This policy has been updated and is effective April 9, 2021
WHAT INFORMATION IS COLLECTED
• Contact information (such as name, postal address, email address, IP address)
• Age (to confirm legal age to order products)
• Payment information (such as your payment card number, expiration date, security code, delivery address, and billing address)
• Purchase and transaction information
• Customer service inquiries and comments
WHY INFORMATION IS COLLECTED
To enable you to open an account
If you register for an Account, you must complete the registration process by providing your name, address, email, verify that you 18 years of age or older, as well as information relating to what you would like to receive from us. If you choose to register for an Account, you may also be asked to choose a secure password.
To provide you with email communications
If you choose to sign up for our re-occurring email communications from us, you must submit certain basic information during the registration process. This information is used to send email communications electronically, provide you with Services and respond to your inquiries. We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service. You have the right to unsubscribe from these communications from us at any time by selecting “Unsubscribe” in the email. Please give us a reasonable amount of time to process your request.
To request feedback and surveys
While visiting certain portions of the Site, you may be given the opportunity to provide feedback regarding various Cremo products. You may be given opportunities to rate Cremo products and to publicly ask and answer questions pertaining to Cremo products.
To fully participate in these portions of the Site, you will be asked to provide your full name and an email address, as well as an online username which will be publicly linked to your product ratings, questions, answers and other comments. You may also be prompted to submit additional voluntary information, such as specific age range, gender, location, and the length of time which you have used Cremo products. This information may be linked online to your chosen username. Cremo stores this additional information, if provided, and later uses it to help us better understand and respond to the collective feedback we receive.
Occasionally, we may invite you to participate in a survey or poll such as providing feedback on our Site’s site content, services, or products. Your responses will be anonymous unless you choose to provide your contact details so that we can provide you with additional information regarding the survey or poll.
To protect against fraud
HOW INFORMATION IS COLLECTED
In addition to you providing information to us, we use other methods and sources for obtaining information regarding your visits to our Site, as described below:
Cookies and other web tracking techniques
We use “cookies” on our Site to help us serve you better on future visits, help us analyze web traffic for our Site, and evaluate and improve the content or functions of our Site. A cookie is a small text file which is sent by a website, accepted by a web browser and then placed on your hard drive.
The information collected from cookies sent by Cremo and approved third parties assisting us with our Site lets us know that you visited our Site in the past and helps you avoid having to re-enter information on each visit to use some of our products or Services. Cookies also help us analyze use of our Site and better aggregate useful information when users provide feedback about our Site or products.
You may be able to set your browser to refuse all cookies from this and other websites that you visit. This will provide you with more control over the acceptance of cookies on your hard drive. However, it is possible that some portions of the Site will not function properly or may perform more slowly if you choose to reject cookies. By using our Site and not disabling cookies, you consent to allowing their use for the described purposes.
Remember also that disabling cookies is browser specific. If you log on using Safari, you must also disable cookies in Chrome if you use that browser at a different time. We may also collect information about your method of access such as your operating system (Windows 7, Windows 8, Mac, Linux, etc.) and your browser (Internet Explorer, Google Chrome, Safari, etc.) We may use access method information along with information about site searches you run to serve you personalized content using third party vendors.
Third parties and other Cremo companies
Cremo may share your information with its corporate parent and related subsidiaries, as well as, with third-party service providers that assist us with providing the Services. This includes companies that provide product fulfillment services, payment processing services, and marketing and promotional services. Cremo does not share or sell any personal information that you provide to us through the Site for any separate use by a third party for its own purposes. However, we may provide aggregate (statistical) information about our customers, sales, online traffic patterns and related information to third parties who help us improve our business and Services, but these statistics do not include any personally identifying information.
We may use third-party web analytics services on our Site, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies to help us analyze how visitors use the site. The information collected through these technologies (including IP address) is disclosed to these analytics providers, who use the information to evaluate use of the Site.
Log file information or log data
Our servers automatically record information ("Log Data") created by your use of the Site or our Services. Log Data may include information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive Log Data when you interact with our Services, for example, when you visit our Site, sign into our Services, interact with our email notifications, or visit a third-party website that includes a Cremo button or widget. Cremo uses Log Data to provide our Services and to measure, customize, and improve them. We periodically delete all Log Data or remove any common account identifiers, such as your username, full IP address, or email address, after 18 months, if not earlier.
Clear gifs information
When you use the Services, we may employ clear gifs (a.k.a. Web Beacons), which are used to track the online usage patterns of our users anonymously. No personally identifiable information from your Cremo account is collected using these clear gifs. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. The information is used to enable more accurate reporting, improve the effectiveness of our marketing, and make Cremo better for our users.
Cremo may keep track of how you interact with links across our Services, including our email notifications, third-party services, and client applications, by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.
