Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.

To provide the Services, we collect and may continue to collect personal information about you from a variety of sources, as set out below. The information that we collect, and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information that you directly submit to us through our Services may include:

• Basic contact details including your name, address, phone number, email.
• Order information including your name, billing address, shipping address, payment confirmation, email address, phone number.
• Account information including your username, password, security questions.
• Shopping information including the items you view, put in your cart or add to your wishlist.
• Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

We also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies who support our Site and Services, such as Shopify and integrated applications.
• Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third Party Websites and Links.

• Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to you account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and to enable you to post reviews.
• Marketing and Advertising. We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites.
• Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Communicating with you. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you.

Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, because information is collected in a variety of different ways, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners. If you have questions about what information has been collected from you or a request to delete information that has been collected, please contact us.

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).

With business and marketing partners, including Shopify, to provide services and advertise to you. We use Shopify to support personalized advertising with third-party services. Our business and marketing partners will use your information in accordance with their own privacy notices.

When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.

With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.

In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you. We also do not sell your personal information.

We may “share” (as that term is defined in applicable law) personal information for the purpose of engaging in advertising and marketing activities, as follows.

Category

• Identifiers such as basic contact details and certain order and account information
• Commercial information such as order information, shopping information and customer support information
• Internet or other similar network activity, such as Usage Data

Categories of Recipients

• Meta, TikTok, Google, Shopify Audiences, Pinterest,
  Youtube, Affiliates, X (formerly known as Twitter)

The Services may enable you to post product reviews and other user-generated content. If you choose to submit user generated content to any public area of the Services, this content will be public and accessible by anyone.

We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.

Right to Delete. You may have a right to request that we delete personal information we maintain about you.

Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.

Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

Right to Opt out of Sale or Sharing or Targeted Advertising. You may have a right to direct us not to "sell" or "share" your personal information or to opt out of the processing of your personal information for purposes considered to be "targeted advertising", as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the "sale" or "sharing" of information for the device and browser that you use to visit the Site.

Right to Limit and/or Opt out of Use and Disclosure of Sensitive Personal Information. You may have a right to direct us to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.

Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.

Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.

Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.

Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, You may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

In this Supplemental California Privacy Policy, we, Otella, disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”) and California law. This Supplemental California Privacy Policy is effective January 1, 2023. 

A. Who and what information is subject to the CCPA?

The CCPA protects Californians with respect to their personal information. As a result, the Supplemental CCPA Disclosures and relevant CCPA Rights subsections below may not apply when they restrict our ability to comply with a court order or regulator with competent authority, federal, state or local laws, cooperation with law enforcement, exercise of our legal claims, or collection or use of de-identified information.

B. Supplemental CCPA Disclosures

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and describe, for each category of personal information collected, the business or commercial purposes for which the information was collected. Each of the categories of personal information listed in the table are collected directly from consumers. Each of the categories of personal information in the table may also be shared with the following categories of third parties: (i) our Service providers, contractors, and business partners (ii) Government entities as required by applicable law (iii) other recipients at your discretion or with your consent (iv) Third parties in the event of a proposed or actual business transaction involving all or any portion of our business. We disclose that information for the purposes described in Section 4 of the Privacy Policy.

Additional information about sales of information can be found below:

Category of personal information:

Identifiers: such as your name, postal address, email address, social media handle, telephone number, or Identification materials 

Categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, including name, signature, address, telephone number, passport number, and credit card number, debit card number, or any other financial information. 

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

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 Web site, application, or advertisement. 

User Generated Content (UGC).

Geolocation data. 

Audio, electronic, visual, or similar information.

Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics and attitudes.

Sensitive personal information, including account credentials and precise geolocation.

We collected such personal information for the following purposes:

To process your transactions and provide you with the products and services you request; 

• To provide, maintain, protect, develop, and improve our websites, applications and services; 
• To improve your experience on our websites and applications, and in our stores; 
• For customer service, including to respond to your inquiries and requests; 
• To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required; 
• To analyze and learn about consumer trends and interests; 
  To learn about the devices you use to access our websites, applications and other online services 
• To personalize the content you see on our websites and applications; 
• To administer contests, sweepstakes, surveys and other promotions; 
• To maintain your reward or loyalty program memberships; 
• To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services; 
• To maintain our community programs and focus groups; 
• To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent); 
• To verify eligibility for discounts and other offers; 
• To prevent and detect fraud, criminal activity and violations of our terms of use; 
• To protect our rights, as well as yours and others; and 
• To comply with our legal obligations. 
• We may use this information for any of the purposes described in section 3.

We use this information to process payment, fulfil your order, or process a return.

We use this information to fulfil your order, manage consumers’ online account with us, personalize and optimize consumers’ shopping experience with us (for example, letting you know when a favorite product is back in stock, recording certain information from past purchases which can be used in future purchases such as preferred address and favorite store locations), provide consumers with customer care, and customize a product per a consumer’s specific request.

• To process your transactions and provide you with the products and services you request; 
• To provide, maintain, protect, develop, and improve our websites, applications and services; 
• To improve your experience on our websites and applications, and in our stores; 
• For customer service, including to respond to your inquiries and requests; 
• To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required; 
• To analyze and learn about consumer trends and interests; 
• To learn about the devices you use to access our websites, applications and other online services 
• To personalize the content you see on our websites and applications; 
• To administer contests, sweepstakes, surveys and other promotions; 
• To maintain your reward or loyalty program memberships; 
• To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services; 
• To maintain our community programs and focus groups; 
• To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent); 
• To verify eligibility for discounts and other offers; 
• To prevent and detect fraud, criminal activity and violations of our terms of use; 
• To protect our rights, as well as yours and others; and 
• To comply with our legal obligations. 
• We may use this information for any of the purposes described in section 3. 
• To process your transactions and provide you with the products and services you request; 
• To provide, maintain, protect, develop, and improve our websites, applications and services; 
• To improve your experience on our websites and applications, and in our stores; 
• For customer service, including to respond to your inquiries and requests; 
• To communicate with you about our and third-party products and services, in accordance with applicable laws and with your consent where required; 
• To analyze and learn about consumer trends and interests; 
• To learn about the devices you use to access our websites, applications and other online services 
• To personalize the content you see on our websites and applications; 
• To administer contests, sweepstakes, surveys and other promotions; 
• To maintain your reward or loyalty program memberships; 
• To provide you with communications, recommendations, ads, and other information of interest to you, including via text message and email and interest-based advertising based on your online activities on our websites, applications and other online services; 
• To maintain our community programs and focus groups; 
• To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent); 
• To verify eligibility for discounts and other offers; 
• To prevent and detect fraud, criminal activity and violations of our terms of use; 
• To protect our rights, as well as yours and others; and 
• To comply with our legal obligations. 
• We may use this information for any of the purposes described in section 3.

We may use this information to enable consumers to view nearby stores.

We use audio, visual or similar information that you may voluntarily provide in connection with customer care inquiries or when you engage with our social media initiatives for purposes of providing and improving customer service, training, resolving complaints or inquiries, legal compliance, and exercising or defending legal claims.

We use such information to personalize and optimize consumers’ shopping experience with us, enable consumers to use our “wish list” or “add to closet” features online, tailor our marketing efforts, and develop and improve our products and services.

We use account credentials for the security purposes and to process your transactions and provide you with the products and services you request.

We retain personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we retain your personal information for a period of time that enables us to: 

• Maintain business records for analysis and/or audit purposes. 
• Comply with record retention requirements under the law or other relevant legal or regulatory requirements. 
• Defend or bring any existing or potential legal claims. 
• Deal with any complaints regarding the services. 
• Preserve historical records of transactions.

We have and will continue to share Identifiers; Demographic information; Internet activity information; Location information; Inferences; and Transaction information. certain categories of personal information about California residents with third parties and business partners in a manner that may constitute a “Sale” or “Sharing” under the CCPA, as described below: 

• Online Promotions and Advertising: We work with one or more third parties to: (i) administer and analyze effectiveness of advertising or promotional campaigns. These third parties may place cookies on individuals’ computers to receive information about traffic to our site, browsing and purchasing activity on our online services, and (ii) From time to time third parties may help us to provide a more tailored user experience. These third parties may collect information about individuals’ internet or other similar network activity and browsing patterns, IP address, page interaction (such as scrolling, clicks and mouseovers), and information obtained via cookies with these third parties (such as the site visited before or after). To opt out of these disclosures, please click: Do Not Sell or Share My Personal Information. We also recognize the “Global Privacy Control” (GPC) to allow you to opt out of the sale of your personal information and the sharing of your personal information for targeted advertising on our websites. The GPC is a proposed specification designed to allow Internet users to notify businesses of their privacy preferences, such as whether or not they want their personal information to be sold or shared. To learn more about the GPC and how you can use it to opt out of the sale or sharing of your personal information you can visit their website: Global Privacy Control. If you visit our website with a browser transmitting GPC, we will not share for targeted advertising or sell your personal information associated with your visit. 

• We do not use or disclose information deemed sensitive under applicable law for purposes other than permitted under such law. We do not knowingly sell or share the personal information of individuals under 16. 

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.

Please note that we do not provide services or sell goods outside of the United States. We may utilize commercially available third-party server hosts to manage our data. Because we do not entirely control where that data resides, we cannot guarantee that the data is stored in the United States.

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at hello@otellacool.com or contact us at Grace Beauty, LLC, 48 Saw Mill Pond Rd, Edison NJ 08817, United States.