Last updated: 10/31/2019
Additionally, before we use PII for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of PII is otherwise required by law or contract, we will endeavor to comply with the law or contract.
Collection and Use of Information
Information Collected or Received from You
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services. Additionally, we acquire, hold, use and Process PII for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. We may use PII to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Generally manage Accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of our Services;
Contact you to answer requests for customer support or technical support.
Administrative Purposes. We may use PII for administrative purposes, including to:
Measure interest in our Services;
Develop new products and Services;
Ensure internal quality control;
Verify individual identity;
Communicate about individual Accounts and activities on our Services and systems, and, in our discretion, changes to any Color & Culture, Inc. policy;
Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
Process payment for products or services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities;
Enforce our Terms.
Marketing Our Products and Services. We may use PII to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide PII; or
Otherwise with your consent.
You may contact us at any time to opt-out of the use of the PII you’ve provided for marketing purposes, as further described in “Your Choices” below.
Research and Development. We may use PII to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail and Email. Individuals who provide us with PII, or whose PII we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in “Your Choices” below.
Anonymous and Aggregated Information Use. We may use PII and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not PII, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within our and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Other Uses. We may use PII for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide PII or with your consent.
Account Information. When you create an Account, we’ll collect PII that can be used to identify you, such as your name and email address, and the individuals for whom you may be purchasing products. We will also collect additional PII if you decide to purchase a product through our Services, such as your phone number, credit card number, billing address and shipping address. When you engage in certain activities via the Services, such as, without limitation, registering for e-mail promotions or notifications, setting up a shopping cart, or filling out and submitting an online form, you may be asked to provide PII. Depending on which activity you engage in, such PII may be required or optional. If you agree to receive email or "special offers" from us when you sign up for an Account, or otherwise consent to receiving email from us, we may, from time to time, send you emails regarding our products and services. If you do not want to receive email advertisements, simply tell us when you sign up for your Account. The option to unsubscribe will also be present in every promotional email sent to you. If you encounter difficulties unsubscribing, please contact us at firstname.lastname@example.org.
Information Related to Use of the Services. Our servers automatically record certain information about how a person uses our Services (we refer to this information as "Log Data"), including both Account holders and non-Account holders (either, a "User"). Log Data may include information such as a User’s Internet Protocol ("IP") address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to fight spam, malware and identity theft. We also use the IP address to generate aggregate, non-identifying information about how our Services are used.
Information Sent by Your Mobile Device. We collect certain information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
Location Information. In some cases, we collect and store information about where you are located, such as by converting your IP address into a rough geolocation. We may use location information to improve and personalize our Services for you.
Via Email. We will also receive PII about you if you send us an email and we’ll use that PII in order to respond to your email communication. Purchase History. If you create an Account, in addition to collecting and storing Log Data, we may also store certain information that you provided in connection with completing your purchase via the Services for each visit and for a period of time prior to that purchase (e.g., your purchase history and certain billing information). We reserve the right to keep such information as long as is appropriate to be compliant with our retention policy or applicable law.
Information that We Share with Third Parties
We will not share any PII that we have collected from you except as described below:
Information Shared with Our Services Providers. We may engage third party service providers to work with us to administer and provide the Services including (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. These third-party service providers have access to PII only for the purpose of performing services on our behalf and are under contract to not disclose or use it for any other purpose.
Information Shared for Interest-Based Advertising and Third Party Marketing. Through our Services, we may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected PII (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share PII with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in the section titled “Your Choices” below.
Information Shared with Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
We offer you choices regarding the collection, use and sharing of PII and we’ll respect the choices you make. Please note that if you decide not to provide us with the PII that we request, you may not be able to access all of the features of the Services.
Even if you opt-out, we may still collect and use non-PII regarding your activities on our Site and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp , or www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
Additionally, Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Although we make good faith efforts to provide Individuals with access to their PII, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to PII you have provided.
The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including PII) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We do not accept liability for unintentional disclosure.
By using the Site or providing PII to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
Links to Other Sites
International Users and Transfer
If you are visiting from the European Union or other global regions, please note that you are agreeing to that PII you provide may be transferred to, and maintained on, our computers and servers and the computers and servers of our service providers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. By providing information to us, you consent to the Processing of PII in these locations.
Our Policy Related to Children
Our Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) (collectively, “child” or “children”) and we do not knowingly collect PII from children. If you are under the age of 18, you must have your parent’s permission to access the Services. If you learn that your child has provided us with PII without your consent, you may alert us at email@example.com. If we learn that we have collected any child’s PII, we will promptly take steps to delete such information and terminate the child’s Account.