Privacy Policy
Last modified as of May 24, 2018
NaturallyCurly (“NaturallyCurly,“ “we,” “us,” or “our”) respects the privacy rights of online visitors to its network of websites and services (the “NaturallyCurly”), and is committed to providing you with a secure online environment. We have created this Privacy Policy (“Privacy Policy”) to let you know how we collect, store, and use the information you provide us online. This Privacy Policy covers websites in the NaturallyCurly including NaturallyCurly.com, and SHOP NaturallyCurly. Please read it carefully. This Privacy Policy will also instruct you on how you can verify the accuracy, and control certain uses, of the information you provide to us on the NaturallyCurly. By accessing the NaturallyCurly, you agree to be bound by the Privacy Policy.
This Privacy Policy may be updated from time to time. Accordingly, you should check the date of this Policy (which appears at the bottom of this Policy) and review any changes since the last version. If at any time you do not agree to the terms of this Privacy Policy, please do not use the NaturallyCurly. Your continued use of the NaturallyCurly constitutes your agreement to this Privacy Policy. Please remember that this Privacy Policy applies only to information collected by the NaturallyCurly. We are not responsible for the privacy of any information you reveal or post in any public forum (e.g., message board, blog, etc.) or for the privacy practices of websites that are operated or owned by third parties. Canadian residents, please note: Since our offices are located in the State of Texas, United States of America, personal information that you provide to us will be stored on servers in the U.S. You agree that by providing us with your personal information, your personal information may be subject to access requests from, and may be disclosed to, governments, courts or law enforcement in the U.S. in complying with U.S. laws, regulations and court orders.
WHAT INFORMATION DOES THE NATURALLYCURLY COLLECT?
We collect two types of information: personally identifiable information and non-personally identifiable information.
Personally Identifiable Information
Personally identifiable information is information that identifies you or can be used to identify or contact you (“Personally Identifiable Information”).
When you visit the NaturallyCurly, you may be asked to provide certain Personally Identifiable Information about yourself on a voluntary basis such as when you: (i) register with us, (ii) shop at SHOP NaturallyCurly online store, (iii) participate as a Curl Ambassador or in contests, events or promotions, (iv) sign up via e-mail for our newsletters or to communicate with us, or (v) fill out online surveys. The requested information may include personal information such as your name, e-mail address, telephone number, and home address. For some activities, we may also ask you to create a password and to provide demographic information such as your birth date, zip code, and hair type. If demographic information is collected for an activity that also requires personal information, we may combine the demographic information with your personal information. This allows us to tailor the notices we send you and the content we provide you according to your preferences and interests.
We want to reiterate that you do not have to provide us with any Personally Identifiable Information to visit the NaturallyCurly. However, if you choose to withhold requested information, you may not be able to use all of the capabilities in the Network, such as purchasing goods and services through SHOP NaturallyCurly or posting a user blog or product review on the Network.
Registration
If you wish to register with on the NaturallyCurly, you may be asked to supply personal information such as your full name and e-mail address. We may also ask you to provide demographic information such as your birth date, the zip code and state in which you live, and information about your hair type. NaturallyCurly uses such information to periodically contact you with product information news, special offers and relevant announcements (including service announcements) and to provide other exclusive benefits to those who register on the Network.
CurlMart Online Store
Visitors purchasing goods and services through SHOP NaturallyCurly will need to provide a valid credit card number and expiration date, in addition to name, mailing address, phone number and e-mail address.
Promotions/Contests
To participate in some of our contests, you may be asked to provide an e-mail address or user name, so that we can let you know if you won a prize. For other contests, we may request your name and home address in order to send you products or information by regular mail. All contests on the NaturallyCurly are administered by NaturallyCurly unless offered by a sponsor in which case you give us your permission to share relevant information with that sponsor. In the same manner, if you opt-in to receive information regarding a promotion, you give us your permission to share your name, e-mail address, hair type, and location with the third party offering the promotion.
If you sign up for our email newsletter, we use your e-mail address to contact you regarding administrative notices, new product offerings and communications relevant to your use of the site. We will not send you promotions or announcements unless you give us permission to do so.
