This Privacy Policy (“Policy”) describes how Lily Harper International, dba Naked Sundays (“Naked Sundays,” “we,” “us,” or “our”) collects, uses, and discloses the personal information you provide to us when:

·       You use our website located at https://us.nakedsundays.com and any other website or application where this Policy is posted (“Sites”);

·       You communicate with us in any manner, including via text, e-mail, or over the telephone; and

·       When we interact with certain third parties, such as service providers and other vendors.

Please note the following sections that include important disclosures:

·       Washington Residents. If you are a Washington resident, please see our Washington Privacy Notice below.

·       Nevada Residents. If you are a Nevada resident, please see our Nevada Privacy Notice below.

·       Connecticut Residents. If you are a Connecticut resident, please see our Connecticut Privacy Notice below. 

·       California Residents. If you are a California resident, please see our California Privacy Notice below.

·       Cookies, Advertising, and Tracking Technology Disclosures. To learn more about how we use cookies and related technologies, see Automatic Information Collection Technologies below.

·       Your Choices. To learn more about your choices regarding your personal information, see Your Choices below.

 

What Type of Personal Information Do We Collect?

We may collect the following personal information about you directly from you, automatically using certain technologies, and from third parties with whom we interact (e.g., service providers and vendors):

·       Basic Identifying Information. Full name, e-mail, phone number, other similar identifiers.

·       Photographs. Your photograph, selfies, or other images of you.

·       Payment Information. Payment card type, last 4 digits of payment card, billing address, and other related payment information.

·       Commercial Information. Purchase history and consumer profiles (including information you provide in response to our quizzes and surveys).

·       Device Identifier and other Unique Identifiers. Information such as your device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, and other unique identifiers.

·       Website Analytics. Web page interactions, referring webpage/source through which you accessed the Site, non-identifiable request IDs, and statistics associated with the interaction between device or browser and the Site.

·       Demographic Information. Your birth month and year, zip code, and gender.

·       Health Information. Skin condition, type, and shade.

·       Geolocation Information. Information including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).   

·       Audio Information. Information such as videos and recordings of your voice (such as when we record customer service calls for quality assurance).

How Do We Use Automatic Information Collection Technologies?

Our Site and certain of our communications may include several automatic information collection technologies. Below we explain these technologies and how they are used.

What technologies do we use?

·       Cookies. Cookies are small bits of data that are stored on your browser or device that send information about your activity online to servers. Those servers could be maintained by us (i.e., first-party cookies) or by third parties (i.e., third-party cookies). We use three types of cookies – essential, performance, and advertising. Essential cookies are required for providing the Sites to you, and for remembering your preferences. Performance cookies allow us to understand how visitors use our Sites (e.g., transmitting information about the number of visitors to the Site, what pages visitors view, how long they are on the Sites, etc.). For example, we may deploy Google Analytics (maintained by Google, a third party) to provide analytics about how our Sites are used and are performing. Finally, we use advertising cookies. These cookies help us determine what advertising to delivery to you and other users of our Sites both within our Sites but also on third-party websites and platforms, such as social media.

·       Pixels. Pixels are similar but different than cookies. Pixels are code embedded in a website, video, email, or advertisement that sends information about your use to a server. This may transmit information directly, or it may allow for cookies to be placed on your device or browser. For example, we may deploy a TikTok or Snap pixel that allows us to further drive advertising on those platforms.

How do we use these technologies?

·       Functionality, Support and Security. We may use these tools to recognize your device, remember what items are in your shopping bag, enable you to use expedited checkout features, facilitate navigation, display information more effectively, personalize your experience such as recognize you when you leave or return to our Sites, maintain the security of our Sites, manage your account, prevent crashes, fix bugs, save your preferences, and assist with basic Site functions.

·       Facilitate Payments. We offer a variety of payment methods for you to checkout and make purchases on our Sites. Different payment processors may require specific information from you to use their services, which also may be collected with cookies. For more information, see What Payment Processors Do We Use?  

