CALIFORNIA PRIVACY POLICY

California Specific Privacy Notice

Last Updated: August 7, 2020


  1. INTRODUCTION
  2. This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“California Specific Privacy Notice”) together with our Terms and Conditions, available on the websites at www.sundayriley.com and https://edit.sundayriley.com/ supplements the information containedinthe Privacy Policies of Sunday Riley Modern Skincare, LLC and Sunday Edit (“SRMS,” we”, “us” or “our”) and our affiliate websites, subdomains, mobile versions and anyassociatedapplications (collectively, the “Site”). Sunday Edit is owned by Sunday Riley Modern Skincare, LLC. This California Specific Privacy Notice shall govern SRMS’s data collection and usage regarding California residents, including but notlimited to,offline and online. 

    Any terms defined in the California Consumer Privacy Act (“CCPA”) have the same meaning when used in this California Specific Privacy Notice. California residents with disabilities may access this notice in an alternative format by emailing usat:hello@sundayriley.com.

    As the CCPA is not final, this California Specific Privacy Notice reflects our good faith understanding of the CCPA as of the date of last revision reflected in the Effective Date above. SRMS will continue to revise our California SpecificPrivacyNotice to reflect the development of the CCPA and our understanding as to how it relates to our data practices.

  1. USE OF THE SITE BY MINORS
  2. You must be the age of Majority or older (18 in most states of the United States; older in some jurisdictions) to become a member of the Site. While individuals under the age of 18 (but not younger than 13) may utilize the Site, they must dosoonly with the consent and involvement of a parent or legal guardian, under such persons account and otherwise subject to our Terms and Conditions. SRMS does not seek through this Site to gather personal information from or about persons undertheage of 18. If we become aware that you are under the age of Majority and are attempting to or have submitted personal information via the Site, we will not accept such information and we will take steps to remove such information from ourrecords.This may involve us having to access and verify your age and other relevant details.

  1. INFORMATION WE MAY COLLECT FROM YOU 
  2. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular,wehave collected the following categories of Personal Information from consumers within the last twelve (12) months:

    Category

    Examples

    Collected

    A. Identifiers.

    A real name, alias, postal address, email address, unique personal or online identifier,

    IP address, account name, Social Security number driver’s license number, passport number, date of birth or other similar identifiers.

    YES

    B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

    A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education,employment,employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category mayoverlap withother categories.

    YES

    C. Protected classification characteristics under California or federal law.

    Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth andrelatedmedical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

    NO

    D. Commercial information.

    Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    YES

    E. Biometric information.

    Physiological, behavioral and biological characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity or other identifier oridentifyinginformation, such as, fingerprints, or and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

    NO

    F. Internet or other network activity.

    Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. 

    YES

    G. Geolocation data.

    Physical location.

    YES

    H. Sensory data.

    Audio, electronic, visual, thermal, olfactory, or similar information.

    NO

    I. Professional or employment-related information.

    Current or past job history or performance evaluations.

    YES

    J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

    Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, studentfinancialinformation or student disciplinary records.

    YES

    K. Inferences drawn from other Personal Information.

    Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    NO

  1. WE OBTAIN THE CATEGORIES OF PERSONAL INFORMATION LISTED ABOVE FROM THE FOLLOWING CATEGORIES OF SOURCES:
    • When you register with us, we ask for information such as your name, postal address, zip code, email address, and telephone number. We also acquire your Internet protocol address and/or mobile device identification, which certainjurisdictionsconsider to be PI because it could be used to identify an individual or device if it were combined with other identifying information.
    • We may capture user information when users send us questions or comments via e-mail. Information collected in this manner will only be used to contact the user and/or respond to the user’s inquiry/issue. Sending us an e-mail will not enrollyouon our e-mail list unless you specifically request it.
    • For purchases made on the Site, a third-party payment processor such as Authorize.net, Amazon Pay or Apple Pay may collect your name, email address, postal address, contact details and credit or debit card information. By making a purchase,yougrant to us and to all other persons and entities involved in the operation of the Site, the right to use, store, monitor, retrieve and transmit your account information in connection with the operation of the Site and as otherwiseprovidedherein. You also agree that such access and use of your personal information is governed by their privacy policies. We are not responsible or liable for the content, activities or privacy policies of any third party websites.Accordingly, pleaserefer to their respective privacy policies.
    • We generally do not request on or through the Site other information that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers), personalhealthinformation, or government issued identification numbers (e.g., social security number, drivers’ license number, or passport number), although we reserve the right to do so when such information is necessary to offer you certain services.
    • We may also obtain your personal information through your use of social media and/or other websites such Twitter, Facebook, YouTube, Pinterest, Instagram, Tiktok or LinkedIn, depending on your settings or the privacy policies of thesewebsites.To change your settings on these services, please refer to their respective privacy notices.

