Effective on June 22, 2023

This Privacy Policy (this “Privacy Policy”) is designed to help you understand how Sonsie Skin Inc. and our affiliates (the “Company”, “Sonsie” “we” or “our”) collect, process, store, and share personal information about our customers. It also explains what controls you have on how Sonsie collects and processes your information. The term “you” or “Customers” refers to customers or any person or entity who views, uses, accesses, browses or submits any content or material to www.sonsieskin.com (the “Site”).

Providing your personal information is voluntary and using the Site after the effective date of this document constitutes your acceptance of this Privacy Policy. If you do not agree to all the terms and conditions of our terms of use (the “Terms of Service”) and this Privacy Policy, do not use the Site.

1. Personal Information / Information we may collect

“Personal Information” means any information that may be used to identify an individual, including, but not limited to, a first and last name, a home or other physical address, a phone number, an email address, credit card information, payment information, and billing address. In general, you can visit the Site without telling us who you are or revealing any Personal Information about yourself. However, in order to access certain information, services, or features that may be contained on the Site, we may require you to provide Personal Information. For example, we will collect certain Personal Information if you choose to subscribe to a mailing list, participate in special offers, sweepstakes or other promotions, or send questions or comments to us via e-mail. If you would like to purchase any products or merchandise offered for sale on the Site using a credit card, we also will collect your credit card information and a shipping address.

We also may collect certain demographic information (such as gender or age) and information about your interests and preferences (“preferences information”). In many cases, such demographic and preferences information is optional. In other cases, such as online surveys, we collect this information on an anonymous basis. However, if we link any demographic or preferences information to any Personal Information, then such demographic and preferences information will be treated as Personal Information under this Privacy Policy.

In some cases, we may request permission to display your photos and accompanying captions from Instagram or other social media outlets.

For some features of the Site, you may be able to submit information about other people. For example, if you wish to purchase a product for another person on the Site and want it shipped directly to that person, you may submit the recipient’s name, address and certain other contact information. We will use and store any such information that we collect form you about another person only to the extent necessary to carry out your request, and we will not use such information for any other purpose.

2. How we may use your information

If you provide us with Personal Information, we may retain and use that information for several purposes. For example, we may use your Personal Information in order to process and fulfill any transactions or services that you request, such as sending e-mails regarding products or merchandise that you purchase on the Site (including any customary follow-up or confirmation communications regarding such transactions), responding to your questions, or sending e-mails to our mailing list subscribers. We may also use Personal Information to ensure compliance with our policies and applicable law. In addition, we may send you periodic communications by e-mail or regular mail, such as a newsletter, news updates, special offers or information on our products or services, if you have chosen to receive such communications. If you later wish to opt-out of receiving such promotional e-mails from us at any time, simply follow the instructions for doing so in the e-mails that you receive from us. We reserve the right to send you certain communications relating to the Site, such as service announcements, e-mails related to purchases you have made, or similar administrative or transactional messages, without offering you the opportunity to opt-out of receiving them.

We may also display your public photos from social media networks, including, but not limited to, Facebook, Instagram, Twitter and Pinterest on our website.

3. With whom we may share your information

We may sometimes use other businesses to perform certain services for us, such as maintaining the Site and our mailing lists, processing orders and delivering products, sending postal mail, and providing marketing assistance and data analysis. We may provide Personal Information to those businesses when that information is necessary for them to complete a requested transaction or otherwise perform their duties. Sonsie will take reasonable steps to ensure that these third-party service providers are obligated to protect Personal Information on our behalf.

You may also have given us permission to send you information regarding products which we may believe may be of interest to you.

As Sonsie develops, we may buy other businesses or their assets or sell our business assets. Customer information is generally one of the business assets involved in such transactions. Thus, in the event that Sonsie or all of its assets are acquired, customer information would be one of the transferred assets.

We reserve the right to disclose visitor information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other visitors, or anyone else that could be harmed by such activities. We also reserve the right to disclose visitor information when we believe in good faith that the law requires it.

