Effective Date: July 6, 2020
As part of our commitment, we strive to protect the privacy of visitors to our Site. You can navigate most of the Site without giving us any personal information which identifies you. However, sometimes we need additional information about you in order to provide you with information or services you want to receive from us.
In this digital world, privacy is important to the Company and should be important to you. The Company believes in transparency and we provide this notice so that you can understand our online information practices and the choices you can make about the way your information is collected and used.
The Information We Collect and Process
The Company collects and processes two basic types of information:
Non-Personally Identifiable Information: We also collect and use information about your interactions with the Site in a manner and format that does not identify you as an individual (“Non-Personally Identifiable Information”). This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information gives us insights on how Site visitors use our site. This data is anonymous and does not contain any Personally Identifiable Information. We use this information to ensure that our website, e-mails and marketing efforts continue to appeal to Site visitors and clients. Generally, we do not combine or associate Non-Personally Identifiable Information with your Personally Identifiable Information. If we do combine Non-Personally Identifiable Information with Personally Identifiable Information, we treat the combined information as Personally Identifiable Information. We may collect, use, and disclose Non-Personally Identifiable Information as set forth below.
Other Information the Company Collects/Processes
Our Site may use technologies such as “cookies” to provide visitors with tailored information upon each visit. Cookies are a common part of many commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard drive as recognition for repeat visits to the Site. Every time you visit the Site, our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to the Site, and your browser and operating system. We also use third party analytical tools (e.g. Google Analytics) to analyze activities on the Site and use of the Site. You do not need to enable cookies to visit the Site; however, some parts of the Site and some services may be more difficult or impossible to use if cookies are disabled. Some Company cookie files remain on your computer’s hard drive unless and until you manually delete the file. The Company cookie files do not contain Personally Identifiable Information.
The Way We Use Information
We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with the Company employees and service providers to the extent necessary to administrate our systems and/or accommodate your request.
For example, if you provide your name, mailing address, telephone and/or email address and request more information about the Company’s services, this information will be shared with appropriate Company personnel to fulfill your request. This information will not be shared with non-affiliated third parties without your consent.
We use the information we collect or receive to:
- Facilitate account creation and login process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and login process for the performance of the contract.
- Send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
- Send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- Post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
- Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
- Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
- Protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
- Enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
- Respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- Manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
- Deliver services to the user. We may use your information to provide you with the requested service.
- Respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
We use non-identifying and aggregate information about the use of the Site to improve the navigation, content, and design of the Site, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. This information may include, for example, the most and least requested pages, analyzing traffic regarding specific features, and the number of users from the U.S. and other countries, among other things.
The Company will not sell or distribute Personally Identifiable Information collected from you outside of the Company without your consent (subject to the limited exceptions stated in this policy).
How Information May be Shared or Disclosed
The Company may preserve and has the right to disclose any information about you or your use of the Site without your prior permission if the Company has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of the Company or its clients or their respective partners, employees, affiliates, other users of the Site, or the public; or (b) respond to claims related to your use of the Site. We may also disclose information as required by law or subpoena to satisfy any applicable law, regulation, legal process or lawful governmental request (including to meet national security or law enforcement requirements) or in the event of a sale or potential sale, merger, acquisition, bankruptcy, or dissolution of the Company or one of its business units or similar transactions or proceedings.
The Company uses Google Analytics features including:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- DoubleClick Platform integrations
- Google Analytics Demographics and Interest Reporting
The Company uses all features of Google Analytics for Display Advertisers. That includes obtaining specific visitor cookie data, such as the source, medium and keyword used to visit this website. Google Analytics does not store any visitor specific data and we will not use visitor specific data in any way related to Google Analytics, Google AdWords, and Remarketing.
The Company and other third-party vendors, including Google, use first-party cookies such as the Google Analytics cookie and third-party cookies such as the DoubleClick cookie together to inform, optimize, and serve ads based on visitor’s past visits to our website.
The Company uses remarketing with Google AdWords (see below) and analytics to display content specific advertisements to visitors that have previously visited our site when those visitors go to other websites that have the Google Display Network implemented.
What is ReTargeting?
The main goal of ReTargeting Ads is to re-engage site visitors after they have left a site. Dynamic ReTargeting Ads are generated based on the actual products or offers viewed on the advertiser’s site. For example, if you’ve visited a retailer’s website and viewed a specific product, you might receive a banner ad containing that product. Rather than showing the same ad to every visitor, the site’s Dynamic Ad Application will select the most relevant ad copy based on the user’s activity on the site. The Site’s Personalized Retargeting Platform works when an advertiser places our tag on his website. The tag embeds a third party cookie on the browser of users visiting the Site. Using Real Time Bidding (RTB) Ad Exchanges, it is then possible to focus media buying efforts against those visitors. It is important to note that the cookie itself does not contain any personal identifying information. Our Personalized ReTargeting ads intelligently match the right offering to each visitor based on such visitor’s previous activities on the Site. Each advertiser using the Company’s service is responsible to limit the number of ad impressions shown to each user in order to ensure that viewers are not overly exposed to specific ads.
How can I remove myself from being ReTargeted?
The Site makes removing our tracking cookie easy for any user who wishes to do so. Users that don’t want to see the Company’s Personalized Ads should simply email us at [email protected]
The Company understands that the safety of your personal information is extremely important to you. Accordingly, the Company uses reasonable technological, physical and other measures to keep your information protected from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal information. Due to the nature of the Internet and related technology, we cannot guarantee the security of any information, including your Personally Identifiable Information, and the Company expressly disclaims any such obligation.
How You Can Access or Correct Your Information
You may access, update or remove the information you provided to us by contacting us – see “How to Contact Us” below. Similarly, Site users who wish to subscribe or unsubscribe to our marketing and informational communications or limit our use of any Personally Identifiable Information in any way can do so by using the subscribe/unsubscribe options contained in our emails or by sending an email to [email protected]. Upon receiving your email with the request to update or remove your information, our privacy team will: 1) log the receipt of your request, including the date and time received; 2) take reasonable steps (including seeking additional information or documentation) to verify your identity, 3) evaluate the request (including, to the extent necessary, contacting the appropriate data holder); 4) once the evaluation is completed, take action consistent with the evaluation; and 5) respond to your request accordingly. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. Some information may be retained for longer periods as required by law, contract or auditing requirements.
Links to Other Websites
Our Site contains links to other websites. The Company is not responsible for any websites that it does not own or operate. You should carefully review the privacy policies and practices of other websites that you link to from the Site, as we cannot control or be responsible for their privacy practices.
Your Rights If You Are a Resident of the European Union or United Kingdom
Subject to applicable data protection laws, customers and users have the following rights with respect to the Company’s handling of Personally Identifiable Information for which the Company is the data controller:
- Access. The right to request access to Personally Identifiable Information held by the Company.
- Objection. The right to object to certain processing of Personally Identifiable Information (unless the Company has overriding compelling grounds to continue processing), including the right to opt-out of receiving direct marketing. We will, however, continue to use Personally Identifiable Information for the limited purpose of communicating important notices relating to changes to the Service or policies, and other reasons permitted by law.
- Rectification. The right to request correction of Personally Identifiable Information that is incomplete, incorrect, unnecessary or outdated.
- Right to be Forgotten. The right to request erasure of all Personally Identifiable Information that is incomplete, incorrect, unnecessary or outdated within a reasonable period of time. The Company will do everything possible to erase Personally Identifiable Information if a user or customer so requests. However, the Company will not be able to erase all Personally Identifiable Information if it is technically impossible due to limitations of existing technology or for legal reasons, such as Fauna is mandated by applicable law to retain Personally Identifiable Information.
- Restriction of Processing. The right to request restriction of processing Personally Identifiable Information for certain reasons, such as the inaccuracy of Personally Identifiable Information.
- Data Portability. If requested, the Company will provide Personally Identifiable Information in a structured, secure, commonly used and machine-readable format.
- Right to Withdraw Consent. If Personally Identifiable Information is processed solely based on consent, and not based on any other legal basis, customers can withdraw consent at any time.
- Data Protection Contact. The right to contact the relevant data protection regulator regarding the Company’s handling of Personally Identifiable Information.
To exercise any of the above listed rights, email the Company at [email protected] or via mail at: Indulge Right Foods, 46 Peninsula Center, Suite E517, Rolling Hills Estate , CA 90274, Attn: Privacy. The Company will process requests in accordance with applicable law, with reasonable efforts and within a reasonable period of time.
Notification of Changes
Do Not Track
At this time, our Site does not support “Do Not Track” preferences that may be available in your browser for letting websites know that you do not want them collecting certain kinds of information. If you turn on the “Do Not Track” setting on your browser, our Site is not currently capable of following whatever Do Not Track preferences you set. For more information about Do Not Track, visit www.donottrack.us.
California Privacy Rights
Under California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents who provide Personally Identifiable Information in obtaining products and services for personal, family or household use are entitled to request and obtain from the Company, once per calendar year, information about Personally Identifiable Information the Company has shared, if any, with other businesses for their own direct marketing uses. The Company does not currently share your Personally Identifiable Information with other businesses for their own direct marketing uses. However, if applicable, this information would include the categories of Personally Identifiable Information and the names and addresses of those businesses with which the Company shared Personally Identifiable Information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities). To obtain this information, please send an email to [email protected] with “Request for California Privacy Information” in the subject line, or via mail at the address below.
How to Contact Us
Indulge Right Foods
Attn: Privacy Officer
46 Peninsula Center, Suite E517
Rolling Hills Estate , CA 90274