    Note, if you do not provide the mandatory Personal Information for a particular activity, we may not be able to offer the required information for you to engage in that activity. 

  1. HOW WE USE THE INFORMATION WE COLLECT
  2. If you elect to provide SRMS with Personal Information, we may use it as needed to provide goods and services to you. These uses are based in our legitimate business interests in providing goods and services to you and/or fulfillment ofourcontractual obligation to deliver the goods and services you have requested. We have balanced these business needs carefully with your privacy rights and these uses do not improperly infringe on your privacy and confidentiality rights. We mayuseyour Personal Information in the following ways:

    • to contact users with updates and relevant information about our products and services because they have signed up to do so through our Site;
    • to provide users with personalized offers, promotions, news, events and other information relevant to them because they have signed up to do so through our Site;
    • to quickly process user requests for information and to allow us to respond efficiently to user questions;
    • to monitor Site statistics;
    • to respond to or satisfy legal requirements, such as a court order, a subpoena, or a law enforcement agency’s or other public agency’s request;
    • to help prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Site, to help protect the security or integrity of our Site, or to enable us totakeprecautions against liability;
    • to provide information to service providers or such companies who provide support for the operations of our Site and who do not use or disclose the information for any other purpose;
    • to administer a contest, promotion, survey, or other features; and
    • to allow us to disclose your information to the extent permitted by law.
  1. HOW WE SHARE INFORMATION
    • SRMS is an Amazon Associate. In connection with the Amazon Affiliate Program, Amazon may monitor, record, use and disclose personal information about you obtained in connection with SMRS’ display of special links and program content(pleasereview the applicable terms and policies, including the privacy and data gathering practices of Amazon for more information); 
    • SRMS has teamed up with Commission Junction LLC, a Conversant company (“CJ Affiliate”), to spread the word out about SRMS! CJ Affiliate may collect and share personal information about you, such as your full name, home address, telephonenumberor email address, to help us provide digital advertising on browsers, mobile applications and televisions, in a variety of ways, from banner and video ads to coupon codes. For more information about CJ Affiliate or to opt-out, pleasereview theirapplicable terms and policies;
    • SRMS has partnered up with ShopStyle Inc., part of the Rakuten Group ("ShopStyle"), to grow its brand awareness! Accordingly, ShopStyle may collect and share your personal information, such as your name, email address, mailing address,phonenumber and payment information to its service providers that perform marketing services and other business operations on their behalf. For more information about ShopStyle or to opt-out, please review their applicable terms and policies;
    • Subsidiaries, Site Consultants and Service Providers. We may disclose personal information to our subsidiaries, third party consultants and service providers (such as providers of hosting, support, maintenance; third partypaymentprocessing agencies; and remedial and repair services) to the extent that they require access to our databases, or the information contained in our databases, to service us and the Site;
    • Enforcement of Rights/Security. We reserve the right to release personal information (i) when we are under legal compulsion to do so (e.g. we have received a subpoena) or we otherwise believe that the law requires us to doso,(ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or our safety, the safety of our users, or the safety of others, or (iii) as we deem necessary to resolve disputes, troubleshoot problems,preventfraud and otherwise enforce the Privacy Policy and other Site user agreements;
    • Reorganization or Sale. In the event that we merge with or become a part of another organization, or in the event that we are sold, we sell all or substantially all of our assets, or we are otherwise reorganized, theinformationyou provide will be one of the transferred assets to the acquiring or reorganized entity;
    • To Help Protect Minor Users of Our Site. In the event that the safety of our users is threatened, and we are able to do something about that by sharing PI with third parties, we reserve the right to do so. This may be donetoprevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Site, to help protect the security or integrity of our Site, or to enable us to takeprecautionsagainst liability;
    • As Otherwise Allowed by Law. We may transfer personal information to third parties where we are expressly authorized by applicable law to do so;
    • Aggregated Information. We may aggregate information that you provide with information provided by other individuals in such a manner that the information is not personally identifiable to you, and we may transfer thataggregatedinformation to third parties;
    • We may make available services such as blogs, message boards and chat functionality to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on the Sitebecomespublic information, and may be available to visitors to the Site and to the general public. In addition, when you choose to make a posting on such services certain personal information will be available for other users to view. We urgeyou toexercise discretion and caution when deciding to disclose personal information about you, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE BY ANY THIRD PARTY OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSETHROUGHANY SUCH SERVICES OR OTHERWISE ON THE SITE; and
    • With your express consent.
  1. YOUR RIGHT TO ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
  2. You have the right to request that we disclose certain information about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

