Privacy Policy

Last Updated and Effective Date: December 13, 2019

PRIVACY POLICY

YOUR PRIVACY IS IMPORTANT TO US

This privacy policy (“Privacy Policy”) describes the policies and practices of Soma Care and Smart Circle International, LLC (sometimes referred to as “us,” “we” or “our”) relating to the information we collect from you when you visit or register on our website, place an order, subscribe to our newsletter, respond to a survey or fill out a form.  This Privacy Policy applies only to information collected through our website.

The creation of this Privacy Policy grows from our fundamental respect for your right to privacy and will serve to guide our relationship with you.  We value the privacy and security of your “personal information,” which as used herein means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.  As such, we take complying with data privacy and security laws very seriously.

The purpose of this Privacy Policy is to provide you with a description of our personal information collection, use, and disclosure practices.  If you provide us with your personal information, or we obtain personal information about you from other sources, we treat your personal information according to this Privacy Policy.

HOW YOU ACCEPT THE TERMS AND UPDATES TO THE PRIVACY POLICY

You consent to and agree to be bound by this Privacy Policy by expressly accepting the terms of the Privacy Policy or by using this website.  From time to time, we will update this Privacy Policy as we adopt new practices and procedures related to your personal information.  Any changes to this Privacy Policy will be placed here and will supersede this version.  If we make changes to this Privacy Policy, we will revise the “Last Updated and Effective Date” above and, in some cases, we may send you a notice of our changes as well if you have provided us your e-mail or mailing address.

THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

We collect personal information that you provide to us when you register on our website, subscribe to our newsletter, respond to a survey or fill out a form.  When ordering or registering on our website, as appropriate, you may be asked to enter and provide us your name, e-mail address, mailing address, phone number or credit card information.  When you visit our website, we also collect your Internet Protocol (“IP”) address.

THE REASON WHY WE COLLECT YOUR PERSONAL INFORMATION

The personal information that we may collect from you may be used in one or more of the following ways:

  1. To personalize your experience. Your information helps us to better respond to your individual needs.
  2. To improve our website. We continually strive to improve our website offerings based on the information and feedback we receive from you.
  3. To improve customer service. Your information helps us to more effectively respond to your customer service requests and support needs.
  4. To process transactions. Your information helps us complete our transaction and deliver the products you purchased or the services you requested.
  5. To administer a contest, promotion, survey or other website feature.

WHETHER WE SHARE YOUR PERSONAL INFORMATION WITH OTHERS

We do not sell your personal information to another business or a third party.  We do, however, use or share your personal information with service providers who assist us in operating our website, conducting our business, processing transactions or servicing you.  We may also share your personal information if necessary to:  (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.  Lastly, we may share non-personal information with other parties for marketing, advertising, or other uses, as long as the information has been deidentified or aggregated.  Such information does not identify you nor is it capable of identifying you.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We have implemented and maintain reasonable security procedures and practices appropriate to the nature of the information to protect your personal information from unauthorized access and exfiltration, theft, or disclosure.  We are committed to protecting your personal information, but you can do your part.  You should create a strong password and protect against unauthorized access to your password and your computer.  Be sure to sign off when finished using a shared computer and do not share your password with anyone.  We cannot guarantee the security of any personal information you transmit to us, and by using our website, you acknowledge that you do so at your own risk.

RETENTION OF PERSONAL INFORMATION

Your personal information will be retained for the time required to fulfil the purposes for which it was collected and processed, including for the purpose of satisfying legal, professional, contractual, regulatory, accounting or reporting obligations.

CHILDREN

This website and the products and services offered herein are not intended for or directed at children under the age of 13.  In addition, we do not knowingly collect information from children under the age of 13.

COOKIES

We use cookies on this website.  Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service provider’s systems to recognize your browser and to capture and remember certain information.

We use cookies to help us remember and process the items in your shopping cart, understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with service providers to assist us in better understanding our site visitors.  These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. We do not respond to Do Not Track Requests.

INFORMATION THIS PRIVACY POLICY DOES NOT APPLY TO

This Privacy Policy does not apply to the collection and use of information by companies that we do not control, nor by individuals not employed by us and only applies to this website.  Any information you provide when you visit websites other than those covered by this Privacy Policy (including any affiliated websites) or when you purchase any products or services that may be linked to or advertised on our website by companies and entities other than us, is subject to the privacy policies posted on those sites.

LINKS TO THIRD PARTY WEBSITES

Some portions of our website may contain links to other websites on the Internet that are neither under our control nor maintained by us.  Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith.  You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.

SOCIAL MEDIA SHARING FEATURES

This website may offer social media sharing features or other integrated tools, which let you share actions you take on this website with other media, and vice versa.  These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie or employ other tracking technologies.  The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature.  Social media sharing features and widgets are either hosted by a third party or hosted directly on our website.  Your interactions with those features are governed by the privacy policies of the companies that provide them.  For more information about the purpose and scope of data collection and processing in connection with social media sharing features, please visit the privacy policies of the third parties that provide these features.

RIGHTS OF California RESIDENTS

Beginning January 1, 2020, California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).  We describe below your rights if you are a California resident.

Right To Know About Personal Information Collected, Disclosed, or Sold

We generally describe in this Privacy Policy how we collect, use, and share your personal information.  In addition to what is described above, as a California resident, you also have the right to request more information regarding the following topics for the preceding 12 months, to the extent applicable:

  • The categories and specific pieces of personal information we have collected about you.
  • The categories of sources from which we have collected your personal information.
  • The business or commercial purpose why we collected or, if applicable, sold your personal information.
  • The categories of third parties with whom we shared your personal information.
  • The categories of personal information that we have shared with third parties about you for a business purpose.
  • If applicable, the categories of personal information that we sold about you and the categories of third parties who received your personal information in the sale.

You may submit a request for the information above by calling us at 888-636-2090 or filling out the web form here.  Once you contact us through one of these channels, we will need to confirm your identity to process your request.

Right To Request Deletion Of Your Personal Information

You have the right to request that we delete the personal information we collected or maintained about you.  Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers with whom we shared your personal information to also delete your personal information from their records.

There may be circumstances where we cannot delete your personal information or direct service providers to delete your personal information from their records.  Some of these instances include, but are not limited to, if we need to: (1) retain your personal information to complete a transaction or provide a good or service; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity; (3) debug to identify and repair errors that impair existing intended functionality; (4) exercise free speech or ensure the right of another consumer to exercise his or her right to free speech; (5) comply with the law; and (6) use your personal information for internal and lawful purposes.

You may submit a request to delete your personal information by calling us at 888-636-2090 or filling out the web form here.  Once you contact us through one of these channels, we will need to confirm your identity to process your request.

Right to Opt-Out of the Sale of Personal Information

We do not and will not sell your personal information to third parties.  As such, there is no need to submit a request for us to not sell your personal information.  If you have any questions, feel free to contact us at 888-636-2090.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

We will not discriminate against you for exercising any of your rights under the CCPA, as described above.  This includes, but is not limited to:  (1) denying good or services to you; (2) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (3) providing a different level or quality of goods or services; or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Authorized Agent

You may use an authorized agent to submit requests on your behalf to exercise the rights above.

CONTACTING US

If you have any questions regarding this Privacy Policy, you may contact us at 888-636-2090.