Privacy Policy

True Botanicals, Inc. Privacy Policy
Last Updated: June 27, 2019

 

This “Privacy Policy” describes the privacy practices of True Botanicals, Inc. (“Company,” “we,” “us” and “our”) in connection with the website, located at truebotanicals.com (the “Site”) and online services (“Services”), and the rights and choices available to individuals with respect to their information.

 

Table of Content

  • How to Contact Us
  • Children
  • Users Outside of the United States
  • Personal Information We Collect
  • Cookies and Other Technologies
  • How We Use Your Personal Information
  • How We Share Your Personal Information
  • Your California Privacy Rights
  • Third-Party Websites
  • Your Choices
  • Security of Personal Information
  • Retention
  • Changes to this Privacy Policy

 

How to Contact Us
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at the following address or phone number:
True Botanicals
522 Washington Street
San Francisco, California 94111
(415) 496-3023

 

A Note About Children
The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.  We encourage parents with concerns to contact us.

  

A Note to Users Outside of the United States
If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy.  In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.  By providing your data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

 

Personal Information We Collect

  • Information You Provide to Us.  Personal information you may provide to us through the Site or Services or otherwise communicate to us may include:
  • Account Registration. When you create an account to log into our network (“Account”), we may collect information such as, but not limited to, your first and last name, email and mailing addresses, phone number and password.
  • Purchases. If you sign up for a subscription or make a purchase, we will collect information needed to process and fulfill your order, including your credit card type, credit card number, expiration date, security code, billing address, and delivery address.
  • Contact Information. We collect your contact details (such as, but not limited to, your name, email and mailing addresses, phone number and professional title), and information about you when you provide it to us through the Site or otherwise.
  • Newsletters. If you sign up for a newsletter, we will collect your email address.
  • Feedback. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
  • Other Information. We may collect other information about you that is not specifically listed here and will use it in accordance with this Privacy Policy.

 

Information You Provide to Social Media Platforms.  
We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing or your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
If you choose to login to the Services via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Services, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address.  You can read more about your privacy choices in the “Third-party platforms or social media networks” portion of the “Your Choices” section below.

 

Information Collected via Technology.  
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

 

Information Collected from Others. 
We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners or publicly available sources.

 

Cookies and Other Technologies
We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Site and third-party websites and online services.  This information, which may be used internally or for marketing purposes generally, allows us, among other things, to improve the delivery of our Site to you, analyze usage, and measure traffic on the Sites.  We review our users' preferences, interests, demographics, traffic patterns, and other information so that we can better understand our audience and what they want.
  • First-party cookies. By showing how and when visitors use the Site, our cookies help us track user trends and patterns. Cookies make your experience easier by saving your preferences and passwords. We also use cookies that contain no personal information at all. These cookies help us estimate our audience size, determine which areas of the Site are the most popular, and serve targeted advertising.
  • Third-party cookies. Our advertisers, third-party analytics providers, and those who provide products and/or services through our site (e.g. Google Analytics, Facebook Pixel, Adroll, Google Ads, and Google Marketing Platform) may also assign their own cookies, a process we don't control. These third parties may use cookies, web beacons, and other storage technologies to collect or receive information from our Site and elsewhere on the Internet and use that information to provide measurement services and target ads.  Such information may include non-personally identifiable information (does not include your name, address, e-mail or telephone number) about your visits to our Sites and other sites, in combination with other non-personally identifiable information about your purchases and interests from other online and offline sources. Such technologies (i) help provide advertisements about goods and services of interest to you, (ii) help us market our products and services that may be of interest to you through advertisements on other websites and applications based on your past interactions with our Sites and (ii) help us understand how effective our marketing is.  For instance, EPE and third-party vendors may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the Google cookie) together to (i) inform, optimize, and serve ads based on your past visits to our website and (ii) report how your ad impressions, uses of ad services, and interactions with the foregoing are related to your visits to the Sites. In addition, we may use Google Analytics data, including but not limited to, geographic, demographics, and interest reporting information to recognize and understand user preferences, make improvements, and for other business purposes. The collection and use of information by these companies is governed by the relevant third-party's privacy policy and is not covered by our privacy policy.  Visit Google’s pages on How Google Uses DataAdvertising and Cookie technologies, Facebook’s Data Policy, and the NAI’s Consumer Opt Out page to read more about these information collection practices, to access your  advertising preferences, or how to limit use of your information for interest-based advertising.  For a full list of our analytics providers, please contact legal@truebotanicals.com. 
  • Flash Cookies. When we post videos, third parties may use local shared objects, known as flash cookies to store your preferences for volume control or to personalize certain video features.  Flash cookies are different from cookies because of the amount and type of data and how the data is stored.
  • Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com

 

How We Use Your Personal Data
To operate the Services. We may use your personal information to:
  • provide, operate and improve the Service
  • provide information about our products and services
  • establish and maintain your user profile on the Service
  • facilitate your to login to the Services via third-party identity and access management providers, such as Facebook
  • communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
  • communicate with you about events or contests in which you participate
  • understand your needs and interests, and personalize your experience with the Services and our communications
  • provide support and maintenance for the Services
  • respond to your requests, questions and feedback

    To send you marketing and promotional communications.  We may send you True Botanicals-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the “Opt out of marketing section” below.

     

    To serve advertisements. We work with advertising partners to display advertisements on the Services. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”


    To display user testimonials and feedback.  We often receive testimonials and comments from users who have had positive experiences with our Services.  We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city.  We obtain the user’s consent prior to posting his or her name along with the testimonial. In addition, we may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only.  If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with our Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages.  We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.


    To create anonymous data.  We may create anonymous data records from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.  We may use this Anonymous Data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and provide marketing services.

     

    How We Share Your Personal Information
    We do not share your personal information with third parties without your consent, except in the following circumstances or as described elsewhere in this Privacy Policy:


    Service Providers.  We may share your personal information with third-party service providers to:  provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company.  These third-party service providers are required not to use your personal information other than to provide the services requested by Company.


    Affiliates.  We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.


    Corporate Restructuring.  We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.


    Third-Party Companies.  We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site (“Third-Party Companies”).


    Third-Party Platforms and Social Media Networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network, we may disclose the personal information that you authorized us to share. We do not control the third-party’s use of your personal information.  

     

    Your California Privacy Rights
    If you are a user of the Site and a California resident, California’s “Shine the Light” law permits you to request and obtain from us once a year, free of charge, information regarding our disclosure of your personal information (if any) to third parties for their direct marketing purposes. If this law applies to you and you would like to make such a request, please submit your request in writing to legal@truebotanicals.com. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

     

    Third-Party Websites
    Our Site may contain links to third-party websites.  When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you.  We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites.  We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

     

    Your Choices Regarding Your Information.  You have several choices regarding use of information on our Services:
    • Email Communications. We will periodically send you free newsletters and emails that directly promote the use of our Site or Services.  When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information above). Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
    • Cookies.   Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Site may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.  
    • Access or Update Your Personal Information.  You may change any of your Personal Data in your Account by editing your profile within your Account or by sending an email to us at the email address set forth above.  You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).  When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
    • Third-Party Platforms or Social Media Networks. If you choose to connect to the Services via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Services using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party. 

     

    Targeted Online Advertising. 
    Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
    Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
    If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

     

    Security of Personal Information
    The security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.


    For online payments and/or Automated Clearing House (ACH) payouts, we use the payment services of Braintree (https://www.braintreepayments.com/) and/or Shopify (https://www.shopify.com/).  We do not process, record or maintain your credit card or bank account information.  For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to Braintree’s Privacy Policy (https://www.braintreepayments.com/legal/braintree-privacy-policy) and Shopify’s Privacy Policy (https://www.shopify.com/legal/privacy).

     

    Retention
    We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. 
    To determine the appropriate retention period for personal information, we may consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

     

    Changes to this Privacy Policy
    We reserve the right to modify this Privacy Policy at any time.  If we make changes to this Privacy Policy, we will post them on the Sites and indicate the effective date of the change.  If we make material changes to this Privacy Policy, we will notify you by email or through the Site. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services.
    Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.