    1. The categories of Personal Information we collected about you.
    2. The categories of sources for the Personal Information we collected about you.
    3. Our business or commercial purpose for collecting or selling that Personal Information.
    4. The categories of third parties with whom we share that Personal Information.
    5. The specific pieces of Personal Information we collected about you (also called a data portability request).
    6. If we sold or disclosed your Personal Information for a business purpose, a separate list disclosing:
      1. sales, identifying the Personal Information categories that each category of recipient purchased; and
      2. disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
        1. Please note that we do not sell your Personal Information.
  1. DELETION REQUEST RIGHTS
  2. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and directourservice providers to delete) your Personal Information from our records, unless an exception applies.

    You may object to SRMS using your Personal Information for the above purposes at any time by emailing us at: hello@sundayriley.com. If you do so, SRMS will cease using your Personal Information for the above purposes (i.e., under alegitimateinterest set out above) and remove it from its systems unless such Personal Information is permitted to be used by SRMS for another purpose set out in this California Specific Privacy Notice or SRMS determines and demonstrates acompellinglegitimate interest to continue in processing your Personal Information.

    We may deny your deletion request if retaining the information is necessary for us or our service providers to:

    1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwiseperformour contract with you.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Debug products to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible orseriouslyimpair the research's achievement, if you previously provided informed consent.
    7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    8. Comply with a legal obligation.
    9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  1. EXERCISING ACCESS, DATA PORTABILITY AND DELETION RIGHTS
  2. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing contacting hello@sundayriley.com. 

    Regarding our marketing materials, you may also withdraw your consent at any time by clicking on the “unsubscribe” link at the bottom of each email or by emailing hello@sundayriley.com. If an individual withdraws their consent toreceivingmarketing emails, we will still be able to send them essential service communications that are necessary for the performance of our services. 

  1. AUTHORIZED AGENTS
  2. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information if you provide the authorized agent writtenpermissionsigned by you or pursuant to a valid Power of Attorney. You may also make a verifiable consumer request on behalf of your minor child. When you use an authorized agent to submit a request, we may require you to:

    1. Provide the authorized agent signed permission to do so. 
    2. Verify their own identity directly with the business.
    3. Directly confirm with the business that they provided the authorized agent permission to submit the request. 
  1. VERIFIABLE CONSUMER REQUESTS
  2. The verifiable consumer request must:

    1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative (such as your name and last product purchased).
    2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Informationprovidedin a verifiable consumer request to verify the requestor's identity or authority to make the request.

