Effective Date: July 18, 2016
When you visit or interact with our Services we may collect personal and non-personally identifiable information from you. Personal information may include for example, your name, email address, postal address, phone number, browsing history and credit card number. We may also collect information about you from third-parties and the social media networks you connect to. More Info
Tracking Technologies (Cookies, etc.)
We and our third party analytics and advertising providers use tracking technologies to automatically collect information from you and the various Devices you use to connect to our Services relating to your use of our Services and your interests. More Info
We use this information to deliver more relevant information to you, or to measure the effectiveness of our Services and advertising. You may opt out of the use of such tracking information collection for use in serving interest based advertising. More Info
If you access our Services through a mobile device, we might also collect additional information such as a unique device identifier and location information. More Info
Please note that we do not respond to “do-not-track” technology. More Info
Storage and Retention
Use and Sharing of Information
We may use and share information we collect from you to operate, improve, and personalize our Services. Your information may also be shared with other users
who access our Communication Services, marketing partners, affiliated companies, our service providers, payment processors, mobile carriers, social media networks, legal and law enforcement and others if there is a change of control. More Info
Your California Privacy Rights
If you are a California resident, you have additional rights. More Info
Your Choices and Opt-Out
You may decline to provide us with information but this may limit or prevent you from using our Services or setting up an account. If you want to update your information or no longer want our Services, you may access your account and make the changes desired or you may contact us at email@example.com. More Info
Effective Date: July 18, 2016
I. INFORMATION WE COLLECT
Personal Information Provided by You. We will collect personal information or other information such as your name, email address, postal address, telephone number, billing information and browsing history if you register on our Services, place an order or otherwise interact with our Services (collectively, "Personal Information").
Surveys and Promotions.From time-to-time we may request information from you via surveys, or sweepstakes, contests, and other promotions (a “Promotion”). Participation in these surveys or Promotions is completely voluntary so you and other users have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Contact information may be used to notify the winners, award prizes and file winners’ information as required by law. Survey information will be used for the purposes of the survey and to monitor or improve of the use and customer satisfaction of the Services.
Social Media Networks.You may be given the option to link your social media account so that you can comment on the Services or take advantage of other features of the Services. When you comment on the Services using your social media username and password and clicking "allow" on the social media’s permission authorization screen, you give us permission to capture, store, use and display your user ID, your basic profile information and any other information from your profile that you specifically allow us to access. The authentication of your login credentials are conducted solely through the social media network.
User Generated Content. The Services may contain review or chat areas and/or other message, communication or other mechanisms designed to enable you to communicate with others or to post content on the Services (the “Communication Services”). Please remember that any information you disclose while participating with the Communication Services becomes public information and is subject to redistribution by BareWeb and others. You should exercise caution and discretion when deciding to disclose your Personal Information in a submission, review or posting. There is no expectation of privacy when participating on the Communication Services and we have no control over how others may use your personally identifiable information. We have the right, but not the obligation, to monitor any activity and content associated with the Communication Services. We reserve the right to take action in connection with any content we deem to be inappropriate. Please review our Terms for more information regarding your appropriate use of these Communication Services.
Portable or Mobile Devices/Location Information. We may collect additional information from you if you access Services through a mobile or portable device, for example your unique device identifier, device’s operating system, mobile carrier, language, locale, or regional location, and geo location but solely for anti-fraud or other internal, non-marketing purposes. We may also use this data internally or in conjunction with our third-party service providers or platforms to customize your experience and provide offers that may be relevant to you. However, the degree to which your location can be identified depends on the device you are using (e.g. laptop, smartphone, tablet) and how you are connected to the internet (e.g. via cable broadband connection, WiFi, etc.). We may also collect your location information from your IP address or zip code. We may also use location data internally or in conjunction with our third party service providers to customize your experience and provide offers that may be relevant to you. Depending on the platform you use to access our Services (e.g., Apple?™s iOS, Google?™s Android, Windows, etc.) you may be able to control from within the settings on your wireless device whether location data is collected. Please be advised that some features will not be available if you choose not to provide your location data to us.
Information Collected Through Technology. In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services. This may include the browser that you are using, the URL that referred you to the Services, all of the areas within the Services that you visit, and the time of day, among other information ("Usage Information"). We may use the Usage Information for a variety of purposes, including to enhance, or otherwise improve the Services. We also use this information to prepare aggregated reports, which we may share with third parties. In addition, we collect your IP address or other unique identifier from your computer or other device used to access the Services. A device identifier is a number that is automatically assigned to the device used to access the Services and our computers identify your device by its device identifier. Usage Information may be non-identifying or may be associated with you. Usage Information collected from your interaction with our Services may be combined with personal information collected from other sources. For example, we may passively collect your geolocation information solely to confirm your address for shipping or to help prevent fraudulent activity. Whenever we associate Usage Information or a device identifier with personally identifiable information, we will treat it as Personal Information. We often use third parties’ analytic tools to collect Usage Information.
