Last updated: February 20, 2023
- Information We Collect
The personal information we collect depends on how you interact with us and may include:
- Device Information: When you visit our Site or open our emails, we may learn information about your browser (name, version, settings, etc.), device type and settings, IP address, MAC address, unique device or other online identifier, internet service provider, the name and version of your operating system, referring and exit pages, the date and time of your visit, and other similar details.
- Website and Email Interactions: We may collect information about your interactions with our Site, including the pages you visit, links or buttons you click, the search terms you enter, and other similar interactions with the Site. We may also collect information about your interactions with our email correspondence (e.g., whether you’ve opened the email, the links or buttons you click within an email, etc.).
- Location Data: We may use various technologies to learn your non-precise geographic location, including by collecting your IP address or other device information, which may depend on your device or browser’s settings for location services and how you interact with us.
- Contact Information: We may collect your contact information, including first and last name, address, telephone number, and email address.
- Call, text, and email records: If you call, text, or email with Palmperfect or our customer service agents, we may keep records of those conversations including all such information you have provided to us in connection with such conversation.
- Submitted Content: We will collect any content you submit to our Site, including photos, videos, or product reviews.
- Demographic Information: We may collect demographic details about our customers such as age, gender, regional location and ZIP code, and other similar details.
- Preferences: We may collect information about your preferences, such as products you may be interested in.
- Inferences: We may draw inferences about any of the above information that reflect your preferences, characteristics, or other matters.
- How Your Information is Collected
We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:
- You: We collect information directly from you, whenever you contact us with questions or comments; upload content to our Site; enter our contests, sweepstakes, or other promotions; respond to a survey; make a product review; opt in to receive text messages from Palmperfect; or fill out any forms on our Site.
- Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Site or open our emails.
- Third Parties: We work with third parties who provide services to us, like analytics or advertising companies, email and text message service providers, companies that assist with website functionalities (including, for example, our product review feature), etc. We may share your personal information with them, and they may share the information they have collected about you with us.
Some of the cookies we or our partners use on our Site are necessary for the operation of the Site; others are not.
- Publicly Available Data: We may collect information about you from publicly available sources.
- How We Use Your Information
- Understanding our Customers: We may analyze your activity with us (including your interactions with our Site and emails or other forms of communication, analyzing trends and statistics, etc.). We keep track of the pages you visit and the manner in which you use the Site to determine, for example, what products are most popular and whether to make changes to the Site. We may, from time to time, review your information and information of other customers to help us analyze trends, patterns and preferences, and demographics.
- Advertising: We may use your information in connection with our presentation of advertising online and via email, or other communication channels, including through partnerships with social media platforms and internet search engines, and measuring the reach and effectiveness of those advertisements.
- Personalization: We may use your preferences and other collected information to personalize your browsing experience by using your product interests and browsing patterns, to recommend other products, services or promotions that we believe you may be interested in as well as personalizing advertising and experiences on our Site and in emails and ads.
- Communications: We will use your information to communicate with you, including by responding to your requests and inquiries and asking for feedback through surveys, product reviews or other messages.
- Promotions: We may use your information in connection with contests, sweepstakes, or other promotions.
- Site Maintenance: We may use your information in connection with providing, maintaining, or troubleshooting access to our Site and to monitor, evaluate, and improve the content, functionality and usability of our Site (e.g., debugging, measuring website traffic, etc.);
- Customer Experience: We may use your information serve content on our Site and develop our products and services.
- Security: We may use your information to protect Palmperfect and our customers from fraud, security threats, and other illegal or harmful activity.
- Legal Obligations: We may use your information to comply with legal and regulatory requirements and respond to requests from courts or other government bodies.
- How We Share Information with Service Providers and Third Parties and For What Purposes.
We may share information with third parties for certain purposes. For example, we may share information with:
- Service Providers: As noted above, we partner with third parties to assist with many aspects of our business, including advertising and marketing, analyzing the interest in and activities on our Site, operating and providing certain functionalities for our Site, and helping us communicate with customers. These third parties may provide services related to any of the purposes described in section 3 “How We Use Your Information,” and we may share with them any types of information described in section 1 “Information We Collect.” We may also receive information collected by these third parties and combine it with the information we have collected. Your information may also be collected and processed by third parties, who will process your information independently in accordance with their own privacy notices.
- Palmperfect Affiliates: We may share personal information we’ve collected via the Site with our Palmperfect Affiliates for our Affiliates’ use.
