Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), residents of the United Kingdom (“UK”) and residents of Switzerland, should consult the sections below of this policy relating to “International Data Transfers” and the “Rights of EEA, UK and Swiss Residents” for provisions that may apply to them.
Users in California and states with comparable privacy laws should consult the section below regarding their rights and choices in regard to Personal Information.
We encourage you to read this Policy carefully. We reserve the right to change this Policy at any time. Any updates or modifications to this Policy will be posted to our Website on this page. By using or accessing the Platform, you signify that you have read, understand and agree to be bound by this Policy. This Policy is effective as of February 21, 2024.
1. When this Policy applies
2. Personal Information we collect and how your Personal Information is collected
You may enter the Platform and browse its contents without submitting any Personal Information. However, if you choose to create an account, obtain discount coupons or codes, order and pay for Products for pickup or delivery, register for newsletters or to receive marketing information about promotions, provide feedback or reviews for our products on our Platform, refer others to us, or communicate with us we may require you provide Personal Information. The Personal Information that we collect may include your name, address, e-mail address, telephone number, or other information about you as needed to fulfill the purposes of collection.
By using our services, you give your explicit consent to receive delivery-related SMS messages to the phone number provided. You may opt-out at any time by replying “STOP” to the SMS. We may respond with a single message to confirm that you have been unsubscribed. After this, you will not longer receive SMS messages from us.
If you sign up for our rewards program on our Application or through our Website, Thanx, which powers our reward program, will provide us with your e-mail address. We also obtain personal information through orders on OLO or when you provide us such information to us in our storefronts at the point of sale.
We may also collect aggregated information regarding users of the Platform that does not identify individual users. We may use third parties to assist in such collection as noted below. We may also collect technical information which includes information about your computer (for example your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website). We may also collect usage data which includes information about your use of the Website. We also collect aggregated data such as statistical or demographic data for legitimate business purposes not prohibited herein or by applicable data protection law. Aggregated data may be derived from an individual’s Personal Information but is not considered personal data under applicable data protection law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We also use Google Analytics and other third party tools to access anonymized data to help us understand how our services are used. These tools are governed by the privacy policies of third parties.
3. Our Use of Personal Information.
We use your Personal Information where:
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, including when you order or obtain information about our Products or subscribe to receiving products;
- We need to comply with a legal or regulatory obligation;
- We have your consent;
- To send SMS notifications related to your deliveries and order status; or
- To improve our services and enhance user experience.
If we contact you or provide any materials or information to you, you always will be given the opportunity to unsubscribe from further emails from us.
4. Disclosures to Third Parties and Service Providers.
We will not disclose, rent, sell or share any Personal Information to unaffiliated third parties for marketing purposes. From time-to-time we have promotions with other brands where you may opt-in to receive e-mails from the brands participating in the promotion. Your decision to participate in such promotions is entirely voluntary and you may always opt-out of receive further communications from us or the other brands participating in the promotion.
We contract with companies or individuals to provide certain services in regard to our website. These services include facilitating customer communications, chat functionality, surveys, e-mails and website design functions. We call them our “Service Providers.” We may share both your Personal Information with Service Providers solely as appropriate for them to perform their functions. We make every effort to insure that our Service Providers do not use your Personal Information in non-aggregated form for their own purposes. These third parties are bound by confidentiality agreements and are prohibited from using your information for any other purpose.
Your phone number may be shared with third parties, such as C. H. Robinson, for the purpose of facilitating and enhancing the delivery process.
We may share your Personal Information with analytics providers, such as Google Analytics and other third parties, to tell us how the Website is performing, which parts of the Website interest interests you and how long you visit before leaving. Among other data, analytics providers may receive a User’s IP address. We make effort to insure that such third parties do not use your Personal Information in non-aggregated form for their own purposes.
5. Usage Data.
Data regarding usage of the Website (“Usage Data”) may be used in aggregate (anonymized) form for internal business purposes, such as generating statistics and developing marketing plans. We may share or transfer such aggregated, non-personally identifiable Usage Data with third parties for administrative, analytical, research, optimization, security and other purposes, but no Usage Data will be linked with your Personal Information or be used to identify or contact you.
6. Other Disclosure of Personal Information
7. Data Retention – How long will we use your Personal Information?
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for as specified in this Policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
For example, we delete some activity as soon as you exit the Website, whereas we may retain traffic data for analytics purposes.
8. Third Party Ordering
We partner with a number of third parties to provide you information about and the ability to order our Products or have them delivered to you. These third parties include Thanx, Olo, Google, Postmates, Door Dash, Amazon, Instacart, Fresh Direct, and Good Eggs, among others. Any Personal Information that you provide to such third parties is governed by their privacy policies.
9. Payment Processing
The store on our Site is hosted by WooCommerce using ShipStation They provide us with the online e-commerce platform that allows us to provide Services to you, including the purchase of our Products.
10. Privacy and security
It is entirely your choice whether or not you provide Personal Information to us. We take commercially reasonable and appropriate technical and organizational precautions to protect our customers’ Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at email@example.com.
12. Children under 16
The Website is targeted to adults. We do not knowingly collect or solicit personal information directly from anyone under the age of 16. If you are under 16, please leave the Website and please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from anyone under 16 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with Personal Information, please contact us at firstname.lastname@example.org.
13. Third-party websites
Our Website or emails may contain links to third party websites to which we have no affiliation. Except as set forth in this Policy, we do not share your Personal Information with those websites and are not responsible for the privacy policies of any other website or their management of your Personal Information. Because they may treat your Personal Information differently than we do, we suggest you read the privacy policies and terms and conditions on those third party websites prior to submitting any Personal Information.
14. Your rights and obligations
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at email@example.com. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person. If you wish to review, delete and/or revise the Personal Information we have stored about you, please contact us with your specific request at firstname.lastname@example.org.
15. Geolocation Information.
16. Your California and other state privacy rights
This section applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights or substantially similar rights. Rights of California residents are specifically referred to as “rights under the CCPA” or “CCPA rights.”
Rights under the CCPA
The California Consumer Privacy Act (“CCPA”) provides California consumers rights regarding their Personal Information (as defined in the CCPA). If you reside in a United States jurisdiction that has enacted a data privacy law, we extend the same rights CCPA grants to California consumers, except where we specify otherwise.
The categories of Personal Information we collect are generally described in the section above titled: <strong>Personal Information we collect and how your Personal Information is collected.</strong> These categories depend on how you use the Website.
Under the CCPA, qualifying California consumers may have the following rights:
Right to Know, Access, Correct and Delete
A California consumer has the CCPA rights to request that we disclose what Personal Information we collect, use, disclose, share or disclosed for a business purpose.
We may deny deletion requests, in whole or in part, with respect to information we reasonably need to:
- Comply with a legal obligation;
- Allow you, other consumer, or us to exercise free-speech rights or other legal rights;
- Perform a contract with you; or
- If we use the information for solely internal purposes reasonably aligned with consumer expectations.
Rights to Opt-Out of Sharing/Sale and Limit Use of Sensitive Information
You also have the CCPA rights to direct us (1) not to share or sell your Personal Information and (2) to limit our disclosure and your use of “sensitive personal information” necessary to provide the Website to you.
Although California consumers have the right to opt-out of sharing or selling of Personal Information we do not share Personal Information with any third party.
We do not collect “sensitive personal information” as it is defined in the CCPA and we therefore do not provide a mechanism to opt out of the use of such information.
The CCPA prohibits us from discriminating against you if you exercise rights under the CCPA. You do not need to exercise this CCPA right. We never retaliate against anyone exercising their rights under the CCPA.
Because we do not collect Sensitive Personal Information or sell or share any Personal Information, the Site is not presently configured to honor any global opt-out preference signal sent from California IP addresses to the Site through browser or device-level settings, provided the signal complies with CCPA’s requirements.
To submit a request to exercise a CCPA right, please submit a request as follows:
Urban Remedy, Inc.
208 S. Garrard Blvd.
Richmond, California 94801
(with “Personal Information Request” in the subject line of your e-mail)
If we receive any request, a California consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. <u>Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests.</u> If requests are unclear or submitted through means other than as outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If the requests are unclear we may respond with direction on how to remedy the deficiencies.
If we cannot verify the identity of the consumer making the request, we may deny the request in full or in part.
Responding to Requests
We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. For California consumers, we will confirm receipt of your CCPA request within 10 days and will substantively respond within 45 days, unless we provide an explanation why an additional 45 days is necessary. California residents may submit rights requests through an authorized agent. We may request proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf.
The content of our response will vary with the nature of your request, but we will always respond in accordance with any deadlines or requirements specified by the laws that apply to you.
Under certain circumstances, we may be unable to provide responsive Personal Information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, users’ accounts with us, or the security or our systems and networks. We do not disclose account passwords or other non-personal information that enables users to access accounts. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medication identification numbers.
We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medication identification numbers, or account passwords and security questions and answers.
We reserve the right to retain an archive of any information about you to the extent permitted by law. We also retain de-identified or aggregate data derived from information about you.
California Do Not Track Disclosures
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
Civil Code 1798.83
Under certain circumstances, California Civil C ode Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
17. Rights of EEA, UK and Swiss Residents
Our Website is available worldwide, however we do not purposefully collect the information of individuals who are resident in the EEA, UK and Switzerland. However, if we do obtain the personal data of individuals who are resident in the EEA, UK and Switzerland it is subject to the protections outlined above and is processed in accordance with the privacy laws of those countries.
Please note that if you are a resident of the EEA, UK or Switzerland that you have certain rights under applicable privacy laws in regard to your Personal Information. These rights may include the Right of Access, Right to Rectification, Right to Erasure, Right to Restrict, Right to Object, Right to Data Portability, and Right to not be Subject to Automated Decision Making.
If you are a resident of the EEA, UK or Switzerland and believe that We have Personal Information about you, and you wish to access, correct, object to processing, request restriction of processing, withdraw consent, or request the transfer to a third party of the Personal Information that we have about you or exercise any other rights that you may have or have any questions relating to the processing of your Personal Information, please contact us at email@example.com.
18. International Data Transfers
Personal Information that is transferred to us may be stored or processed in the United States, which does not have data protection laws equivalent to those in the UK or the EEA and other jurisdictions.
If you do not wish your Personal Information to be stored or processed in the United States, please do not provide such information to us.
We reserve the right to change this Policy at any time. In the event we make material changes to this Policy, such policy will be re-posted in the “Privacy” section of our Website with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy.