THRIVE CAUSEMETICS PRIVACY POLICY

Last Updated: [9/10/21]

 

This Privacy Policy explains how Thrive Causemetics, Inc. (“TC,” “we,” or “us”) collects, uses, and discloses personal information about you. This Privacy Policy applies when you use our websites (“Websites”), contact our customer service team, engage with us on social media, or otherwise interact with us. “Personal information” means information about an identifiable individual, or information that could be used to identify an individual, when combined with other, readily available information.

 

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

 

If you are a California resident, please see the Your California Privacy Rights section below. If you are a Canadian resident, please see the Canadian Residents section below.

 

CONTENTS

 

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics 

Transfer of Information to the United States and Other Countries

Your Choices

Your California Privacy Rights

Canadian Residents

Contact Us

 

COLLECTION OF INFORMATION

 

Information You Provide to Us

We collect personal information you provide directly to us. For example, you share personal information directly with us when you create an account, fill out a form, submit a product review through our Websites or comment on our blog, make a purchase, call or text us on the phone, communicate with us via third-party platforms and on social media, sign up to join our email list, join our Thrive Rewards program, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, account user name and password, shipping and billing postal address, phone number, credit card and other payment information, information about your skincare needs, and any other information you choose to provide.

In some cases, we may also collect personal information you provide about others, such as when you purchase an egift card for someone and request that we deliver it electronically or decide to purchase and ship products to someone. We will only use this personal information to fulfill your requests, and we rely on you to ensure you have obtained appropriate consent for this collection and use of the other person’s information that you share with us.

Information We Collect Automatically When You Interact with Us

When you access or use our Websites, we automatically collect certain information that may be personal information, including:

• Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
• Device and Usage Information: We collect information about how you access our Websites, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Websites, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Websites.
• Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Websites and your experience, see which areas and features of our Websites are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Websites and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or make inferences about your preferences and interests based off of your profile information. 

 

USE OF INFORMATION

We use the personal information we collect to personalize and improve your experience on our Websites. We also use personal information we collect to:

 

• Provide and deliver our products and services, process transactions and returns, and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
• Communicate with you about products and events offered by TC and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
• Provide and administer our loyalty program;
• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
• Send you technical notices, security alerts, and support and administrative messages; 
• Respond to your comments and questions and provide customer service;
• Monitor and analyze trends, usage, and activities in connection with our Websites; 
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of TC and others;
• Debug to identify and repair errors in our Websites; 
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

 

SHARING OF INFORMATION

 

We share personal information in the following circumstances or as otherwise described in this policy: 

• We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.
• If you submit a product review or comment on our blog, we share this information publicly on our Websites.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of TC, our users, the public, or others.
• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. 
• We share personal information with your consent or at your direction.

We also share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. 

 

ADVERTISING AND ANALYTICS 

 

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Websites and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by TC and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Websites and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices or change your settings using the consent management tool on our Websites here.

 

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

Text marketing (if applicable): With your permission, we may send text messages about our store, new products, and other updates. Updates include Checkout Reminders. Webhooks will be used to trigger the Checkout Reminders messaging system.

 

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

 

TC is headquartered in the United States, and we have operations and service providers in the United States, Canada, and Israel. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

 

YOUR CHOICES

Account Information

You may update and correct certain account information at any time by emailing us at help@thrivecausemetics.com. If you wish to delete your account, please email us at help@thrivecausemetics.com or submit your request here, but note that we may retain certain information as required by law or for our legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Websites.

Communications Preferences

You may opt out of receiving promotional emails from TC by following the instructions in those communications, contacting our Customer Experience team at help@thrivecausemetics.com, or submitting your request here. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations. If you are a resident of Canada, see the section below outlining your rights under Canada’s Anti Spam Law (“CASL”).

YOUR CALIFORNIA PRIVACY RIGHTS 

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. 

 

In the preceding 12 months, we have collected the following categories of personal information: identifiers, information described in Cal. Civ. Code § 1798.80(e), commercial information, internet or other electronic network activity information, and inferences. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

 

Category of Personal Information	Categories of Recipients
Identifiers	Analytics providers Communication providers Customer service providers Fraud prevention and security providers Infrastructure providers Loyalty program providers Marketing and advertising providers Payment processors Shipping and other order fulfillment providers
Information described in Cal. Civ. Code § 1798.80(e)	Payment processors
Commercial information	Analytics providers Communication providers Customer service providers Fraud prevention and security providers Infrastructure providers Loyalty program providers Marketing and advertising providers Payment processors Shipping and other order fulfillment providers
Internet or other electronic network activity information	Analytics providers Communication providers Fraud prevention and security providers Infrastructure providers Marketing and advertising providers
Inferences	Analytics providers Communication providers Infrastructure providers Marketing and advertising providers

 

California law requires that we provide transparency about personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which TC has shared personal information with third parties in exchange for valuable consideration. While we do not provide personal information about you to other companies for money, we do allow our advertising and analytics partners to collect certain device identifiers, commercial information, and internet or other electronic network activity information via our Websites to show ads that are targeted to your interests. For more information about having your personal information used for targeted advertising purposes, please see the Advertising and Analytics section above.  In the preceding 12 months, we have “sold” the following categories of personal information to the following categories of third parties: 

 

Category of Personal Information	Category of Third Parties
Identifiers	Analytics providers Marketing and advertising providers
Commercial information	Analytics providers Marketing and advertising providers
Internet or other electronic network activity information	Analytics providers Marketing and advertising providers

 

You have the right to opt out of these sales at any time by visiting our “Do Not Sell My Personal Information” webpage here. We do not knowingly sell personal information about consumers under the age of 16.

 

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, disclose, and sell, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by submitting our webform or by emailing us at help@thrivecausemetics.com. We will verify your request by asking you to provide information related to your recent interactions with us, such as your name, email address, or recent purchases. We will not discriminate against you if you exercise your rights under the CCPA.

 

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

 

We offer various financial incentives. For example, we may provide discounts, coupons, and other benefits for users who sign up to receive our marketing emails or join our loyalty program. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). You can opt into a financial incentive by following the sign-up or participation instructions provided, and you can opt-out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by following the instructions in our promotional emails or by contacting us at help@thrivecausemetics.com. In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.

 

CANADIAN RESIDENTS

If you are a Canadian resident, this section applies to you. 

 

Consent: By submitting personal information to TC, or our service providers and agents, you consent to the collection use, disclosure, and transfer of your personal information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information time by contacting TC at the email address provided below. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that TC may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you.

 

Retention of Personal Information: The personal information that you provide will be retained by TC in accordance with applicable laws. However, we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for the purposes for which it was collected.

 

Access and Correction: TC will take reasonable steps to ensure the personal information we hold is accurate, complete and up-to-date. Upon your written request, and subject to certain exceptions provided by law, TC will inform you of the existence, use, and disclosure of your personal information and give you access to that information. TC may charge a minimal fee for providing such access to you. If you believe that the personal information that TC holds about you is not accurate or complete, you may write to the TC at the email address provided below. If you are able to establish that the information is not accurate or complete, TC will take reasonable steps to delete and/or correct the information so that it is accurate, complete, and up-to-date. In order to facilitate a request to correct or update information, TC may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by TC.

Canada’s Anti Spam Law (“CASL”)

We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.

 

CONTACT US

 

If you have any questions about this Privacy Policy, please contact us by phone at (888) 804-4318, by email, at help@thrivecausemetics.com, or by mail at:

 

Thrive Causemetics

[Re: Privacy Compliance Officer]

10900 NE 4^th St. Suite 2300

Bellevue, Washington 98004