4. Aggregate Information

From time to time, we may collect general, non-personal, statistical information about the use of the Site, such as how many visitors visit a specific page on the Site, how long they stay on that page and which hyperlinks, if any, they “click” on. We collect this information through the use of “cookies” and other tracking technologies, which are discussed in greater detail below. We collect this information in order to determine which areas of the Site are most popular and to enhance the Site for visitors. We may group this information into aggregate visitor data in order to describe the use of the Site to our existing or potential business partners, sponsors, advertisers, or other third parties, or in response to a government request. We also may group demographic and preferences information and responses to surveys that we collect from visitors into aggregate data for the same purposes. However, please be assured that this aggregate data will in no way personally identify you or any other visitors to the Site.

5. Cookies and other Tracking Technologies

Some of our web pages utilize “cookies” and other tracking technologies. A cookie is a small text file that a website transfers to an individual’s hard drive for record-keeping purposes. For example, we may use cookies to collect information about website activity and to maintain your shopping experience in our online store. We never save credit card information in cookies. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, please be aware that some features of the Site may not function properly or may be slower if you refuse cookies. You may occasionally get cookies from our advertisers or other third parties with links on the Site. We do not control these cookies. The use of advertising cookies sent by third-party servers is standard in the Internet industry. We do not link the information we store in cookies to any Personal Information you submit while on the Site.

Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our Site is accessed. An IP address is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the big computers that “serve up” webpages, automatically identify your computer by its IP address. It is not our practice to link the information we record using tracking technologies to any Personal Information you submit while on the Site. However, we reserve the right to use IP addresses and other tracking technologies to identify a visitor only when we feel it is necessary to enforce compliance with the Site’s policies, to protect the Site, our customers, or others, or when we believe in good faith that the law requires it.

6. Links to other Sites; Public Venues

Please be aware that when you are on the Site, you could be directed to other sites that are beyond our control. These other sites may send their own cookies to visitors, collect data, or solicit Personal Information. The privacy policies of these other sites may be significantly different from this Privacy Policy. We are not responsible for the privacy practices of these other sites and cannot guarantee the security of any of your Personal Information collected there.

Please keep in mind that whenever you give out Personal Information on a “public” venue online (for example, in a blog, message board or chat room), that information can be collected and used by people you do not know. If you choose to voluntarily disclose information in any blog, message board, chat room, or similar forum that may be available on the Site, the protections of this Privacy Policy will not cover such disclosure of information. We urge you to use caution when disclosing any Personal Information on these venues. We are not responsible and will not be liable for any opinions, content, or other materials posted by users on any such venues, or for the use by other visitors or third parties of any information or content you may post to such venues.

7. Security

We intend to take reasonable and appropriate steps to protect the Personal Information that you share with us from unauthorized access or disclosure. The security of your Personal Information is important to us. We maintain physical, electronic, and procedural safeguards to secure your personal information. However, there is some risk in transmitting information electronically. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet. By supplying us with information, you acknowledge these risks and signify that you have voluntarily chosen to provide the information despite the inherent risks involved. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your Personal Information.

If you create an account on the Site, you may be asked to choose a password for your account, in which case your online account information shall be protected by your password. We recommend that you do not disclose your password to any other person. You are responsible for maintaining the confidentiality of your password and account, and are fully responsible for all activities that occur under your password or account.

8. Children’s Privacy

You may not use of engage with the Site if you are under thirteen (13) years of age. If you use or engage with the Site and are between the ages of thirteen (13) and eighteen (18) years of age, you must have your parent’s or legal guardian’s permission to do so. By using or engaging with the Site, you acknowledge and agree that you are not under the age of thirteen (13) years, are between the ages of thirteen (13) and eighteen (18) and have your parent’s or legal guardian’s permission to use or engage with the Site, or are of adult age in your jurisdiction. By using or engaging with the Site, you also acknowledge and agree that you are permitted by your jurisdiction’s applicable law to use and/or engage with the Site.