    You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 

  1. RESPONSE TIMING AND FORMAT
  2. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mailorelectronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request,ifapplicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision andprovideyou with a cost estimate before completing your request.

  1. SALE OF PERSONAL INFORMATION
  2. We do not sell Personal Information. 

  1. NON-DISCRIMINATION
  2. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    1. Deny you goods or services.
    2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    3. Provide you a different level or quality of goods or services.
    4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of services.
  1. CHANGES TO THIS CALIFORNIA SPECIFIC PRIVACY NOTICE
  2. We may, in our sole discretion, modify or revise this California Specific Privacy Notice at any time. Such changes or updates are effective immediately after we give notice of the change or update, which we may do so by revising the EffectiveDateat the top of the California Specific Privacy Notice or by otherwise posting on the Site, by email, conventional mail and/or by any other means that provides reasonable notice. If you are subscribed to one of our mailings, you must provide uswithyour correct email address and make sure that email from us is not filtered from your inbox by your ISP or email software. You agree that your use of the Site, after the date such notice is posted, means that you accept and agree to be boundbysuch modifications or revisions to the California Specific Privacy Notice. You agree that we shall not be liable to you for any damages that might result from any changes to this California Specific Privacy Notice, if any.

  1. CONTACT US
  2. Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to hello@sundayriley.com.

    Copyright © 2020 Sunday Riley Modern Skincare, LLC.All Rights Reserved.

Effective Date: May, 2019

This is the Privacy Policy of Sunday Riley Modern Skincare, LLC and its subsidiary companies (collectively “SRMS,” “we,” or “us”), which applies to the websites located at www.sundayriley.com, edit.sundayriley.com and its affiliate sites, subdomains, mobile versions and any associated applications (collectively, the “Site”).

Sunday Riley Modern Skincare, LLC understands that your privacy is important to you and that you care about how your personal information is used and shared online. We respect and value the privacy of everyone who visits this Site, and will only collect and use personal information in ways that are described here (whether or not you have an account with us), and in a manner that is consistent with our obligations and your rights under the law.


In conjunction with the Terms and Conditions, this Privacy Policy sets out the basis on which any personal information you provide will be collected, processed, used and stored by us. Please read it carefully. By visiting this Site, you are accepting and consenting to the practices described in this Privacy Policy, which may be amended in our sole discretion from time to time.  If you use the Site after we have published such changes, you will be agreeing to be bound by those changes.  If you do not agree to be bound by this Privacy Policy at any time, you should not use the Site.

 

  1. Registration on our Site

You must be at least the age of Majority (18 in most states of the United States; older in some jurisdictions) to register with us.  Please do not provide any of your information to us if you are under the age of 18.  We do not knowingly collect or maintain any PII (defined below) about anyone under age of 18, nor is this information knowingly used by us for any marketing or promotional purposes.

 

If we become aware that you are under the age of Majority and are attempting to or have submitted personal information via the Site, we will not accept such information and we will take steps to remove such information from our records. This may involve us having to access and verify your age and other relevant details.

 

  1. Introduction

This Privacy Policy explains the following:

  1. What information we collect about you and why;
  2. How we use information about you;
  1. How your information may be shared;
  1. How we store and process information about you;
  2. When and how we communicate with you;
  3. How long we may keep personal information about you;
  4. How you can opt-out from receiving communications from us;
  5. Analysis tools and our use of cookies;
  6. Information over the Internet and other Sites;
  7. Offensive or inappropriate content;
  8. Legal disclaimer;
  9. How to contact us;
  1. What information we collect about you and why:

We may collect two types of information: personally identifiable information (“PII”) and information that is not personally identifiable (“Non PII”).

  1. What PII Do We Collect? 
  • When you register with us, we ask for information such as your name, postal address, zip code, email address, and telephone number.  We also acquire your Internet protocol address and/or mobile device identification, which certain jurisdictions consider to be PII because it could be used to identify an individual or device if it were combined with other identifying information.
  • We may capture user information when users send us questions or comments via e-mail. Information collected in this manner will only be used to contact the user and/or respond to the user’s inquiry/issue. Sending us an e-mail will not enroll you on our e-mail list unless you specifically request it.
  • For purchases made on the Site, a third-party payment processor such as Authorize.net, Amazon Pay or Apple Pay may collect your name, email address, postal address, contact details and credit or debit card information. This record will be stored and processed in the United States and other countries (see further below under “How we use information about you” and “How we store and process information about you”). By making a purchase, you grant to us and to all other persons and entities involved in the operation of the Site, the right to use, store, monitor, retrieve and transmit your account information in connection with the operation of the Site and as otherwise provided herein. You also agree that such access and use of your personal information is governed by their privacy policies. We are not responsible or liable for the content, activities or privacy policies of any third party sites. Accordingly, please refer to their respective privacy policies.
  • We generally do not request on or through the Site other information that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers), personal health information, or government issued identification numbers (e.g., social security number, drivers’ license number, or passport number), although we reserve the right to do so when such information is necessary to offer you certain services.
  • We take reasonable precautions to protect the confidentiality and security of your personally identifiable information by using industry recognized security safeguards such as site monitoring, secured networks and servers, firewalls and/or encryption. When we ask for sensitive information, we protect it through the use of encryption during transmission, such as SSL (Secure Socket Layer). Unfortunately, no method of transmission over the Internet is completely secure. Therefore, while we strive to protect your personally identifiable information within industry standards, we cannot guarantee its absolute security.
  • We may also obtain your personal information through your use of social media and/or other websites such as Facebook, Twitter, Instagram, YouTube or Amazon, depending on your settings or the privacy policies of these websites. To change your settings on these services, please refer to their respective privacy notices.

 

  1. What Non PII Do We Collect?
  • Some of the information that we acquire cannot identify, distinguish or trace you or your device, even if combined with other identifying information, and some information that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your device, but is instead used in an anonymous way, often aggregated with other anonymous information about other users.
  • If your personally identifiable information changes, or if you no longer choose to use our services or the Site, you can contact customer service by e-mail, telephone or postal mail at the contact information listed below to assist you with changes to your account. To the extent your account closes or becomes inactive, we will continue to protect your information as described in this Privacy Policy.

  

  1. How we use information about you:
  1. We may use the PII we collect in the following ways:
  • to contact users with updates and relevant information about our products and services because they have signed up to do so through our Site. If you would no longer like to receive promotional e-mails or other communications from us, please refer to the “How you can opt-out from receiving communications from us” Section below;
  • to provide users with personalized offers, promotions, news, events and other information relevant to them because they have signed up to do so through our Site;
  • to quickly process user requests for information and to allow us to respond efficiently to user questions;
  • to monitor Site statistics;
  • to respond to or satisfy legal requirements, such as a court order, a subpoena, or a law enforcement agency’s or other public agency’s request;
  • to help prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Site, to help protect the security or integrity of our Site, or to enable us to take precautions against liability;
  • to provide information to service providers or such companies who provide support for the operations of our Site and who do not use or disclose the information for any other purpose;
  • to administer a contest, promotion, survey, or other features; and
  • to allow us to disclose your information to the extent permitted by law.

 

  1. How your information may be shared:

Except as set forth below, we do not sell, trade, or otherwise transfer to third parties our users’ PII unless we receive their consent. That being said, in the following situations, we may share PII with outside parties:

  • In connection with their content and advertisements, our Affiliates may collect personally identifiable information. For example:
  • SRMS is an Amazon Associate. In connection with the Amazon Affiliate Program, Amazon may monitor, record, use and disclose personal information about you obtained in connection with SMRS’ display of special links and program content (please review the applicable terms and policies, including the privacy and data gathering practices of Amazon for more information); and 
  • SRMS has teamed up with Commission Junction LLC, a Conversant company (“CJ Affiliate”), to spread the word out about SRMS! CJ Affiliate may collect and share personal information about you, such as your full name, home address, telephone number or email address, to help us provide digital advertising on browsers, mobile applications and televisions, in a variety of ways, from banner and video ads to coupon codes. For more information about CJ Affiliate or to opt-out, please review their applicable terms and policies.
  • Subsidiaries, Site Consultants and Service Providers. We may disclose personal information to our subsidiaries, third party consultants and service providers (such as providers of hosting, support, maintenance; third party payment processing agencies; and remedial and repair services) to the extent that they require access to our databases, or the information contained in our databases, to service us and the Site;
  • Enforcement of Rights/Security. We reserve the right to release personal information (i) when we are under legal compulsion to do so (e.g. we have received a subpoena) or we otherwise believe that the law requires us to do so, (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or our safety, the safety of our users, or the safety of others, or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce the Privacy Policy and other Site user agreements;
  • Reorganization or Sale. In the event that we merge with or become a part of another organization, or in the event that we are sold, we sell all or substantially all of our assets, or we are otherwise reorganized, the information you provide will be one of the transferred assets to the acquiring or reorganized entity;
  • To Help Protect Minor Users of Our Site. In the event that the safety of our users is threatened, and we are able to do something about that by sharing PII with third parties, we reserve the right to do so. This may be done to prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Site, to help protect the security or integrity of our Site, or to enable us to take precautions against liability;
  • As Otherwise Allowed by Law. We may transfer personal information to third parties where we are expressly authorized by applicable law to do so;
  • Aggregated Information. We may aggregate information that you provide with information provided by other individuals in such a manner that the information is not personally identifiable to you, and we may transfer that aggregated information to third parties;
  • We may make available services such as blogs, message boards and chat functionality to which you are able to post information and materials.  Please note that any information you disclose through such services or otherwise on the Site becomes public information, and may be available to visitors to the Site and to the general public.  In addition, when you choose to make a posting on such services certain personal information will be available for other users to view.  We urge you to exercise discretion and caution when deciding to disclose personal information about you, or any other information, on the Site.  WE ARE NOT RESPONSIBLE FOR THE USE BY ANY THIRD PARTY OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH ANY SUCH SERVICES OR OTHERWISE ON THE SITE; and
  • With your express consent.
  1. How we store andprocess information about you:

This Site is hosted in the United States. In order to communicate with you about products, local events, offers and opportunities, the information that we collect from you may be transferred to, stored, used and processed by SRMS in the United States or one of our service providers based in the United States or outside of the United States.  Such entities may be engaged in, among other things: (i) preparing and sending newsletters to which you subscribe; (ii) the processing of payment details; and (iii) the provision of support services. 

If you are visiting from the European Union or other regions with laws governing information collection and use that may differ from United States law, please note that you are transferring your personal information to the United States. The laws of some countries may not provide the same levels of protection of personal information as your home country, particularly if you are resident in the European Union.  By submitting information, you agree to the collection, transfer, storage, use and processing of information about you for the purposes described in this Privacy Policy.  When you provide personal information to us or our service providers or vendors, you consent to the processing of your information in the United States as the Site is operated in the United States.  We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Policy, and that all information you provide to us is stored on our secure servers or those of our service providers.  

YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR INFORMATION WITH US, OR MAKE USE OF THIS SITE. 

TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISIDICTION OTHER THAN THE UNITED STATES.  HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION.  TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.

 

  1. When and how we communicate with you:

We may use the information we collect to contact you by mail, email and telephone (including automated calls, and by SMS text messages and other multimedia electronic messages such as picture messaging).

We will not send you unsolicited premium rate SMS messages (which are SMS messages you pay to receive), although your service provider may impose a charge on anymessages that you receive.  Please check with your service provider for details. 

You can unsubscribe from promotional emails and other commercial communications by following the instructions contained within the communication. Please note that due to marketing production schedules you may receive any messages already in production.

 

  1. How long we will hold personal information about you

We will hold personal information about you on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with SRMS, subject to any applicable laws and/or regulations. In the case that you wish to cancel your registration as a member of the Site once an account is deleted, we will not use the personal information about you other than for administrative purposes. 