·       Session Replay. Some of the technologies we use recreate your session on our Sites and understand how you navigated our Sites, what content you looked at, and other related information that helps us assess how our Sites are being used. We may obtain this information through the use of cookies and pixels, and may share this with third parties to obtain related insights. For example, we use Hotjar to better understand how visitors use our Sites and to improve the user experience. For more details, see Hotjar’s Privacy Policy

·       Targeted Advertising, Marketing Measurements. We may use cookies and pixels to market our services to you, measure the success of our marketing campaigns, and compile statistics about Site usage and response rates. In addition, we may use the information we have collected from you to enable us to display targeted third-party advertisements on our Sites and on other platforms, such as social media. Some advertisements on the Sites are served by third-party advertisers, ad networks, and ad servers. These third parties may use cookies, alone or in conjunction with pixels or other tracking technologies, to collect information about you. The advertising tools include:

o   Google AdSense. We use Google AdSense to display ads on our Sites. AdSense uses cookies, web beacons, and similar technologies to serve relevant ads, limit how often you see an ad, and measure ad performance. Google may collect information such as your IP address, browser type, device information, and browsing behavior on our Sites and others. This information may be used both to help us deliver ads and by Google for its own advertising and analytics purposes. For more details, see Google’s Privacy Policy.

o   DoubleClick (Google Ads): We use DoubleClick, part of Google’s advertising services, which uses cookies and similar technologies to deliver ads, measure their performance, and prevent fraud. DoubleClick may collect information such as your IP address, cookie ID, browser details, the ads you view, and your interactions with our site. This information may be used both to improve our campaigns and by Google for its own advertising purposes. For more details, see Google’s Privacy Policy.

o   Meta (Facebook) Pixel: We use the Meta Pixel, a small piece of code that uses cookies and similar tools to track actions you take on our Sites (e.g., visiting a page, signing up, or making a purchase). This information is shared with Meta (Facebook) to measure the effectiveness of our ads and deliver more relevant advertising. Meta may also use this information for its own advertising and analytics purposes. You can learn more in Meta’s Privacy Policy.

o   Facebook Custom Audience. We use Facebook Custom Audience to deliver ads that are more relevant to people who have interacted with us. This tool uses cookies, pixels, and similar technologies to match information we collect (such as email addresses or site activity) with Facebook’s systems. This allows us to show ads to our customers or people with similar interests when they use Facebook or Instagram. Meta may also use this information for its own advertising and analytics purposes. For more details, see Meta’s Privacy Policy.

o   TikTok Pixel. We use the TikTok Pixel to better understand how our ads perform and how visitors engage with our Site. The pixel uses cookies or similar technologies to track actions like page visits and purchases. This information is shared with TikTok to help us improve advertising, and TikTok may also use it for its own advertising and analytics purposes. For more information, see TikTok’s Privacy Policy.

o   Pinterest Conversion API/Tracking: We use the Pinterest Conversion API, along with technologies such as cookies, pixels, and web beacons, to understand how visitors use our Sites and to measure the effectiveness of our ads. These tools may collect information like your device and browser details, pages you visit, and actions you take on our site (for example, making a purchase). We share this information with Pinterest so they can help us analyze site activity and show ads that may be more relevant to you. Pinterest may also use this data for its own advertising and analytics purposes. For more details, please see Pinterest’s Privacy Policy.

o   Snap Pixel (Snapchat Analytics & Ads). We use the Snap Pixel to help measure how our Site performs after someone views a Snapchat ad. It tracks actions like pages you visit, items you add to your cart, and purchases, so we can improve our ads and offer better service. Information about your activity is shared with Snapchat for measurement and ad-targeting, and Snapchat may also use it for its own advertising and analytics purposes. To learn how Snapchat handles the data they collect, please see Snapchat’s Privacy Policy.

o   AdRoll. We use AdRoll, which places cookies, pixels, and similar technologies to show you ads for our products and services after you’ve visited our Sites. AdRoll may collect information such as the pages you view, how you interact with our Sites, and your device and browser details. This helps us deliver ads that are more relevant to you across different websites and apps, and AdRoll may also use this information for its own advertising and analytics purposes. For more details, see AdRoll’s Privacy Notice.

o   AppLovin. We use AppLovin, which uses cookies, device identifiers, and similar technologies to help deliver, measure, and improve ads. AppLovin may collect information such as your device type, operating system, IP address, app or site activity, and interactions with ads. This data helps us and AppLovin show ads that are more relevant to you and understand how our campaigns perform across websites, apps, and devices. AppLovin may also use this data for its own advertising and analytics purposes. For more information, see AppLovin’s Privacy Policy

What Payment Processors Do We Use?