Blogs and Reviews
If you wish to post a user blog or a product review, you will need to register on the NaturallyCurly. During that process, you will be asked to supply personal information such as your full name and e-mail address as well as to select a user name. These are discussed further below under Public Forums.
Online Polls
We may offer online polls to interact with visitors to the NaturallyCurly. You do not need to be a registered user to submit a response to a poll. However, information collected through a poll is anonymous; we cannot identify who is submitting a response or tie it to other personally identifiable information a user may have provided us through another means.
Non-Personally Identifiable Information
Some of the information that we collect as described above cannot be used by itself to identify or contact you, such as demographic information (like age or gender) and hair type (“Non-Personally Identifiable Information”). Non-Personally Identifiable Information may also include user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the NaturallyCurly and other websites linked to the NaturallyCurly, such as the domain name of the Web site from which you linked to the Network. Non-Personally Identifiable Information is used to help us understand who uses the NaturallyCurly and to improve and market the Sites.
WHO IS COLLECTING MY INFORMATION AND HOW WILL IT BE USED?
NaturallyCurly collects the personal information you provide on the NaturallyCurly. We use Personally Identifiable Information as described above. We also use your Personally Identifiable Information for our internal marketing and demographic studies, so we can constantly improve the products and services we provide you and can better meet your needs.
We use Non-Personally Identifiable Information to help administer the NaturallyCurly. Non-Personally Identifiable Information may also be used to provide information about the NaturallyCurly to potential business partners and other unaffiliated entities. In addition, the demographic information (for example, age and zip code) you provide us may be disclosed in aggregate to third parties. However, this aggregate demographic information cannot be used to personally identify you or your computer.
We specifically share Non-Personally Identifiable Information about your activity on the NaturallyCurly to Lotame Solutions, Inc. (“Lotame”) for the purpose of tailoring, analyzing, and reporting on advertising you see. Lotame may use cookies, web beacons, and/or other technologies to tailor the ads you see on the NaturallyCurly. For more information about the Non-Personally Identifiable Information that is collected and used by Lotame, or to opt-out of Lotame’s use of this information, please see Lotame’s privacy policy at www.lotame.com/privacy.
We allow third-party companies to collect certain information when you visit our web site. These companies may utilize cookies, pixels or other technologies to collect and use both personally identifiable information (e.g., your name, phone number, physical or electronic address) and non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide advertisements about goods and services likely to be of greater interest to you. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info or Networking Advertising Initiative at www.networkadvertising.org/choices.
California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of their personally identifiable information to third parties for their direct marketing purposes. You may request a list of all of the third parties with whom we share your PII by sending an e-mail to [Licensor’s contact information] and place “California Third Party Disclosure” in the subject line. Please allow up to thirty days for a response.
As stated earlier, Non-Personally Identifiable Information does not identify you individually. However, when Non-Personally Identifiable Information and Personally Identifiable Information are combined, we refer to this as Personally Identifiable Information and the combined information will be treated by NaturallyCurly as Personally Identifiable Information under this Agreement as long as it is so combined.
WITH WHOM DOES NaturallyCurly SHARE MY PERSONALLY IDENTIFIABLE INFORMATION?
NaturallyCurly shares Personally Identifiable Information as described above. From time to time, NaturallyCurly may also employ and share users’ Personally Identifiable Information with entities who use it solely to provide support for the internal operations of the NaturallyCurly (for example, online product fulfillment, online registration and email services, or technical support). These entities will not use your personal information for any other purpose, and have agreed to maintain the confidentiality, security, and integrity of the personal information they obtain from us.
We may disclose Personally Identifiable Information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, actual or alleged intellectual property infringement, or other activity that is illegal or may expose you or us to legal liability.
Except as specifically noted in this Policy, NaturallyCurly does not sell, rent, or otherwise disclose Personally Identifiable Information collected from and about its users to third parties for promotional purposes. However, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, NaturallyCurly’s user information may be transferred to NaturallyCurly’s successor or assign, if permitted by and done in accordance with applicable law.
COOKIES AND CLEAR GIFS
NaturallyCurly uses cookies and clear GIFs to enhance your experience at our Sites. These cookies and clear GIFs let us know how many people are coming to individual sites, how frequently, and how they are using the Sites, allowing us to make updates to content and improve navigation as appropriate.