- Parties to a Business Transaction: Your information may be transferred to another entity that succeeds to all or part of Palmperfect’s business in connection with a sale, reorganization, consolidation, or merger. Your information may be shared under obligations of confidentiality and non-disclosure to a prospective successor or purchaser of Palmperfect’s business.
- Other Third Parties: We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law. We may also disclose information about you if we believe it is necessary to: (i) investigate any suspected misuse of the Site; (ii) protect or defend the rights, property and interests of Palmperfect, our customers, or the interests of our third-party service providers; or (iii) under exigent circumstances, to protect the personal safety of users of the Site or the public.
- Your Privacy Choices
You can control the personal information we collect and use in the following ways:
- Location Data: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Site from accessing your location information. Note that some services may not be available if you disable location-based services, and you may experience difficulties shopping online at the Site.
- Emails: You can unsubscribe from marketing emails by clicking the unsubscribe link in the footer of such email.
- Cookies: You can at any time change your cookie preferences on our Site by clicking here [insert hyperlink to cookie settings]. Note that you can also refuse to accept third-party cookies by following your browser’s instructions. If you do not accept cookies, you may experience some inconvenience in your use of the Site.
- Text Messaging: You can cancel the Palmperfect text service by notifying us of your intent to opt out at email@example.com
- User Requests: You can contact us at any time using the contact information in section 12 below to request we do any of the following: (i) erase or delete all or some of your personal information; (ii) change, update, or correct your personal information; (iii) restrict how we use all or some of your personal information; (iv) access your personal information and, where applicable and feasible, request to receive that personal information in a commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v) disclose what personal information we collect, use, or disclose. You may also request that we stop sharing your personal information with third parties for certain purposes. We will consider and respond to any such requests promptly, and otherwise in accordance with applicable laws.
If you are a California resident, you can learn more about your privacy rights below in section 13 “Privacy Rights of California Residents”. If you are a resident of the European Union, Iceland, Liechtenstein, Norway or the United Kingdom, you can learn more about your privacy rights below in section 14 “Privacy Rights of EEA and UK Residents”.
- Text Messaging
We do not knowingly or purposefully request or collect personal information from any person under the age of 13 years old. If you believe that your child under the age of 13 has submitted personal information to Palmperfect in connection with our Site, please contact us at firstname.lastname@example.org.
We take steps to help protect the confidentiality and security of your personal information. Although we use measures to protect your personal information, in general, information transmitted through the Internet may not be completely secure. Accordingly, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk.
We only retain personal information for as long as reasonably necessary for the purpose in which it was collected. For example, where your personal information is needed to provide you with access to our Site, we retain your personal data for the period in which we are providing that access unless we are required by law to dispose of it earlier or to keep it longer. We also retain personal information as necessary to comply with our legal obligations, resolve disputes, pursue legitimate business interests, conduct audits, and protect or enforce our rights.
- Links to Other Websites.
This Site may, from time to time, contain links to websites owned and operated by third parties (“Third Party Sites”). We encourage you to review the privacy policies of such Third Party Sites so that you understand how those websites collect, use, and share your information. We are not responsible for the privacy policies or other content on Third Party Sites.
- Contact Us
We welcome your comments and questions. Please contact us at:
85 Wells Ave. Suite 106
Newton, MA 02459
- Privacy Rights of California Residents
As a resident of California, you have rights under the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as amended from time to time, “CCPA”) relevant to your Personal Information (as defined under the CCPA), as well as other laws. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.
Personal Information We Collect. In the preceding 12 months, we may have collected the categories of personal information about California consumers set out in the section 1, “Personal Information We Collect”, for the purposes described in section 3, “How We Use Your Information” above.
Categories of Sources. In the preceding 12 months, we may have collected the above-mentioned personal information from the sources described in section 2, “How Your Information is Collected”.
Disclosing Personal Information for Business Purposes. In the preceding 12 months, we may have disclosed your personal information to a third party for the purposes set out in section 4, “How We Share Information with Service Providers and Third Parties and For What Purposes”.
Sale and Sharing of your Personal Information. We may share personal information with third parties, including for purposes of cross-context behavioral advertising and website data analytics, which may constitute “selling” or “sharing” under the CCPA. Such sale or sharing does not include information about individuals we know are under age 16. In the preceding twelve (12) months, Palmperfect may have sold or shared the categories of personal information listed below with the categories of third parties listed below.
|Categories of Personal Information:||Shared with the following categories of third parties:|
|Personal and online identifiers (such as first and last name, email address, IP address, or unique online identifiers)||
· Advertising/marketing companies.
· Advertising networks.
· Marketing data companies.
· Data analytics providers;
· Social networks.
|Internet or other electronic network activity information (such as browsing history, search history, and information regarding a consumer’s interaction with an internet website)|
|Inferences drawn from the above information about your predicted characteristics and preferences|
Sensitive Personal Information. We do not collect or use sensitive personal information.
California Consumer Rights Under the CCPA: If your personal information is subject to the CCPA, you may have certain privacy rights with regard to that information. You may have the right to:
- Request that we provide you access to the following no more than twice in a 12-month period:
- the categories and specific pieces of Personal Information that we have collected about you;
- the categories of sources from which the Personal Information is collected;
- the business or commercial purpose for collecting or sharing your Personal Information;
- the categories of third parties with whom we share your Personal Information; and
- the categories of Personal Information that are sold (as defined under the CCPA) and the categories of third parties to whom the Personal Information was sold.
- Request that we correct or delete your Personal Information, subject to exceptions under the CCPA or other applicable law; and
- Request to opt out of our “sale” or “sharing” of your personal information.
California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CCPA, as described in this section. We will not discriminate against you because you have exercised any of your rights under the CCPA.
How to Submit a Request to Exercise Your Rights.
If you wish to exercise your right to opt out of the sale or sharing of your personal information, please click the “Do Not Sell or Share My Personal Information” link in the footer of the Site. If you wish to exercise any other right set out above, please submit your request through our toll-free number 1-800-514-2546 or at email@example.com. To ensure we can verify your identity and help us respond to your request please provide us with your full name, email, and home address, and clearly indicate which of the rights you wish to exercise.
We are required to provide access to Personal Information or delete or correct Personal Information only in response to a verifiable consumer request. To verify your request, we will compare the information you have provided as part of submitting the request to any information we may have in our possession. We may also contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that personal information is not disclosed to any person who does not have the right to receive it, and is not deleted or changed in error. The information collected through this process will be used only for verification purposes and responding to your request.
Requests made through Agents. Please note that you may authorize an agent to exercise any of these rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of you and your agent’s identity and authorization.
Notice of Financial Incentives. We may offer discounts, coupons, and similar benefits (each, a “financial incentive”) to customers who sign up to receive our marketing emails or text messages. When you participate in a financial incentive, we may collect personal information from you, such as your contact information or demographic information. You can opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by contacting us at firstname.lastname@example.org. 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 the offer or discount presented to you is reasonably related to the value of your personal information.
Additional California Privacy Rights. California residents may also ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make one request per calendar year.
To make this request, you may contact us at email@example.com. In your request, please include a subject line that states “CA Shine the Light Request”, state that you are a California resident, and provide a current California address for our response.
- Privacy Rights of EEA and UK Residents
We will only process your personal data to the extent applicable law allows us to do so.
The United States has not sought nor received a finding of “adequacy” from the European Union or the United Kingdom under article 45 of the GDPR or article 45 of the UK-GDPR. Therefore, we rely on derogations for specific situations as set forth in article 49 of the GDPR and article 49 of the UK-GDPR. In particular, we collect and transfer to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
If you are a resident of the EU, Iceland, Liechtenstein, Norway, or the United Kingdom, you have certain rights under applicable law, including the right to:
- Request that we provide you access to the personal data that we maintain about you;
- Request to correct, revise, or update any of the personal data we maintain about you;
- Request that we erase the personal data we maintain about you;
- Object to our processing of your personal data on the basis that the processing has a disproportionately detrimental impact on your interests, rights, and freedoms;
- Request that we restrict our processing activities related to your personal data;
- Withdraw your consent to our processing of your data at any time, however, such a withdrawal will not affect the lawfulness of our processing based on your consent prior to the withdrawal. Please note that where we rely on your consent in order to process your personal data and you then withdraw that consent, it may affect our provision of services to you, and may mean that we are unable to provide our services (either in part or in full) to you;
- Request to have your personal data reproduced in a structured, commonly used, and machine-readable format, whether or not such request relates to the transmission of the personal data to another party; and
- Require us to stop sending you marketing communications.
Residents of the EU, Iceland, Liechtenstein, Norway or the United Kingdom may initiate any of the above requests, objections, or requirements by sending us an email at firstname.lastname@example.org and writing “GDPR Request” in the subject line. You may also write to us at the postal address provided in section 12 above.
Finally, you have the right to raise a concern about our collection and processing of your personal data with your local supervisory authority, available here (EU/EAA) or here (UK) and you may do so without prejudice to any other rights you may have.