Social platform registrations and social media plugins
This Site permits you to use a third party social networking platforms such as Facebook, Instagram and Twitter. This includes use of social media plugins such as Facebook “Like” and Tweet buttons, etc. When you use these social networking platforms and plugins, your username and password for the services and other information available about you or collected from you on these services may be shared with us. We may ask your permission to repost your Facebook or Twitter quotes on our Site. If you agree, you grant us the right to use your posts on our Site and on third party social networking platforms for promotional purposes.
We may obtain information from other sources, including commercially available sources. Examples of information we may collect from these other sources are:
• Postal address
• Email address
• Date of birth
• Income level
• Household information
• Your interests such as hobbies and pets
• Consumer and market research data
• Purchase behavior
• Product use behavior
• Publicly observed data or activities, such as blogs, videos, internet postings, and user generated content
All the information we collect about you may be combined to help us improve our Services and to develop relevant products and promotions.
Our Site may contain links to websites operated, controlled and maintained by independent third parties. We do not control the use of information you may provide to such third parties. If you access other websites using the links provided in our Site, the operators of the third-party sites may collect information from you which will then be used by them in accordance with their own privacy policies, not ours. Those policies may differ from ours. It is your responsibility to familiarize yourself with privacy policies on our Site and other websites.
Cremo maintains physical, technical, and administrative safeguards that are designed to protect your personal information from loss, misuse, unauthorized alteration, theft, unauthorized access, and unauthorized disclosure. Cremo also partners with third parties that have security safeguards in place based on the services provided.
Personal information retention period
Our Site is intended for users age 18 and over. Cremo does not market any of its products online for children under the age of 13, nor does Cremo design its online applications, advertisements and other features to attract an audience of children under the age of 13. Cremo does not knowingly register or otherwise collect personally identifiable information from anyone under the age of 18.
UPDATING YOUR INFORMATION
We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. To the extent provided by the law of your jurisdiction, Cremo also permits you to obtain a copy of personal information that we hold about you. To do so, please email us at firstname.lastname@example.org, or write to us at:
6 Research Drive, 6th Floor
Shelton, CT 06484
Please note that we will likely require additional information from you to honor the request, such as to ensure proper authentication and identity verification of the requestor.
You have the right to unsubscribe from both marketing emails and from Service that we offer. To do so, please use our contact us on the Site for additional information or click “Unsubscribe” in the email Please note that if you have already requested products or Services when you decide to withdraw consent, there may be a short period for us to update your preferences and ensure that we honor your request.
MODIFICATIONS TO THE POLICY
CALIFORNIA PRIVACY RIGHTS NOTICE
California Personal Information We Collect
We may have collected the following categories of California Personal Information within the last 12 months about you.
(A) Identifiers such as a real name, alias, postal address, online identifier, Internet Protocol address, email address, or other similar identifiers.
(B) Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to their name, address, credit card number, debit card number, or any other financial information provided.
(C) Characteristics of protected classifications under California or federal law (such as age.)
(D) Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(E) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application or advertisement.
(F) Inferences drawn from any of the information identified in this subdivision to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
(G) Geolocation data.
Within the last 12 months we have not shared California Personal Information identified in the above categories (A)-(G) in a manner that could be considered a “sale” under the California Consumer Privacy Act.
We do not disclose personal information of individuals we know to be under the age of 16 to business or third parties for monetary or other valuable consideration which could be considered a “sale” under California law, without affirmative authorization.
Use of California Personal Information
For each of the above categories, we use the California Personal Information we collect for the business purposes disclosed within our Privacy Notice and detailed in the section entitled “Why Information is Collected”.
We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.
Your California Rights
If you are a California resident, you have certain rights related to your California Personal Information. Including:
• The right to request that we disclose to you:
o specific species of personal information we have collected;
o categories of California Personal Information we have collected about you;
o categories of sources from which the California Personal Information is collected;
o our business or commercial purpose for collecting or selling California Personal Information; and
o categories of third parties with whom we share California Personal Information.
• The right to request that we delete California Personal Information about you which we have collected from you.
• To the extent that we disclose California Personal Information for a business purpose, you may request that we disclose to you the categories of California Personal Information we have collected about you as well as the categories of California Personal Information about you that we disclosed for a business purpose.
You may exercise these rights by:
• By completing our rights request form available here Data Subject Request Form; or
• Calling us toll-free at 1-(844)-383-0442.
As required under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide additional personal information as necessary to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law.
Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:
• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require you to verify your own identity in response to a request even if you choose to use an agent. We may deny a request by an agent if they fail to submit proof that they act on your behalf.
If you use assistive technology and the format of this Privacy Notice interferes with your ability to access information, please contact us at email@example.com. To enable us to respond in a manner most helpful to you, please indicate the preferred format in which to receive the material and your contact information.
You may contact us with questions and concerns about our privacy policies or practices by contacting us at firstname.lastname@example.org.
This California-specific addendum was last updated: April 9, 2021.
If you wish to download the California Privacy Rights Notice, please click below: