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NAANI Privacy Policy

This Privacy Policy (the “Privacy Policy“) applies to our websites at www.naanilove.com and www.shop.naanilove.com (collectively, the “Website” or “Site“) operated by Naani Botanicals, LLC (“Naani,” “we,” “our“, or “us“), as well as to the products, services and information available via the Website (collectively, the “Services“). This Privacy Policy describes how we collect, use, and disclose information, governs how we treat this information, and lets you know your associated rights.

Our Website contains links to other websites for your convenience and reference. We are not responsible for the privacy practices or the content of those sites.

  1. Navigating this Privacy Policy.  To help you navigate our Privacy Policy, we have divided it into numbered sections and provided a set of definitions in Section 21 (Definitions) to allow easy reference to key concepts.
  2. Your Consent to this Privacy Policy. You indicate your consent to the terms of this Privacy Policy in different ways, depending on your relationship to the Website. The procedures for consenting to this Privacy Policy are less formal if you are a casual visitor to our Site (a “Guest User“) and more formal if you are, or are seeking to become, a registered user (a “Registered User“). 
    1. Consent by Guest User. We have structured our Website so that, as a casual Website visitor, you are able to come to our Website and review selected information about our Services without providing us with any Personally Identifiable Information. By accessing and using our Website as a visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it.
    2. Consent by Registered Users. In order to create an account to purchase products or otherwise participate in the Services, you must: (i) complete the registration process at our Website; (ii) be age eighteen (18) or older; and (iii) indicate your consent to this Privacy Policy in the manner we specify during the registration process. 
    3. Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 12 (Your Right to Opt-Out; Object to Processing; Deleting Information).
  3. The Information We Collect.  To provide our Services, and to otherwise conduct our business via the Website, we rely on information provided by, and collected from, our users. This information is collected in order to provide benefits and Services to you and to continue to improve and enhance our Service offerings. This information may include, but is not limited to, that which you provide voluntarily through your interactions with the Site, as well as information about how you use and navigate through the Site. This information consists of the following: 
    1. Personally Identifiable Information. We collect certain information that identifies you as an individual (collectively, “Personally Identifiable Information“). The Personally Identifiable Information we collect may include the following:
  • Name
  • Email
  • Full Address
  • Phone Number
  • Your device and/or hardware ID for your mobile device; and
  • Financial account information (collected by our Payment Processor if you purchase products)

[Note to draft: Is the above all correct?  Is there any other Personally Identifiable Information that is collected?]

  1. Online Activity Information. We may also collect technical and device-related information through our Website and third party analytics tools that we use (collectively, “Online Activity Information“). Sometimes Online Activity Information can be associated with your Personal Information, in which case we will treat it as Personal Information (as described in Section 2.4 (Treatment of Combined Information), otherwise we consider, and treat, Online Activity Information as Anonymous Information.
  2. Anonymous Information. Our Website also collects, processes, and/or uses information that does not identify you or your devices, including Personally Identifiable Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information“). Information that meets these criteria might include, for example, demographic information, statistical information (e.g. page views and hit counts), and general tracking information.
  3. Treatment of Combined Information. If we combine Online Activity Information or Anonymous Information with Personally Identifiable Information, we treat the resulting combination as Personally Identifiable Information. 
  1. How We Collect this Information.  We collect the above information through the following means and technologies:
    1. Registration. In order to provide you with certain Services, we need to collect certain Personally Identifiable Information, including those specified in Section 3.1 (Personally Identifiable Information). For example, when you register to create an account for making purchases or to use certain password-protected Services or areas on our Website, you must provide a variety of Personally Identifiable Information to us in connection with creating a user account.
    2. Contacting Us. You can contact us via the Site with questions or comments – for example, you can contact us to learn more about Naani’s products and Services. In order to communicate with us, you must provide certain Personally Identifiable Information.
    3. Payment Processing. If you pay for the classes you register for using our Website, we may collect Personally Identifiable Information, including contact information and payment information (such as credit card number, expiration date, and security code), in connection with your order and purchase. We may already have this information on file if you are a Registered User. This Information is used for billing purposes, order fulfillment, contacting you about your purchases and payments, and sending you other communications. Please note that Naani uses a reputable company (the “Payment Processing Company“) to collect and process your payment information – Naani does not collect, store or process your credit card information itself. Rest assured that we have taken steps to ensure that the Payment Processing Company protects Personally Identifiable Information it collects from you in compliance with our Privacy Policy. 
    4. User-Generated Content. We give you the ability through the Website to engage with us and with others in public exchanges, and this may include opportunities for you to provide comments, reviews, recommendations, and other input via the Website (collectively, “User-Generated Content“). Please understand that, if you include Personally Identifiable Information in User-Generated Content that you post to public exchanges on our Website, others will be able to read, collect, re-publish, and otherwise freely use the Personally Identifiable Information. We are not responsible for Personally Identifiable Information you decide to include in User-Generated Content that you post in public forums, and we will not take down, remove, or edit User-Generated Content, except as required by Applicable Law. If you include in your User-Generated Content any Personally Identifiable Information relating to others, you represent that you have full permission and authority to do so.
    5. Requesting Information. You can request information directly from Naani via the Site. To do so, you must provide certain Personally Identifiable Information, such as your name, your mailing address or email address, other specified contact information, and a description of the information you are requesting.
    6. Newsletters and Special Offers. You can provide us with Personally Identifiable Information so that we can send you (i) newsletters about Naani, our Services, and information about issues that we believe may be of interest to you, and (ii) special offers about our products and Services.
    7. Beacons and Tags. The Website may use certain data collection technologies that rely on (i) beacons; (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Website have been visited or to measure the effectiveness of searches that users perform on our Website. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, Online Activity Information and, in certain instances, Personally Identifiable Information.
    8. Device Identifiers; Logs; IP Addresses. To determine whether your device is supported by our Website, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Website, as well as the presence of any software that our Website may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Online Activity Information. 
    9. Click-Throughs. We may send email messages or display links that use a “click-through URL” linked to our Website or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Online Activity Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications. 
    10. Other Technologies and Data Sources. We currently do not augment the Personally Identifiable Information that you provide to us with data from other third-party sources, such as privately-held marketing or analytics databases. We do not, for example, link your Personally Identifiable Information with third-party demographic information (such as age, sex, household income, job industry, or job title). If we later choose to use these data sources, or technologies other than those listed above in this Section 4 (How We Collect Your Information), we will treat any information we collect or generate in that manner in full accordance with this Privacy Policy. 
  2. Cookie Privacy Policy. This section provides Naani’s cookie policy (“Cookie Privacy Policy”) and describes how Naani uses Cookies (as defined below) and similar technologies. 
    1. Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. Naani uses cookies, web beacons and similar technologies (“Cookies”) to enhance your user experience, understand your usage of the Website and to perform analytics. Cookies may also be set by other websites or services that run content on the page you are visiting. The provision of your data via Cookies is voluntary except for those Cookies that we place on your device that are necessary for the performance of the Website. We use “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Website. A persistent Cookie may remain on your device for much longer until you manually delete it.
    2. Use. Cookies can contain the following information about you and your use of the Website: browser type, search preferences, data relating to which pages of the Website that you have visited and the date and time of your use. We use Cookies for the following purposes:
  1. To enable and support security features, prevent fraud, and protect your data from unauthorized access.
  2. To enable features and help us provide you with personalized content.
  3. To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.
  4. Third-Party Cookies. We use the following third-party Cookies on the Website:
  5. [Please provide a list of cookies used on the Website].
  6. Opting Out. You can control and/or delete cookies as you wish – for details, see http://www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by Naani.
  1. GDPR.  We do not intentionally target or otherwise seek to collect or receive Personally Identifiable Information from residents outside of the United States, such as from the European Economic Area.  As such, we do not specifically address foreign laws such as the EU General Data Protection Regulation (“GDPR”) in this Policy, and will protect all Personally Identifiable Information as described by this Privacy Policy
  2. How We Use this Information.  We use the information we collect or process, including Anonymous Information, Online Activity Information, and Personally Identifiable Information, as permitted under Applicable Law, including where the use is based on (i) the consent you provide to us at the point of collection as set out in Section 2.2 (Consent by Registered Users); (ii) performance of our agreement to provide you with the Services; (iii) compliance with our legal obligations; and/or (iv) our Legitimate Interests, as well as a third party’s Legitimate Interests. More specifically, we use the information we collect for some or all of the following:
Our Use of the InformationBases for Our Use
To provide you with the information and Services you request and, specifically, to allow us to send you information via email Performance and management of our agreement with you
To allow you to post User-Generated ContentPerformance and management of our agreement with youYour Consent
To respond to your inquiries and fulfill your purchasesPerformance and management of our agreement with you
To customize your visit to and use of the WebsiteOur Legitimate Interests
To determine which Services and content (including marketing content) might interest you Your consentOur Legitimate Interests
To inform you of products and Services that we think would be appealing to you, whether the products or services are provided by us or by others and whether the products are services are available via our Website or via some other channel (including channels operated by third parties); this includes information in the form of recommendations and endorsements that we might provide Your consentOur Legitimate Interests
To enable our affiliates and sponsors to inform you of their products and services that may be of interest to you through their own direct marketing activitiesYour consentOur Legitimate Interests
To track access to and use of our Website, and conduct data and other analyses, including anonymization and aggregation of Personally Identifiable Information Our Legitimate Interests
To perform internal administration, auditing, operation, and troubleshooting for our Website Our Legitimate Interests
To engage in the activities specified in Section 6 (How We Share This Information)Our Legitimate InterestsCompliance with our legal obligationsPerformance and management of our agreement with you
To evaluate and improve our Website and our communications, and to develop and test new services and contentOur Legitimate Interests
To comply with Applicable LawCompliance with our legal obligations