9. Changes to our Privacy Policy

The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by posting a notice on the homepage of the Site for a reasonable period of time after such changes are made that this Privacy Policy has been updated and by changing the “Last Modified” date at the top of this Privacy Policy. We encourage you to check this page periodically for any changes. Your continued use of the Site following the posting of changes to these terms will mean you accept those changes.

10. State Privacy Laws:

California Privacy Rights.  If you are a California resident, you have the right to request certain information regarding the collection, use for business purposes, and disclosure of personal information by certain businesses governed by California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) (collectively, “California Privacy Laws”). You may find information regarding business entities governed by the California Privacy Laws, the applicability of California Privacy Laws, and California consumers’ privacy rights, and other related information in greater details at this link.

As of the “Effective” date, our operations are not subject to California Privacy Laws. If California Privacy Laws become applicable to Sonsie (following consultation with our privacy compliance advisors), we will exercise commercially reasonable efforts to update this Privacy Policy promptly.

Other State Privacy Rights: We closely monitor our data collection practices based on the requirements set forth in other state privacy laws, including those in Virginia, Colorado, Utah, and Connecticut. To the extent any state privacy laws apply following consultation with our privacy compliance advisors, we will exercise commercially reasonable efforts to update this Privacy Policy promptly.

11. International Privacy Laws:

If you are visiting the Site from outside the United States, please be aware that you are sending information (including Personal Information) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States depending on the type of information and how it is stored by us. We will hold and process your Personal Information in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in your country, and while in the United States Personal Information may be subject to lawful access requests by government agencies.  If you are a resident of the European Union or a country, like Canada, that provides similar data subject rights to those provided in the GDPR, you should review the GDPR provisions of this Privacy Policy in the section above titled “Privacy Rights for European Union Residents” for a description of your rights and our handling of your Personal Information.

12. Privacy Rights for European Union Residents

We process Personal Information you submit to us to provide customer service to you, based on your consent, which you provide by checking the box prompt before submitting your data to us.

Unless subject to an exemption under the GDPR, you have the following rights:

• Consent:  You have the right to withdraw your consent to the processing of your Personal Information at any time. 
• Access:  You have the right to access a copy of your Personal Information that we hold about you.
• Accuracy:  You have the right to correction of any inaccurate or out of date Personal Information. 
• Portability:  You have the right to our transmission of your Personal Information directly to another data controller, where possible and applicable.
• Deletion:  You have the right to delete your Personal Information when we no longer need it.
• Object:  You have the right to object to the processing of your Personal Information, where applicable.
• Restriction: You have the right to restrict further processing of your Personal Information, where there is a dispute as to the accuracy or processing.
• Complaint: You have the right to lodge a complaint with the Information Commissioner’s Office.

To exercise any of these rights, please email us at contact@sonsieskin.com with the phrase “Privacy Opt-out” in the subject line and specify what you would like us to do (for example, Send me my data, Correct my data, Delete my data, Restrict use of my data, etc.). 

You have the right to file a complaint with the Data Protection Authority in your jurisdiction if you have concerns about how we process your Personal Information.  You may do so through the following links:

• France
• Germany
• The Netherlands
• Switzerland
• United Kingdom

13. Data Retention

You may close your account, unsubscribe to emails, and otherwise limit our use of your Personal Information by contacting us. However, we may retain your Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information, it may persist on backup or archival media for an additional period of time.

14. SMS/MMS MOBILE MESSAGE MARKETING PROGRAM TERMS AND CONDITIONS.

By either (a) agreeing to our Terms of Service and this Privacy Policy or (b) entering your phone number to opt in to replenishment reminder messages and clicking “Submit”, you agree that we or our providers may send you text notifications and text marketing offers. You understand that consent is not a condition of purchase. You can unsubscribe from further text messages by replying STOP. Message and data rates may apply.

Sonsie is offering a mobile messaging program (the “Program”), which you agree to use and participate in subject to this Privacy Policy (this “Agreement”). By opting in to or participating in any of our Programs, you accept and agree to these terms and conditions. This Agreement is limited to the Program and is not intended to modify other Terms of Service or Privacy Policy that may govern the relationship between Sonsie and you in other contexts.

User Opt In: The Program allows you to receive SMS/MMS mobile messages by affirmatively opting into the Program, such as through online or application-based enrollment forms. Regardless of the opt-in method you utilized to join the Program, you agree that this Agreement applies to your participation in the Program. By participating in the Program, you agree to receive autodialed or prerecorded marketing mobile messages at the phone number associated with your opt-in, and you understand that consent is not required to make any purchase from Sonsie. While you consent to receive messages sent using an autodialer, the foregoing shall not be interpreted to suggest or imply that any or all of our mobile messages are sent using an automatic telephone dialing system (“ATDS” or “autodialer”). Message and data rates may apply.

User Opt Out: If you do not wish to continue participating in the Program or no longer agree to this Agreement, you agree to reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any mobile message from Sonsie in order to opt out of the Program. You may receive an additional mobile message confirming your decision to opt out. You understand and agree that the foregoing options are the only reasonable methods of opting out. You also understand and agree that any other method of opting out, including, but not limited to, texting words other than those set forth above or verbally requesting one of our employees to remove you from our list, is not a reasonable means of opting out.

Duty to Notify and Indemnify: If at any time you intend to stop using the mobile telephone number that has been used to subscribe to the Program, including canceling your service plan or selling or transferring the phone number to another party, you agree that you will complete the User Opt Out process set forth above prior to ending your use of the mobile telephone number. You understand and agree that your agreement to do so is a material part of these terms and conditions. You further agree that, if you discontinue the use of your mobile telephone number without notifying Sonsie of such change, you agree that you will be responsible for all costs (including attorneys’ fees) and liabilities incurred by us, or any party that assists in the delivery of the mobile messages, as a result of claims brought by individual(s) who are later assigned that mobile telephone number. This duty and agreement shall survive any cancellation or termination of your agreement to participate in any of our Programs.

YOU AGREE THAT YOU SHALL INDEMNIFY, DEFEND, AND HOLD SONSIE
HARMLESS FROM ANY CLAIM OR LIABILITY RESULTING FROM YOUR FAILURE TO NOTIFY US OF A CHANGE IN THE INFORMATION YOU HAVE PROVIDED, INCLUDING ANY CLAIM OR LIABILITY UNDER THE TELEPHONE CONSUMER PROTECTION ACT, 47 U.S.C. § 227, et seq., OR SIMILAR STATE AND FEDERAL LAWS, AND ANY REGULATIONS PROMULGATED THEREUNDER RESULTING FROM US ATTEMPTING TO CONTACT YOU AT THE MOBILE TELEPHONE NUMBER YOU PROVIDED.

Program Description: Without limiting the scope of the Program, users that opt into the Program can expect to receive messages concerning the marketing and sale of digital and physical products, services, and events.

Cost and Frequency: Message and data rates may apply. The Program involves recurring mobile messages, and additional mobile messages may be sent periodically based on your interaction with Sonsie.

Support Instructions: For support regarding the Program, text “HELP” to the number you received messages from or email us at contact@sonsieskin.com. Please note that the use of this email address is not an acceptable method of opting out of the Program. Opt outs must be submitted in accordance with the procedures set forth above.

MMS Disclosure: The Program will send SMS TMs (terminating messages) if your mobile device does not support MMS messaging.

Our Disclaimer of Warranty: The Program is offered on an "as-is" basis and may not be available in all areas at all times and may not continue to work in the event of product, software, coverage or other changes made by your wireless carrier. We will not be liable for any delays or failures in the receipt of any mobile messages connected with this Program. Delivery of mobile messages is subject to effective transmission from your wireless service provider/network operator and is outside of our control.

Participant Requirements: You must have a wireless device of your own, capable of two-way messaging, be using a participating wireless carrier, and be a wireless service subscriber with text messaging service. Not all cellular phone providers carry the necessary service to participate. Check your phone capabilities for specific text messaging instructions.

13. How to contact us

Questions regarding this Privacy Policy should be directed to contact@sonsieskin.com.