Privacy policy

Privacy and Cookie Policy

 SECTION 1 - WHAT DO WE DO WITH YOUR INFORMATION?

When you visit our website, CompletelyBare.com, or purchase something from our e-commerce store hosted at that domain, we may collect certain information about your device used to access our website as well as certain information as part of the buying and selling process.  When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.  If you make a purchase from the store, we collect certain of your personal information needed to process your purchase, including your name, address and email address. With your permission, we may send you emails about our store, new products and other updates.  We may also collect additional information from you if you contact us for customer support.  In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”.  When you voluntarily submit your Personal Information to our website for any reason at all, you are providing us with your consent to collect and use your Personal Information for the reasons and in the manner noted below.

Device information:

  • Examples of Personal Information collected: Version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with our website.

  • Purpose of collection: To load the website accurately for you, and to perform analytics on your website usage to optimize our Website for your user experience.

  • Source of collection: Collected automatically when you access our website using cookies, log files, web beacons, tags, or pixels.

  • Disclosure for a business purpose: Shared with our processor Shopify. Should you elect to participate in any sweepstakes, contests or other promotional offers (collectively, “Promotions”) hosted by third-party platforms for our website, such Promotions may detail separate and additional guidelines with respect to the collection and use of your Personal Information.

Order Information:

  • Examples of Personal Information collected: First and last name, billing address, shipping address, payment information (including credit card numbers, credit card security numbers, credit card expiration dates, and/or other payment details provided through Shop Pay), email address, and phone number.

  • Purpose of collection: To provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

  • Source of collection: Collected from you by direct submission through the website.

  • Disclosure for a business purpose: Shared with our processor Shopify. Shipping carriers (such as UPS) may also have access to aspects of your Personal Information, such as your first and last name, delivery address, phone number and email address.  

User Account Information:

  • Examples of Personal Information collected: First and last name, billing address, shipping address, payment information (including credit card numbers, credit card security numbers, credit card expiration dates, and/or other payment details provided through Shop Pay), email address, and phone number.

  • Purpose of collection: To provide you with an optimized website experience.

  • Source of collection: Collected from you by direct submission through the website.

  • Disclosure for a business purpose: Shared with our processor Shopify.

Customer support information:

  • Examples of Personal Information collected: First and last name, billing address, shipping address, payment information (including credit card numbers, credit card security numbers, credit card expiration dates, and/or other payment details provided through Shop Pay), email address, and phone number.

  • Purpose of collection: To provide customer support.

  • Source of collection: Collected from you by direct submission through the website.

  • Disclosure for a business purpose: Shared with our processor Shopify.

 SECTION 2 - AGE OF CONSENT/MINORS

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.  The Website is not intended for individuals under the age of 13. We do not intentionally collect Personal Information from children. If you are the parent or guardian of a minor and believe your child has provided us with Personal Information, please contact our Customer Support team to request deletion c/o Completely Bare Distributors, LLC, 35 Sawgrass Drive, Bellport, NY 11713.  If you choose to provide Personal Information to us through the Website, you represent that you are 13 years of age or older.  If you are between 13 and 17 years of age, and you submit Personal Information to the Website, you represent that you are doing so with the permission of a parent or guardian and such parent or guardian agrees to this Privacy and Cookie Policy on your behalf. 

SECTION 3 – SHARING PERSONAL INFORMATION

 We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above.

  For example:

 ●        Our store is hosted on the online e-commerce platform, Shopify Inc.  Your data is stored through Shopify’s data storage, databases and the general Shopify application.  If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. The PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. You can read more about how Shopify stores, manages and uses your Personal Information here: https://www.shopify.com/legal/privacy. 

●        We may share your Personal Information with third parties if necessary to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.  In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

●        When you click on third party links on our online storefront, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

 SECTION 4 – BEHAVIORAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

  • We use Google Analytics to help us understand how our customers use the Website. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

  • We share information about your use of the Website, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

SECTION 5 – USING PERSONAL INFORMATION AND CONSENT

We use your Personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

 How do you get my consent to use my Personal Information?

When you provide us with Personal Information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only. If we ask for your Personal Information for a secondary reason, like marketing, we will either ask you directly for your express consent, or provide you with an opportunity to opt out.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at: info@completelybareproducts.com or mailing us at: Completely Bare Distributors, LLC, 35 Sawgrass Drive, Bellport, NY, 11713.

 SECTION 6 – RETENTION AND SECURITY

 When you place an order through the Website, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

 To protect your Personal Information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide us or Shopify with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

 SECTION 7 – CALIFORNIA CONSUMER PRIVACY ACT; CALIFORNIA RESIDENT RIGHTS

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information about California residents that we will collect or disclose in the twelve months following the launch of the Website.  This CCPA Notice does not apply to Completely Bare job applicants, employees, contractors, owners, directors or officers where the Personal Information we collect about those individuals relates to their current, former or potential role with Completely Bare.

 Under the CCPA, “Personal Information” is information that identifies, relates to or could reasonably be linked with a particular California resident or household.  We collect the following categories of Personal Information:

·         Identifiers, including but not limited to, name, contact information, IP address.

·         Personal Information, as it is defined in California’s customer records law, including but not limited to, name and contact information as well as payment card details.

·         Commercial information, including but not limited to, transaction information and purchase history.

·         Internet or network activity information, such as browsing history and interactions with our Website.

·         Geolocation data, such as IP location.

·         Electronic and similar information.

·         Inferences that can be drawn from the above Personal Information identified above to create a profile that includes an individual’s preferences and characteristics.

 We collect this Personal Information from you as well as from our joint marketing partners.  We use this Personal Information to operate, manage, and maintain our business, as well as to provide our products and services through the Website and in connection with customer service and order fulfillment, and to ensure that we meet our business purposes and objectives, including using Personal Information to address the following:

 ·         Fulfill customer requests, process orders and transactions, and respond to inquiries.

·         Develop, improve, repair, and maintain the Website, our products and services.

·         Personalize, advertise and market our products and services.

·         Optimize Website performance and user experience of the Website.

·         Conduct research, analytics and data analysis.

·         Maintain property and records of Completely Bare, and perform quality and safety assurance measures.

·         Conduct risk and security control and monitoring; detect and prevent fraud.

·         Perform accounting, audit and other internal functions, including internal investigations and record retention.

·         Fulfill obligations under contractual agreements, including license agreements for trademark rights.

·         Comply with laws and other legal requirements and due diligence, and investigate and defend Completely Bare and its affiliates from legal claims.

In providing access to the Website and performing our e-commerce services associated therewith, we disclose the following Personal Information to our affiliates and third-party service providers for operational business purposes associated with the Website and our e-commerce order fulfillment:

 ·         Identifiers, including but not limited to, name, contact information, IP address.

·         Personal Information, as it is defined in California’s customer records law, including but not limited to, name and contact information as well as payment card details.

·         Commercial information, including but not limited to, transaction information and purchase history.

·         Internet or network activity information, such as browsing history and interactions with our Website.

·         Geolocation data, such as IP location.

·         Electronic and similar information.

·         Inferences that can be drawn from the above Personal Information identified above to create a profile that includes an individual’s preferences and characteristics.

 We DO NOT sell your Personal Information for financial compensation.  We share your information with select marketing partners that aggregate that information with information from other member in their marketing networks to improve marketing analytic performance for you.  If this constitutes a “sale” under the CCPA, the following categories of Personal Information would be deemed “sold”:  Identifiers, such as contact information, IP address, and other online identifiers; Personal Information, as defined in California’s customer records law (including contact information); Internet or network activity information, such as browsing history and interactions with the Website; and Geolocation data, such as your IP address.

 If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact Customer Service at info@completelybare.com.

 You additionally have the right to select a “Do Not Track” privacy preference in your web browser(s).  When you select this option, the browser will send a message to websites requesting that the websites not track the user.  For information about Do Not Track, please visit www.allaboutdnt.org. 

If you would like to designate an authorized agent to submit these requests on your behalf, please contact our Customer Support team to request deletion c/o info@completelybare.com or by mail at Completely Bare Distributors, LLC, 35 Sawgrass Drive, Bellport, NY 11713.

SECTION 8 - COOKIES

 A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Website. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the Website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the Website or browse from one page to another. Our site uses cookies to store information about your session, to track internal statistics on the number of visits to the store, to store information about purchases. The cookies are used by us to learn about the traffic on our store to improve the experience for our customers. It is possible to opt out of the cookies used on the site. Please contact Shopify for more information.

 We use the following cookies to optimize your experience on our Website and to provide our services.

a.                  Cookies Necessary for the Functioning of the Store

Name

Function

_ab

Used in connection with access to admin.

_secure_session_id

Used in connection with navigation through a storefront.

cart

Used in connection with shopping cart.

cart_sig

Used in connection with checkout.

cart_ts

Used in connection with checkout.

checkout_token

Used in connection with checkout.

secret

Used in connection with checkout.

secure_customer_sig

Used in connection with customer login.

storefront_digest

Used in connection with customer login.

_shopify_u

Used to facilitate updating customer account information.

 

b.                  Cookies Necessary for Reporting and Analytics

Name

Function

_tracking_consent

Tracking preferences.

_landing_page

Track landing pages

_orig_referrer

Track landing pages

_s

Shopify analytics.

_shopify_fs

Shopify analytics.

_shopify_s

Shopify analytics.

_shopify_sa_p

Shopify analytics relating to marketing & referrals.

_shopify_sa_t

Shopify analytics relating to marketing & referrals.

_shopify_y

Shopify analytics.

_y

Shopify analytics.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

 You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our Website may no longer be fully accessible.

 Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

 Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioral Advertising” section above.

SECTION 9 – DO NOT TRACK

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

 SECTION 10 - CHANGES

 We reserve the right to modify or update this Privacy and Cookie Policy from time to time in order to reflect changes to our practices or for other operational, legal, or regulatory reasons, so please review it frequently.  Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

 SECTION 11 - CONTACT

 For more information about our privacy practices, if you have questions, or if you would like to make a complaint, access, correct, amend or delete any Personal Information we have about you, please contact our Customer Support team by e-mail at info@completelybare.com or by mail at Completely Bare Distributors, LLC, 35 Sawgrass Drive, Bellport, NY 11713.

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact the Federal Trade Commission for complaints in the United States (https://www.ftc.gov/contact) or your local state attorney general.  California residents who have a CCPA complaint should contact the California Attorney General (https://oag.ca.gov/contact/consumer-complaint-against-business-or-company).

 

Last updated:  March 11, 2022