosed;
- obtain a copy of the personal information, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form;
- update, correct or delete the information;
- object to the use or disclosure of the information;
- withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information, or of uses and disclosures for which the law does not require consent); and
- obtain a restriction on the use of the information.
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 email@example.com. 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:
- 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).
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 firstname.lastname@example.org.
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