To better understand your purchasing preferences, we may use third party vendors (such as Bazaarvoice) that provide tracking tools that recognize and collect Usage Information and information about the various computers, mobile devices, tablets (“Devices”) that you may use to connect with our Services and the Internet. When these tools are enabled, the data that we and our third party service providers collect about these Devices is used to enable delivery of product recommendations, advertising or other promotional materials across Devices to deliver more relevant information to you, or to measure the effectiveness of our Services and advertising. When you visit this website on a specific device, a unique ID is created for that device which allows us and our third party vendors to deliver relevant product recommendations, personalized content and advertising based on your interests gathered across multiple sites. This data may be combined with the same information from another browser or device if you use multiple browsers or devices. You may opt out of this tracking information collection for use in serving interest based ads by clicking here Please note this does not opt you out of being served ads. This opt-out applies to the specific device/browser combination on which you are browsing. To opt out of other device/browser combinations you will need to opt out of those as well. You will continue to receive generic ads.
We and third party vendors, including Google, also use first-party cookies (such as Google Analytics) to report how our ad impressions, and interactions with these ad impressions, are related to visits to the Services. To learn about Google Analytics’ and the other third party companies we use to provide Usage Information and other analytics services and your choices for opting out, click here
For a description of tracking technologies that may be used to collect Usage Information and other ad serving analytics, please click here.
Please be aware that if you choose to block certain cookies, you may not be able to sign in or use those cookie dependent features, and preferences that are dependent on cookies may be lost. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
Information We Collect From Third Parties. We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as information to validate or update your address or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services and offers that may be of interest, for security and verification purposes and for internal business analysis or other business purposes.
II. HOW WE USE AND SHARE YOUR INFORMATION
Transactional Communications. We may send you notices from time to time relating to your account or your orders. These may include order confirmations, invoices or customer service notifications. We may also send you service-related announcements when it is necessary to do so; for instance, if our Service is temporarily suspended for maintenance, or the delivery of a product is delayed or there is some service issue with something you may have ordered. You may not opt-out of receiving these communications, which are not promotional in nature.
Service and Payment Providers. We may use third party service providers to help us operate our business and the Services or administer activities on our behalf. We may share your information with these third parties for these limited purposes. Billing information you provide will be disclosed to our payment processor to process credit or debit card transactions. In this case, established third-party bank processing agents and distribution institutions handle these transactions. They receive the information needed to verify and authorize your payment information to process your order. Also, we may disclose information to third parties to verify the authenticity of any transaction or to update your billing information.
Storage of Your Billing Information. When you create an account with us, we store the last four digits of your credit card, card type and billing address for verification purposes. If you consent to having your credit card stored for future purchases, our payment processor will store your payment card information on our behalf to facilitate your future purchases with us. You will be asked to create a user name and password to protect the security of your credit card information. Please choose a strong and secure password and keep your password confidential. You are entirely responsible for maintaining the security of your password.
Electronic Promotional Offers. We may send you promotional emails regarding special offers about our Services. If you wish to opt out of receiving marketing emails from us regarding special promotions or offers you may click the unsubscribe link in the footer of any email, (ii) email us at firstname.lastname@example.org with "Unsubscribe Promotional Offers" in the subject line or (iii) call customer care at 1-877-728-9272. As an alternative to unsubscribing, you also have the ability to “opt-down” to receive a limited # of promotional emails per week or month. Please be sure that if you use more than one email address to shop with us, send your messages from each email account you use. Please note that even if you opt out of receiving promotional e-mails, we may continue to send you electronic service/transactional notifications that are related to your accounts, orders or other services you have requested.
SMS Text Messages. If you opt-in to receive transactional messages such as delivery information from us via SMS Text Messages your phone number will not be shared with third parties for marketing purposes.
Direct Mail Promotional Offers. We may send you our catalog and/or offers through direct mail that we feel might be of interest to you. Names and postal mailing addresses may be shared with our marketing partners. If you do not want us to send you our catalog or any promotional offers or offers from third parties through direct mail or sell, rent or share your information with other companies so that they can send you direct mail offers about their products and services, please send an email to email@example.com with "Direct Mail Opt-Out" in the subject line or write to BareWeb, Inc., 90 Northfield Avenue, Edison, NJ 08837 and include your mailing address to be removed. Please note that even if you opt out of receiving promotional direct mail offers, we may continue to send you service/transactional notifications that are related to your accounts and other products and services you have requested. Note that California residents have additional rights with regard to direct marketing as described in the Section below titled, Your California Privacy Rights.
Telephone Transactions. If you have provided your telephone number when registering with us or when ordering merchandise from us, we may use that telephone number to reach out to you to follow up on your order of merchandise.
Collection of Information through Our Advertising and Third Party Advertising. We may allow ad servers and ad networks to serve other advertisers’ digital advertisements on our Services. These companies (and the advertisers themselves) may use tracking technologies (for example, third party cookies) to collect and use interest based or behavioral information about your visits on our Services and other websites in order to provide targeted advertisements about goods and services of interest to you. They may also use tracking technologies to measure the effectiveness of their advertisements and to personalize advertising content. You should consult the respective privacy policies of any third party advertisers you access from our Services to see your options for opting out of their collection of such information.
In addition, we use ad servers and ad networks to serve our advertising on the Services and on other third party websites and services. These ad servers or networks may collect interest based information from you through their tracking technologies in order to provide advertisements about products and services that may be of interest to you or to measure the effectiveness of those advertisements. We may also use the information collected using third party technology placed on our ads or other services to deliver interest based advertising about our Services to you on other services and sites.
Browser Do Not Track Signals. Some third party browsers provide "do not track" machine readable signals for websites which are automatically applied by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, we do not respond to these signals.
Sweepstakes, Contests and Promotions. We may offer Promotions through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion. If you choose to enter a Promotion, information about you may be disclosed to third parties or the public in connection with the administration of such Promotion and as required by law or permitted by the Promotion’s official rules.
Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you (including, without limitation, the contents of any chat, messaging, or other communication posted via our Communication Services or social media networks, and any other information that we may have about you or your account) as may be permitted or required by law or by a governmental regulatory authority, or to prevent or investigate suspected fraud, violations of our Terms or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information and/or communications in situations that we believe to be: (i) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat; or (ii) your conduct on the Services or when using our Communication Services that we believe is inappropriate and inconsistent with generally accepted norms of behavior.
Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, information about our customers and visitors to our Services may be one of the assets sold or merged in connection with that transaction. Information about our customers and registered users may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, and support or funding.
III. ACCESS TO YOUR INFORMATION
IV. CHOICE AND OPT OUT
You may opt out of receiving future communications or close your account or opt out of our sharing information with third parties for marketing purposes by emailing us at firstname.lastname@example.org or sending postal mail (certified mail, return receipt requested is recommended) to the following postal address:
90 Northfield Avenue
Edison, NJ 08837
Attention: Privacy Administrator
If you prefer not to receive electronic promotional communications from us, you can also opt-out by following the unsubscribe instructions included in each promotional communication.
If you've signed up for mobile text messaging offers from Bare Necessities but later decide you no longer wish to receive these offers, simply follow the opt-out instructions included in the mobile message (e.g., Reply STOP to quit.)
Please note that changes may not be effective immediately and we may still retain certain information for archival and recordkeeping purposes. We will comply with your request as soon as reasonably possible and in compliance with law.
V. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Permission to Contact You. When you provide us with contact information in connection our Services, you agree that you are authorized to do so and that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you about our Services using the information you provided to us. You also attest that you have the legal authority over any telephone number, email address or other means of contacting you that you provide to us and can provide us with the authorization to contact you. This means we may contact you, in person or by recorded message, by e-mail, telephone and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.
Security. .We implement safeguards to help protect against the loss, misuse and alteration of information under our control. For instance, we use SSL encryption to transmit your credit or debit card information to our payment processor. However, despite our efforts, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and your use of the Services indicates that you are willing to assume this risk.
Your California Privacy Rights (as provided by California Civil Code Section 1798.83). California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. If you do not want us to share your information with other companies so that they can send you direct mail offers about their products and services, please write to us at the street address set forth at the end of this document or email us at email@example.com.
Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes including, without limitation, to count visitors to our Services, to monitor how users navigate the Services, to count how many sent e-mails were actually opened, or to count how many particular articles or links were actually viewed.
An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code downloads temporarily onto the device you use to access Services from our web server or third-party service provider. It is active only while you are connected to the Services, and is deactivated or deleted after that.
We may use HTML5 in some of our Services, including in our mobile website. HTML5 has browser web storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies are not stored in a browser “cookies” file and, like Flash cookies, can be used to track users across websites. To our knowledge, there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage.
E-tags/cache browsers/web logs
Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) and device identifier to improve security, analyze trends, and administer the Services. We may track your movement within the Services, the pages from which you were referred, access times, and browser types. This information may include the browser you are using, the Internet address from which you linked to our Services, the operating system of your computer, the unique IP address of the computer or device identifier of the mobile device that you used to access our Services, and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Services, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information. We may also use individual information we collect through web logs to send you targeted offers and other communications.
We may use device fingerprinting in some of our Services, which allows us to collect information about a remote computing device for the purpose of identification. It can be used to prevent fraud or collect information about you.
The IDFA is a device identifier that is used by many software kit developers for various reasons including to measure user behavior in mobile apps. Additionally, the IDFA is the shared identifier between an ad network and an ad server to report which networks delivered a particular download.
As of October 11, 2016