We use a variety of payment processors to facilitate your purchase of products on our Sites. These payment processors may collect your personal information directly, or through the use of cookies. The payment processors we use include:   

·       Shopify. We use ShopPay from Shopify to securely process transactions on our Sites. Shopify may access your personal information to securely process a payment, and also use your information to detect and prevent fraudulent transactions. For more information about how Shopify Payments handles your information, please see Shopify’s Privacy Policy.

·       Square. We use Square’s Square Pay to securely process transactions on our Sites. Square uses your personal information to process payments, and protect against fraud. To learn more, see Square’s Privacy Policy.

·       Stripe. We implement Stripe to securely process payments on our Sites. Stripe uses your personal information to process transactions, detect and prevent fraud, and for other business purposes, including improving its services and supporting analytics. For more information, see Stripe’s Privacy Policy.

·       GooglePay. When you choose Google Pay at checkout, Google collects information such as your payment method, transaction amount, merchant details, and device information. This information is used to process your payment, help prevent fraud, and comply with legal obligations. Google may also use aggregated or de-identified transaction data to improve its payment services and related Google products. For more details, see Google Pay’s Privacy Notice

·       PayPal. We offer PayPal Checkout so you can securely pay using your PayPal account or supported payment methods. When you choose PayPal at checkout, PayPal collects information such as your payment details, transaction amount, merchant information, device information, and other identifiers. PayPal uses this data to process your payment, detect and prevent fraud, and comply with legal obligations. PayPal may also use certain data for its own business purposes, such as improving its services, supporting analytics, and in some cases personalizing offers. For more information, see PayPal’s Privacy Statement.

·       AfterPay. We offer Afterpay to allow you to split your purchase into installment payments. When you choose Afterpay at checkout, Afterpay collects information such as your payment details, transaction amount, purchase history, device identifiers, and contact information. This information is used to process your installment plan, determine eligibility, and prevent fraud. Afterpay may also use your information to comply with legal obligations, assess creditworthiness, and improve its services. For more information, see Afterpay’s Privacy Policy.

How Do We Use Your Personal Information? 

·       Provide our Site to You. We use your information to provide our Sites to you, including to: (1) create and manage your account when you sign-up to use our Sites; (2) facilitate your access and use of our Sites; (3) process and fulfill your orders; (4) send you notifications relating to your account; and (5) perform other related business functions.

·       Communicate with You. We use your information to communicate with you, such as to respond to your requests, inquiries, issues, feedback, and to provide customer service.  

·       Market and Advertise. We use your information for marketing and advertising purposes, including sending marketing, advertising, and promotional communications to you by email, text message, or postal mail. We also use your information to show you advertisements on the Site, to administer contests, and to send you advertising and marketing through other channels such as through social media.   

·       Conduct Analytics and Personalization. We use your information to conduct research and analytics, including to improve our Sites and the products we offer. We also use your information to understand your interaction with our Sites, advertisements, purchase preferences, and our communications with you. We also use your information to personalize your experience, to save you time when you visit our Sites, to better understand your needs, and to provide personalized recommendations for our products.  

·       Security and Fraud Prevention. We use your information to detect, investigate, prevent, or take action against malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions. We also use your information to enforce our terms, procedures, prevent against security incidents, and prevent harm to other individuals or entities.  

·       Legal Obligations. We use your information to comply with our legal and regulatory obligations, to establish and exercise our rights, and to defend against legal claims.

·       Business Functions. We use your information to support our core business functions, including to maintain records related to business management, loss prevention, collecting amounts owed, and identifying and repairing errors or problems on the Site.  

How Do We Disclose Your Personal Information?

