PRIVACY POLICY

VERBODEN INC. ("we", "us" or "VERBODEN") has created this privacy policy statement in order to demonstrate our firm commitment to your privacy. The following discloses our information gathering, use and dissemination practices solely for the Website located at verbodenx.com (the "Website"). By using or accessing the Website, you confirm your agreement to our Privacy Policy.

Age Restrictions:
You must be at least 18 years old to access this site. If you are under 18 years old you are not permitted to use this site for any reason. You must be of legal age required by the state or province you are in to purchase our products. It is your responsibility to know whether you are legally able to purchase our products.

Personal and Non-Personal Information:
When using the Website, in order to utilize some of our services, you may choose to upload, or we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Information"). Personally identifiable information may include, but is not limited to:

  • Name

  • Email address

  • Mailing / physical address

  • Telephone number

  • Credit card number

  • User name

  • Date of birth

  • Usage data (collected automatically upon use of the Website)

In connection with our product review system, you might provide other voluntary personal information including your:

  • Age range

  • Skin tone

  • Skin type

We collect Personal Information from you when you choose to participate in our offers and programs or when you otherwise provide information directly to us, including when you register with us, purchase products, review products, participate in our interactive features or otherwise interact with us on the Website.

In addition, we may also collect non-personally identifiable information, such as IP addresses (which identify your device), pages viewed, computer type, screen resolution, operating system version, Internet browser type and version, information collected through cookies, pixel tags, web beacons, and other technologies, and other data. Because Non-Personal Information does not personally identify you, we may collect, use and disclose Non-Personal Information for any purpose.

We may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area ("Aggregate Information"). In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined, and may aggregate any information collected in a manner which does not identify any individual.

Use of information:
We use personal information to process and fulfill any orders that you have placed, contact you about our products and services, personalize your experience with us including suggesting products or treatments tailored to you, and allow you to use, communicate and interact with others on our Website, including our product review system. This may include sharing information with third parties such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, information technology services, customer service, e-mail delivery services, credit card processing, auditing, training, and other similar services. These third parties may have access to Personal Information necessary to perform their functions, but may not use it for other purposes. We will never sell your Personal Information to any third party not affiliated with VERBODEN without your consent except in connection with the sale or merger of VERBODEN or the division responsible for such services.

We may disclose Personal Information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use Aggregate Information to improve and enhance your experience on the Website and for our market research activities. For example, we may share Aggregate Information with unaffiliated third parties, such as business partners, site analytics vendors, manufacturers, distributors and retailers, in an aggregate, anonymous form, which means that the shared information will not contain nor be linked to any Personal Information.

We may at times share our customers email addresses (on a non-sale basis) with distributors, manufacturers and/or other services that we believe will be of interest to the VERBODEN customer. From time to time, we may give you the opportunity to opt in or participate in special third party offers that require us to share certain Personal Information with such third parties. We will disclose this anticipated sharing of Personal Information at the time we make such opportunities available to you. If you choose to opt in, we may disclose your Personal Information to such third parties for their direct marketing purposes. We recommend that you consult such third parties' privacy policies in advance if you wish to participate in these offers.

Email and Telephone Communications:
We do use "browse abandon" and "cart abandon" tracking functions. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also contact you from time to time via telephone regarding customer service inquiries pertaining to your orders.

Cookies:
"Cookies" are pieces of information that may be placed on your computer by a Website for the purpose of facilitating and enhancing your communication and interaction with that Website. We may use cookies to customize your visit to the Website and for other purposes to make your visit more convenient or to enable us to enhance our service. For example, cookies allow us to keep track of items you add to your shopping cart. There are several types of cookies, including browser cookies, session cookies, and persistent cookies. We use cookies that allow customers and members to remain logged in to our Website, that keep track of items in shopping carts, and that recognize your Website preferences and user attributes. You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Website, but it may interfere with some of its functionality. We do not use cookies to retrieve personal information from your computer for purposes that are unrelated to the Website or your interaction with the Website.

Clickstream:
As you use the Internet, a trail of electronic information is left at each Website you visit. This information, which is sometimes referred to as "clickstream data," which can be collected and stored by a Website's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the Website from which you linked to the Website. We may collect and use clickstream data as a form of Aggregate Information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Website and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Website and our services. Any collection or use of clickstream data will be anonymous and aggregate, and will not intentionally contain any Personal Information.

Site Analytics:
We may work with third-party service providers who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Site.

Social Network and Interactive Tools:
Certain features on our Website may give you an opportunity to interact with us and others. These may include blogs, message boards, messaging functionality, chat functionality, and creating community profiles. When you use these features you should be aware that any information you submit, including your name, location and e-mail address, may be publicly available to others. We are not responsible for any information you choose to submit through these interactive features and we strongly discourage you from disclosing any sensitive Personal Information (such as health or credit card information) through these features. If you use these features, your Personal Information may remain on the Website even after you cease use of the Website.

Security:
The security of your Personal Information is very important to us. It is our priority to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. If you provide us with your credit card information during the payment process, we send it to our PCI-DSS compliant payment gateway for processing using SSL encryption technology. Your credit card information is never stored for use beyond your current transaction. All direct payment gateways comply with 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. PCI-DSS requirements help ensure the secure handling of credit card information by our store and our payment processors and service providers. However, due to the inherent open nature of the Internet, we cannot guarantee that communications, or information stored on the Website or our servers, will be free from unauthorized access by third parties and your use of the Website demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information. We store only the last four digits of your credit card number. The credit card full number, expiration date, and security code are transmitted to our payment processor in encrypted form. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us immediately.