Cookies are pieces of information that we place on your computer to help us accurately understand how many consumers are visiting a particular site, how often they visit that site, what content they are most interested in, and how they prefer to shop for our products. For example, a cookie will allow us to remember certain things based on your Internet Protocol or “IP” address (an IP address is the string of numbers that identifies each sender or receiver of information that is sent across the Internet), such as your login information, the time and duration of your visits, how you navigated through our content and where you exited a particular site. To save you the time of re-entering your login information every time you come back to our Web sites, NaturallyCurly may link information contained in a cookie to your email address. We do not use cookies to retrieve information from your computer that we did not originally send in a cookie.
Clear GIFs, sometimes called “Web bugs,” are file objects, usually a graphic image such as a transparent one pixel-by-one pixel GIF (Graphics Interchange Format, one of the two most common file formats for images on the Web), that are placed on a Web page or in an e-mail message to monitor user behavior. The GIF tells us the IP address of the computer that fetched our page, the URL of the page the GIF is on, the time the page was viewed, the type of browser used, and can tell us a previously set cookie value. This anonymous information is returned by the clear GIF to NaturallyCurly and we use this information to accurately count visitors across the NaturallyCurly and understand how they navigate and use the Network. NaturallyCurly does not combine information gathered through clear GIFs with your Personally Identifiable Information.
LOG FILES
Other information passively collected by NaturallyCurly is in the form of logs – files that record website activity and gather statistics about web users’ browsing habits. These entries are generated anonymously, and help NaturallyCurly determine (among other things) how many and how often users have visited the NaturallyCurly, which pages they’ve visited, and other similar data. We also use the log file entries for our internal marketing and demographic studies, so we can constantly improve the online services we provide you. Log files are used internally only, and are not associated with any particular user, computer, or browser.
LINKING TO THIRD PARTY SITES
To provide relevant information not found on the NaturallyCurly, to facilitate online shopping, and to allow you to interact with other Web sites on which you may have accounts (such as Facebook and other social media sites), NaturallyCurly may provide links or embed third-party applications that allow login from our websites to third party websites. NaturallyCurly will notify users when they are leaving the NaturallyCurly or otherwise indicate that you will be going to a third-party’s site. Your use of these websites or applications is subject to the third parties’ privacy policies, and we encourage you to read the third party sites’ privacy policies before submitting personal or other information or using the applications.
OPT-OUT
If you do not want NaturallyCurly to send you e-mail or otherwise contact you about our products or services, you can opt-out at the time of registration or at the time of information collection. If you are receiving e-mails and at a later date you choose to opt-out and have your name removed from NaturallyCurly’s e-mailing list, you can do so by using the “unsubscribe” link included with a NaturallyCurly e-mail.
Please note that “welcome” and service e-mail communications are not promotional in nature and, therefore, an opt-out is not provided. These are simply to notify the user of a service they recently signed up for or to notify the user of website issues.
PUBLIC FORUMS
From time to time you may be able to participate in certain activities on the NaturallyCurly, such as chat rooms or bulletin boards, which will allow you the opportunity to communicate with NaturallyCurly or other users of theNaturallyCurly. Unless otherwise noted, these activities are generally accessible to all users of theNaturallyCurly and any information that you post or otherwise make available through these forums will be non-confidential and known to all other users. Accordingly, please exercise discretion when using these forums and when publishing any Personally Identifiable Information in these forums. You acknowledge and agree thatNaturallyCurly does not review, censor, or in any manner control the content of these forums and consequentlyNaturallyCurly has no liability or responsibility whatsoever for information made available through these forums and that you will be liable to NaturallyCurly for any liability that we incur as a result of any statement made by you in these forums. Your use of these forums is also subject to NaturallyCurly’s Terms of Use and to our Ground Rules.
SAFEGUARDING YOUR PERSONAL INFORMATION
NaturallyCurly will only collect personal information to the extent deemed reasonably necessary to serve our legitimate business purposes, and we employ reasonable and current methods to ensure the security and integrity of any information you provide to us. Any information provided to NaturallyCurly on the NaturallyCurly is housed in a secure datacenter, and sensitive information such as credit card numbers are secured using SSL encryption. Your account information and profile are password-protected. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Remember to sign out of your account and close your browser window when you have finished your session. This is to help ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place where others may have access to it.
Whenever you voluntarily disclose personal information online – for example on message boards, through e-mail or in chat areas – that information can be collected and used by others.
No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee its absolute security.
CHILDREN
NaturallyCurly is concerned about the safety of children when they use the Internet. However, the NaturallyCurly are neither directed nor targeted to children under 13 years old. Consistent with the Children’s Online Privacy Protection Act of 1998, NaturallyCurly has no intention to knowingly collect any Personally Identifiable Information from individuals under the age of 13 years. If NaturallyCurly learns that a child under the age of 13 years has provided Personally Identifiable Information to the NaturallyCurly without verifiable parental consent, NaturallyCurly will use commercially reasonable efforts to delete such information from its databases. If you believe your child, who is under 13, has submitted Personally Identifiable Information to the NaturallyCurly, please contact us via one of the methods described on our Contact Us page. We strongly encourage parents to monitor their children’s use of the Web.
REVIEW, UPDATE AND REMOVAL OF PERSONAL INFORMATION
If you have registered with the Site, you may at any time review and update the contact information we have for you or inform us that you want us to remove your information from our database by either visiting the online profile section of one of our sites or contacting us by clicking here. Your account can be deleted or deactivated, but doing so will result in your not being able to access member services.
AMENDMENTS TO THIS PRIVACY POLICY
PLEASE NOTE THAT WE MAY CHANGE OUR PRIVACY POLICY FROM TIME TO TIME TO CONFORM TO CHANGES IN THE LAW OR FOR OTHER REASONS, WHICH WE RESERVE THE RIGHT TO DO WITHOUT YOUR CONSENT AND SUCH REVISED POLICY WILL BE APPLICABLE AT THE TIME IT IS POSTED ON THE NaturallyCurly. Your continued use of the NaturallyCurly following the posting of changes to this Privacy Policy means you accept the changes.
INQUIRIES
NaturallyCurly welcomes your feedback, questions, comments and concerns regarding your use of the NaturallyCurly and any third party websites linked to the NaturallyCurly. Inquiries regarding the NaturallyCurly may be made by contacting us via one of the methods described on our Contact Us page, or send a letter to NaturallyCurly, LLC., 3636 Executive Center Dr. Suite 100, Austin, TX. 78731. You can also send us your feedback on any third party sites linked to the NaturallyCurly.
EU Citizens Only: Our Compliance with the General Data Protection Regulation
We respect and safeguard the data privacy rights of all of our website visitors and customers. The European Union (“EU”) has enacted the General Data Protection Regulation (“GDPR”), which requires additional protections for the Personal Information of EU citizens. The definition of Personal Information for EU citizens is broader than the definition set forth in this Privacy Policy – it can also include IP addresses, responses to surveys, social media identifiers and photographs posted to social media. EU citizens also enjoy additional protections under the GDPR. For this reason, we have amended our Privacy Policy as it applies to EU citizens, effective May 25, 2018. Below we set forth how we are satisfying the GDPR requirements for our EU citizen users.
Rights of EU Citizens under GDPR
Under the GDPR, EU citizens have the right to request the following information from us:
- What Personal Information we hold about you, and for what purpose.
- Access to the Personal Information we hold about you.
- The right to correct Personal Information we hold about you.
- The right to withdraw consent for any use of your Personal Information by us.
- The right to object to any use of your Personal Information by us.
- The right to have your Personal Information deleted from our database.
- The right to ask for Personal Information to be transferred either back to you or to another data controller.
Any GDPR request must be made sending an email to customerservice@naturallycurly.com.
Transparency of Personal Information
We only share your Personal Information with our business partners for the lawful purpose of digital marketing, and we ensure any third parties receiving your Personal Information comply with the requirements of the GDPR. If you provide us with social media details, we may obtain publicly available information about you from these social media platforms. We will obtain consent from you for any uses of your Personal Information that fall outside the purpose described in this Privacy Policy. We do not collect sensitive information about you.
Retention of Personal Information
Your Personal Information will be retained by us for no longer than is necessary to fulfill the purpose for which it was collected, or as if required by law. When your Personal Information is deleted, it shall be deleted across all of our platforms and no longer shared with our business partners.