We may disclose your personal information:  

·       With Affiliated and Non-Affiliated Third Parties. We may share your personal information with certain affiliated and non-affiliated third parties:

o   Service Vendors. These include companies that are providing services to us, including: (i) payment processing partners such as Stripe, PayPal, Afterpay, ShopPay, and Google; (ii) hosting, technology and communication providers; (iii) security and fraud prevention consultants; (iv) support and customer service vendors; (v) product fulfillment and delivery providers; (vi) payment processors.

o   Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include ad networks, marketing providers, and data brokers.

o   Analytics Partners. These parties provide analytics on web traffic or usage of the Sites, including organizations that track how users found and interact with the Sites.

o   Business Partners. These parties partner with us in offering various services. They include businesses that you have a relationship with, and companies that we partner with to offer joint promotional offers or opportunities.

o   Parties You Authorize, Access or Authenticate. These parties may be those you access through our Sites, including but not limited to social media platforms.

·       To Fulfill Legal Obligations. We may disclose or share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (i) enforce or apply our agreements; (ii) protect our interests, property, or safety of others; (iii) in connection with claims, disputes, or litigation; and (iv) to protect our Sites.

·       Business Transfers. Your personal information may be disclosed to a third party if we undergo a merger, acquisition, bankruptcy or other business transaction in which that third party requires such information to complete or facilitate the transaction.

·       With Your Consent. We may disclose or share your personal information with your consent, which may be obtained in writing; online, through “click-through” agreements; when you accept the terms on our Site; orally, either in person or on the phone; or by other means.

How Do We Secure Your Personal Information?

We deploy and maintain commercially reasonable physical, technical, and organizational safeguards to protect your personal information from unauthorized access, use, disclosure, or destruction. You should also help protect your personal information by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

How Long Do We Retain Your Personal Information?

We retain your personal information about you for as long as necessary to provide you with our Site or to perform our business or commercial purposes, and to comply with applicable law.

Links to Third Party Sites

Our Site may contain links to third party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review and consider before proceeding.

Your Choices

·       Account. You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to the email address set out as set out in the Contact Us section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

·       Communications. The following is information about how to opt out of receiving certain communications from us, depending on means of delivery:

o   E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out as set out in the Contact Us section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.

o   Phone & SMS Text Messaging. You can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set out in the Contact Us section below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set out in the Contact Us section below and specifying you want to opt-out of calls.

o   Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our mobile application.

·       Cookies and Tracking Technologies. The following disclosures relate to your choices in connection with cookies and other tracking technologies. Please be aware that if you disable or remove tracking technologies, some parts of the Sites may not function correctly. If you disable or refuse cookies, some parts of this website may then be inaccessible or not function properly:  

o   Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. We do not currently monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

o   Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. Below are links to instructions for managing cookies on commonly used browsers:

1.     Google Chrome: https://support.google.com/chrome/answer/95647   

2.     Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09   

3.     Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox   

4.     Safari (macOS): https://support.apple.com/en-us/H+T201265   

 

o   Analytics and Interest-Based Advertising.

1.     Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/. 

2.     The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services). To opt out of us using your data for Matched Ads, please contact us as set forth in the Contact Us section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you Matched Ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out. You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

3.     Facebook: You may control how Facebook shows you ads by adjusting your settings in your Facebook account or visiting https://www.facebook.com/settings?tab=ads. 

4.     Google Ads: Users can opt out of cookies used by Google for advertising. Each site where the privacy policy is posted must provide users with at least one of the following two options for opting out:

·       Opting out of Google advertising cookies: Users can opt out of Google's use of cookies for advertising, including DoubleClick cookies, by visiting Google's Ads Settings page.

·       Opting out of cookies from all participating advertisers: Users can opt out of third-party advertising cookies from a wide range of advertising services, including Google, by visiting the NAI's Opt-Out page.

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

Do We Collect The Personal Information Of Children?

No. We do not knowingly collect or solicit the personal information of children under 16 years of age. If you are a child under the age of 16, please do not attempt to register for or otherwise use the Site or provide us with any personal information. If we learn we have collected personal information from a child under 16 years of age, we will delete that information as quickly as possible.

California Privacy Notice

If you are a California resident under 18 years old and a registered user of the Sites, you can request that we remove content or information that you have posted to our Sites or other online services. Fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please send an email to info@nakedsundays.com.

Nevada Privacy Notice

Sale of Personal Information

If you are a Nevada resident, you have the right to submit a request directing us not to make any sale of your personal information. Naked Sundays does not sell your personal information as defined under Nevada law. However, to request email confirmation that we do not, and will not sell your personal information, please send an email to info@nakedsundays.com with “Nevada Opt-Out of Sale” in the subject line and in the body of your message.

Health Data Privacy Notice

You have certain rights over how we process your health data under Nevada law. For this section, “health data” refers to information that is linked or reasonably capable of being linked to you and that is used to identify any past, present, or future health status of you. This may include any health condition or treatment, such as your skin condition.

What categories of health data do we collect from you, and why do we collect it? When you answer our quizzes, we collect information concerning your skin condition, tone, and preferences. The purpose of this collection is to provide you with certain product recommendations.

Who do we collect your health data from, and how do we collect it? We collect your health data when you directly engage with us through our Sites.

How do we use your health data? We use your health data to determine appropriate product recommendations, courses of skin treatment, or other related purposes.

Do we share your health data, and with whom? No.

How will you notify me of any material changes to this notice? We will provide you with a notice via e-mail, posting on the Site, or other appropriate method.

Will any third parties track my health data across other websites? No.

What rights do I have concerning my health data? You may submit a request to info@nakedsundays.com for the following concerning your health data, subject to exceptions recognize by law:

·       Access. Confirm whether we collect, share, or sell your health data. We may also provide a list of all third parties with whom we’ve shared or sold your health data.

·       Correction. You may review and request changes to your health data.

·       Withdraw Consent. You may withdraw consent from us collecting, sharing, or selling your health data.

·       Deletion. Delete your health data.

Washington Privacy Notice

If you are a Washington resident, the following disclosures are provided to you pursuant to the Washington MY Health MY Data Act. The phrase “health data” below means information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. Physical health status can include individual health conditions or treatment, such as skin condition.

What categories of health data do we collect from you, and why do we collect it? When you answer our quizzes, we collect information concerning your skin condition, tone, and preferences. The purpose of this collection is to provide you with certain product recommendations.

Who do we collect your health data from, and how do we collect it? We collect your health data when you directly engage with us through our Site.

How do we use your health data? We use your health data to determine appropriate product recommendations, courses of skin treatment, or other related purposes.

Do we share your health data, and with whom? No.

What rights do I have concerning my health data? You may submit a request to info@nakedsundays.com for the following concerning your health data, subject to exceptions recognize by law:

·       Access. Confirm whether we collect, share, or sell your health data, and access such data, including a list of all third parties and affiliates with whom we have shared your health data and an email address or other online mechanism that you can use to contact such third parties.

·       Withdraw Consent. You may withdraw consent from us collecting and sharing your health data.

·       Deletion. Delete your health data.

·       Appeal. Appeal any refusal by Naked Sundays to take action on any of the above requests. Such appeals must be submitted within 30 days from the date of refusal.

Connecticut Privacy Notice

If you are a Connecticut resident, the following disclosures are provided to you pursuant to the Connecticut Data Privacy Act. For the purpose of this section, the phrase “health data” means any personal information that we use to identify your physical or mental health condition or diagnosis, which can include skin condition.

What categories of health data do we collect from you, and why do we collect it? When you answer our quizzes, we collect information concerning your skin condition, tone, and preferences. The purpose of this collection is to provide you with certain product recommendations.

Who do we collect your health data from, and how do we collect it? We collect your health data when you directly engage with us through our Site.

How do we use your health data? We use your health data to determine appropriate product recommendations, courses of skin treatment, or other related purposes.

Do we share your health data, and with whom? No.

What rights do I have concerning my health data? You may submit a request to info@nakedsundays.com for the following concerning your health data, subject to exceptions recognize by law:

·       Access. Confirm whether we process your health data and access such data.

·       Correction. Correct inaccuracies in your health data.

·       Deletion. Delete your health data.

·       Copy of Health Data. Request a copy of your health data in a portable and where feasible readily usable format that would allow you to transmit the data to another entity.

·       Appeal. Appeal any refusal by Naked Sundays to take action on any of the above requests. Such appeals must be submitted within 30 days from the date of refusal.

Accessibility

If you require a copy of this Privacy Policy in an alternative format, please email us at info@nakedsundays.com.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at info@nakedsundays.com.