Other Websites:
Our Website may contain links to other Websites not maintained by VERBODEN. Other Websites may also reference or link to our Website. The inclusion of a link on the Website does not imply endorsement of the linked site by us. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Website, or for the privacy practices of third party Internet advertising companies. We encourage you to be aware when you leave our Website, or surf the Internet, and to read the privacy statements of each and every Website that you visit.

"Do Not Track":
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Privacy of Minors:
We do not intentionally collect or maintain information from persons under the age of 13. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. We also recommend that parents monitor their children's Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian's preferences.

California Privacy Rights:
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. You can also request the discontinuation (or opt-out) of our sharing of the information with those third parties. Please submit any requests ("California Privacy Rights Request") to verbodenbeauty@gmail.com with a subject line of "My California Privacy Rights."

For each California Privacy Rights Request, please clearly state the following in the body:

  • the nature of your request;

  • that the request is related to "Your California Privacy Rights;"

  • your name, street address, city, state, zip code, and email address; and

  • whether you prefer to receive a response to your request by mail or email

VERBODEN is not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled, or incorrectly sent.

To opt out of our email marketing campaigns:

  • You can opt out of our email marketing campaigns by clicking the unsubscribe link at the bottom

Visitors From Outside The United States—Cross-Border Transfer:
The Website is hosted in the United States. If you are visiting the Site from outside the United States, your information may be transferred to, stored in, and processed in, the United States or any other country where we or our affiliates, subsidiaries, or third-party service providers maintain facilities.

The European Commission has not determined that the United States ensures an adequate level of protection for Personal Information. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions.

By providing us with Personal Information, you consent to the storage or processing of your Personal Information in the United States and acknowledge that the Personal Information will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Information. By using the Website and/or providing personal data to us, you also consent to transfer, storage, and processing of your information as described in this Privacy Policy. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored.

General Data Protection Regulation (GDPR) Privacy Rights:
Data Controller

VERBODEN is the controller of your personal data provided to, or collected by, or processed in connection with your use of the Website. Please see the “Cross-Border Transfer” section for more information about the transfer of your personal data to the United States or other countries.

Purposes of Processing and Legal Basis for Processing
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. As explained above, we process Personal Information in various ways depending upon your use of our Website. We process Personal Information on the following bases: (1) with your consent; (2) as necessary to fulfill orders when you purchase products; and (3) as necessary for our legitimate interests in providing you with our products and services, enhancing our web services, conducting analytics, and delivering relevant advertising.

Your Rights Regarding Personal Information

The GDPR requires that we inform our EEA users about certain specific rights:

  • the right to object, for legitimate purposes, to the processing of personal data;

  • the right to request copies of your personal data held by us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible);

  • the right to request that we delete or block your personal data without undue delay; and

  • the right to lodge a complaint with a supervisory authority.

Withdrawing Consent
If you wish to withdraw your consent, please contact us using the contact information detailed in the “Contact” section. Please note that if you withdraw consent, we may not be able to provide or continue to provide certain services or marketing communications to you.

Objection and Requests for Copies
If you wish to (i) object, for legitimate purposes, to the processing of personal data as provided under applicable law, or (ii) to request copies of your personal data held by us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible), please contact us using the contact information detailed in the “Contact” section.

Requests for Deletion
If you wish to request that we delete your personal data, please contact us using the contact information detailed in the “Contact” section. We will promptly send you a response to ensure that the request was not made in error. We will respond to your request to delete your information within one month of receipt of your verification. Our response period may be extended by 60 additional days where necessary, taking into account the complexity and number of requests we receive. We may need to retain certain records, for example those relating to open orders, payments, or customer service matters, for legal and accounting purposes. Please note that if you are a member of our Rewards Program and you request that your personal data is deleted, you may be removed from our Rewards Program.

Lodging Complaints
You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority in your country. For more information, please contact your local data protection authority in the EEA.

Existence of Automated Decision-Making

We may use automated decision-making processes to personalize the Website to enhance your shopping and consumer experience on the Site (for example, by recommending certain products to you) or, if you have opted into receiving promotional material from us, to send you personalized promotional emails. We do not believe any of these automated decision-making processes will produce legal effects concerning our users or similarly significantly affects our users.

Contact
By providing your email address to VERBODEN, you expressly consent to receive emails from us. We may use email to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us or by other third party manufacturers, services and/or distributors that we believe will be of interest to our customers. If you receive an unwanted email from us, you can simply reply and request to opt out. We also give you the option to remove your personal information from our list of active users completely. All unsubscribe or opt-out requests should be emailed to verbodenbeauty@gmail.com and we will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third party who has been provided your information in accordance with this policy, such as a business partner.

For questions or concerns relating to privacy, email us at verbodenbeauty@gmail.com

Changes to policy:
We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time by posting the updated policy here. Your continued use of the Website following the posting of any changes to this policy means you accept such changes. If you are concerned about potential changes in our Privacy Policy, you should check for updated version each time you use the Website.  You are also advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

This Privacy Policy was last updated on December 19, 2018.