Note that when determining the bases for our use of your information, we rely on what we consider to be the most appropriate basis, even if there are multiple bases available in connection with our use. 

  1. How We Share this Information. We value your privacy, and we share the information we collect only in the manner set out below.
    1. Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Website, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personally Identifiable Information, Online Activity Information, and Anonymous Information as applicable. The following are examples:
  • We may use service providers: (i) to fulfill your orders; (ii) to provide customer service (where applicable) and facilitate payment; (iii) to process and distribute email or SMS messaging; and (iv) to manage promotions, special offers, and similar activities. These service providers generally require access to your Personally Identifiable Information in order to perform these services. 
  • We may use analytics service providers to assist us in understanding and using Online Activity Information and other information that we collect via the Site. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout
  • We may use service providers to anonymize and aggregate Personally Identifiable Information in order to generate Anonymous Information. 
  • We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and Online Activity Information, identify others who might share those interests and attributes. We then use this information to reach out to relevant market segments to provide them information concerning the Website. 
  • Online Activity Information may also be used by our advertising service providers to support Online Behavioral Advertising, or Interest-based advertising as it is sometimes called. If you would like to learn more about Online Behavioral Advertising, please visit the “For Consumers” page on the AboutAds website. If you prefer that our advertising service providers do not know which pages you viewed on our website, you can opt-out on the “Consumer Choice Page” also located on the AboutAds website. Note: If you opt out of Online Behavioral Advertising, you may still receive online advertising from Naani. Opting out from a specific advertising provider means that the ads you do receive will not be based on your preferences or behavior. Also, In order for Online Behavioral Advertising opt-outs to work, your browser must be set to accept cookies. Because the opt-out is registered for the specific computer and browser you use when submitting the opt-out, you will need to opt-out again if you delete the cookies from your computer, buy a new computer, access our website from a different computer, login under a different screen name, or change web browsers.

We do not permit our service providers to use the Personally Identifiable Information we give them for any purpose other than providing services to us. 

  1. Questions of Harm; Legal Process. We may disclose your Personally Identifiable Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary: 
  • To comply with legal process; 
  • To protect and defend our rights and property, including the Website and associated content; 
  • To protect against misuse or unauthorized use of our Services; 
  • To protect the personal safety or property of Website users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
  • To cooperate with public and government authorities including, where required, authorities outside your jurisdiction.

While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personally Identifiable Information, we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted. 

  1. Transfer of the Website. We shall be entitled to transfer information that we collect (including Personally Identifiable Information) to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that are compatible with those set out in this Privacy Policy. 
  2. Our Affiliates and Sponsors. We may choose to rely on and share the information we collect with our affiliates. By “affiliate” we mean an entity that is closely related to us, such as an entity that controls, is controlled by, or is under common control with, Naani Botanicals, LLC. Our affiliates will be bound by the terms of this Privacy Policy.  We may also share your information with our sponsors for our sponsors to conduct direct marketing activities.
  1. Banner Ads; Advertising Profiles.  Our Website may include the use of ad banner partners for the serving and/or targeting of ads, promotions, and other marketing messages.  These ads may be provided by our sponsors, or they may be provided by a third party ad service provider or advertiser (collectively, “Advertisers”).  These Advertisers may use traditional banner ads, or other advertising methods, such as advertising using profiles and related content, as well as cookies and active tracking technology.  An Advertiser may place or utilize its own cookie on your browser and may use Anonymous Information about your visit to our Site, such as the number of times you have viewed an ad.  If the Advertiser requests that you provide Personally Identifiable Information to it, please be aware that the Advertiser’s use and collection of this information will be governed by its privacy policy, and not our Privacy Policy.  We recommend that you review the Advertiser’s privacy policy before providing Personally Identifiable Information.  
  2. How We Safeguard the Information We Collect. We recognize the sensitivity of our users’ Personally Identifiable information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this Information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personally Identifiable Information in accordance with Applicable Law.
  3. Our Retention of Data. We retain Personally Identifiable Information for the period of time necessary to fulfill the purposes for which we obtained the Personally Identifiable Information and consistent with Applicable Law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations). 
  4. Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personally Identifiable Information we process, and (ii) to limit the Personally Identifiable Information that we process to that which is reasonably necessary for the purposes for which we obtained the information. 
  5. Accessing and Updating Your Information. If you would like to review, correct, or update the Personally Identifiable Information that you have provided to us, or if you would like to request an electronic copy of this Personally Identifiable Information for purposes of transmitting it to another company (to the extent Applicable Law provides you with this right to data portability) you may make such requests by us as provided in Section 21 (Contact Us).
  6. Your Right to Opt-Out; Object to Processing; Deleting Information
    1. Unsubscribing to Email or Third Party Marketing. If you no longer wish to receive email messages from us or to have your Personally Identifiable Information shared by us with our sponsors for their own marketing purposes, you can opt out of such uses by either (1) following the “unsubscribe” instructions located near the bottom of each email message, or (2) contacting us as provided in Section 21 (Contact Us).
    2. Deleting Information. If you request, we will take reasonable steps to remove your name and email address from our databases, within the time frames (if any) set out in Applicable Law. Please understand, however, that if you request the deletion of your information, you will no longer be able to receive our Services. In addition, it may be impractical (or essentially impossible) to remove the requested information completely, due to requirements promulgated by Applicable Law, and/or data backups and records of deletions. As such, certain Personally Identifiable Information may remain in our databases following the deletion of your account; we will continue to treat the remaining information (if any) in accordance with this Privacy Policy and Applicable Law. 
    3. Objections. If you object to our processing of your Personally Identifiable Information, and a request for us to delete this Information is not, in your view, sufficient, please contact us as provided in Section 21 (Contact Us). 
    4. Anonymous Information. We will not delete Anonymous Information from our database, and nothing in this Privacy Policy restricts our use of Anonymous Information.
  7. Advisory Regarding Participation by Children and Teens. Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html
  8. Relationship to Terms of Use; Incorporation of Terms of Use. This Privacy Policy must be read in conjunction with our Terms of Use, and the provisions of our Terms of Use are incorporated herein. To the extent the Terms of Use conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.
  9. Notice of Privacy Rights to California Residents.  The following provisions of this Section 17 (Notice of Privacy Rights to California Residents) apply if you are a California resident.
    1. Shine the Light Law.  California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.
  10. California Consumer Privacy Act.  Naani makes the following disclosures regarding the California Consumer Privacy Act:
    1. No Financial Incentives.  Naani does not provide a financial incentive or a price or service difference to individuals in exchange for the retention or sale of their Personal Information. We may send offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or “Do Not Sell” request has been submitted. Naani does not offer financial incentives to deter consumers from making such requests. Naani will not discriminate against any consumer for exercising their privacy rights, including those provided by applicable law.
    2. Consumer Reporting.  Naani will endeavor to report consumer request metrics when they become available.
    3. Questions.  If you have any questions about our privacy practices, including in connection with the California Consumer Privacy Act, please contact us as directed in Section 21 (Contact Us).
  1. Do Not Track Notice.  Our Website does not change its behavior when receiving “Do Not Track” signals from browser software.
  2. Complaints.  We want your feedback. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 21 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.
  3. Changes to this Privacy Policy. From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in Applicable Law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Website and/or notifying you of the change via the Website, email, or other methods. Your continued use of the Website following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy.
  4. Contact Us. If you have any questions about this Privacy Policy, the Website, or your dealings with this Website, please contact us at melissa@naanilove.com
  5. Effective Date. The effective date of this Privacy Policy is February 1st, 2021.
  6. Definitions. Below are definitions applicable throughout this Privacy Policy. Additional terms are defined in context.
    1. Applicable Law” means statutes, regulations, and any other laws that apply to the Website, the Services or the Website. 
    2. Legitimate Interest” means that there is a good reason for the processing your Personally Identifiable Information, and that the processing is carried out in a way that minimizes impacts (if any) on your privacy rights and interests. The term “Legitimate interest” also refers to our use of information in ways that you would reasonably expect, based on your relationship to us. For example, there is a Legitimate Interest in collecting and processing your Personally Identifiable Information: (i) to safeguard our Website, networks, content, and related information and resources; (ii) to administer and generally conduct our business; and (iii) to prevent fraud.