Where you contribute to the Site, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted.

 

  1. How you can opt-outfrom receiving communications from us:

At any time you can add or remove your name from a SRMS list by contacting us at hello@sundayriley.com. 

We will endeavor to comply with your request as soon as reasonably practicable.  Please keep in mind that if you opt-out of receiving promotional messages from this Site, we will continue to send you transactional messages and important account-related information regarding this Site or products orservices offered through this Site.

 

  1. Analysis Tools and our use of cookies

We may use cookies, log files, clear gifs, and/or similar devices to identify you, to keep track of the user’s interactions with the Site, and to and enhance certain activities available on the Site. These devices are small text or other electronic files that are used for user-identification purposes, record-keeping purposes, and to increase the ease of use of the websites. We may use persistent or not-persistent cookies. Users can remove or reject persistent cookies by following the directions provided in their Internet browser’s “help” file. If a user removes a persistent cookie or rejects persistent cookies, the functionality of the Site, or any part thereof, may be impaired or unavailable.

Third-party advertisers on the Site may place or recognize cookies and other technologies on your browsers in connection with their advertisements for statistical purposes; we have no control over cookies placed on the Site by third parties.

  1. Information over the Internet and other Sites 

The Internet is a global network and, therefore, there are times when information about you travels globally and may not always be completely secure.  If you provide us with information over the Internet, this will be at your own risk.  By using the Site, you agree and authorize us to process information in this way.  However, please be assured that we use commercially reasonable procedures and security features to prevent unauthorized access to information about you.

In an attempt to provide you with increased value, the Site may contain links to third party sites. These linked websites have separate and independent privacy policies or may have no privacy policy at all. We are not responsible or liable for the content, activities or privacy policies of such linked sites. Nonetheless, we seek to protect the integrity of the Site, and welcome any feedback about a linked site (including if a specific link does not work).

 

  1. Offensive or inappropriate content

If you find any link on our Site that is offensive for any reason, you are free to contact and inform us any moment. We will consider requests to remove links but we are not obligated to or so or to respond to you directly. You acknowledge that we have not reviewed and do not necessarily endorse the Content of sites, applications, destinations or services linked to or accessible from this Site and are not responsible for the Content or actions of any other sites, applications, destinations or services. Your linking to or accessing any other site, application, destination or service is at your sole risk.

 

  1. Legal disclaimer

We are not responsible nor will be liable to you in any way for events beyond our direct control. Because of the complex and constantly changing nature of our technology and business, we cannot guarantee nor do we represent that our performance will be error free, and to the maximum extent permitted by law we will not be liable for any direct, indirect, incidental, consequential or punitive damages or other loss suffered by you and relating to the use or release of your personal information.

 

YOUR CALIFORNIA PRIVACY RIGHTS

A California privacy law that went into effect on January 1, 2005, the “Shine the Light” law, allows California residents to obtain a list of third parties to whom a business has disclosed personal information if it shares such information with third parties for their direct marketing purposes. However, if a business adopts and discloses in its privacy policy a policy of not disclosing customers’ personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and by providing a cost-free means to exercise that right.

 

As stated earlier in this Privacy Policy, personal information submitted at the time of registration or submission may be used for marketing and promotional purposes only with the user’s permission. Whenever a user agrees to allow us to collect personal information, we provide the user with an option to prevent such information from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time by sending an email to hello@sundayriley.com.

Because the Site has a comprehensive privacy policy and provides you with details on how you may opt-in or opt-out of the use of your personal information by third parties for direct marketing purposes, we are not required to provide you with the third party list.

 

  1. How to contact us:

We welcome your questions, comments and concerns about privacy. Please contact us at hello@sundayriley.com with any questions or comments you may have regarding the privacy of your information.

 

Sunday Riley Modern Skincare, LLC

4444 Westheimer Rd, Ste G305

Houston, TX 77027                                                                                               

 

Copyright © 2019 Sunday Riley Modern Skincare, LLC. All Rights Reserved.