Effective date: April 9th, 2021
How To Contact Us
70 Washington Street
Brooklyn, NY, 11201
If we need, or are required, to contact you concerning any event that involves your personal information we may do so by telephone or email.
Types of Data collected
Among the types of Personal Data that we collect, by itself or through third parties, there are: Tracker; Usage Data; Email.
We may obtain Personal Data about you from various sources. We may collect this information when you provide it on our website, via our social media pages, when you download one of our mobile applications (either via Apple iOS or Android). When you visit this Site, our social media pages, or use services or features of one of our mobile applications, we may also collect certain information about your device or usage by automated means, including using technologies such as cookies, web server logs and web beacons.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when online, social media or via one of our mobile applications.
Unless specified otherwise, all Data requested by us is mandatory and failure to provide this Data may make it impossible for us to provide our services. In cases where our online, social media or one of our mobile applications specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact us.
Users are responsible for any third-party Personal Data obtained, published or shared through us and confirm that they have the third party’s consent to provide the Data to us.
How we use the Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
- Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of us, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Category of personal information collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
- Google Analytics (Google LLC)
- User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to us, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving us.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on us.
- Drip (Drip Global, Inc.)
Personal Data processed: Email; Tracker; Usage Data.
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumer.
- Drip (Drip Global, Inc.)
We may use the Personal Data you provide to:
- Send you promotional materials or other communications (such as general communications and specific communications)
- Provide services to you
- Process your payment card and/or gift card transactions
- Create and manage any online account, including access to your online purchase history
- Assist with product selection and replenishment
- Administer any loyalty or membership program
- Respond to your inquiries (including requests and inquiries related to any loyalty program or memberships)
- Tailor ads displayed to you on our Site and elsewhere to your interests and history with us
- Communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs, surveys and other offers
- Operate and communicate with you about our social network pages or mobile applications
- Operate, evaluate and improve our business (including developing new products and services; managing our communications; analyzing our products; performing data analytics; and performing accounting, auditing and other internal functions)
- Comply with applicable legal requirements, relevant industry standards and our policies
- We also may use the information in other ways for which we provide specific notice at the time of data collection.
Methods of processing
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. The list of persons able to access the Data is available at any time. Contact us for more information.
Legal basis of processing
We may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations, we may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
User Rights & Choices
We offer you certain choices in connection with the personal information we collect from you, such as how we use the information, how long we retain the information, and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us in the manner specified below.
We may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Information for Californian consumers
This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).
Categories of personal information collected, disclosed or sold
In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof.
You can read about these activities in detail in the section titled “How we use the Data” and “Methods of processing” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers and internet information.
We will not collect additional categories of personal information without notifying you.
How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use us.
For example, you directly provide your personal information when you submit requests via any forms on us. You also provide personal information indirectly when you navigate us, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of us and features thereof.
How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.
To find out more about the purposes of processing, please refer to the relevant section of this document.
Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.
Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by us, both online and offline, you can contact us for further information using the contact details provided in this document.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of us and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
Your California privacy rights and how to exercise them
The right to know and to portability
You have the right to request that we disclose to you:
- the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
- in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
- for sales, the personal information categories purchased by each category of recipient; and
- for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on us, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12 month period.
Should we deny your request, we will explain to you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).