Privacy Policy CCPA

 

Credo Beauty Privacy Policy for California Residents

Effective Date: November 3, 2023

This Privacy Policy for California Residents supplements the information contained in Eco-Chic, LLC’s general Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We obtain the categories of personal information listed above directly from you.  For example, from forms you complete or products and services you purchase.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We may also share your personal information with third parties for cross-context behavioral advertising, which constitutes a sale under the CCPA.  You may opt-out of those sales.  In the preceding twelve (12) months, Company has sold personal information as indicated in the chart below.  For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

 

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	Email and SMS service provider; payment processors; catalog service company.	Database management company (for cross-context behavioral advertising)
B: California Customer Records personal information categories.	Email and SMS service provider; payment processors; catalog service company.	Database management company (for cross-context behavioral advertising)
C: Protected classification characteristics under California or federal law.	None	None
D: Commercial information.	Email and SMS service provider; payment processors; catalog service company.	Database management company (for cross-context behavioral advertising)
E: Biometric information.	None	None
F: Internet or other similar network activity.	None	None
G: Geolocation data.	None	None
H: Sensory data.	None	None
I: Professional or employment-related information.	None	None
J: Non-public education information.	None	None
K: Inferences drawn from other personal information.	None	Database management company (for cross-context behavioral advertising)

Reselling Personal Information

The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. We share personal information with Oracle Advertising (Oracle Data Cloud), which allows us to access data compiled by Oracle so as to improved our interest-based advertising.

For information on Oracle Advertising’s opt-out mechanisms and information on how to access the data collected and processed by Oracle Advertising, please visit the Oracle Advertising opt-out and access site, available at: https://datacloudoptout.oracle.com.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

 

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at 1-844-692-7336.
• Emailing us at ccpa@credobeauty.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by either:

• Calling us at 1-844-692-7336.
• Emailing us at ccpa@credobeauty.com.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
• Identifying recently purchased items.
• Specifying the date of a recent order and/or the dollar amounts of recent purchases.
• A signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.
• Parents and guardians will be required to match at least three (3) pieces of personal information we have pertaining to their child, and they must submit a signed declaration under penalty of perjury that the requestor is the parent and/or legal guardian of the consumer whose personal information is the subject of the request.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, call us at 1-844-692-7336 or email us at ccpa@credobeauty.com.

 

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email arealperson@credobeauty.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance[, specifically a .csv file format of your product order(s) history.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). To exercise the right to opt-out, you (or your authorized representative) you can update your preferences on the cookie pop-up on our website.  Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at ccpa@credobeauty.com with the subject line “Opt In Notice” so that we may document in writing your affirmative authorization of personal information sales.  We will, however, contact you upon receiving your email solely to verify that you are authorizing such sales before we honor your request to opt back in.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

We do not knowingly sell the personal information of consumers we actually know are less than 16 years old.  If you are under the age of 16 years of age, please do not use our Website or submit any personal information to us.  If you are the parent or guardian of a person between the ages of 13 and 15, please inform us at arealperson@credobeauty.com so that we may discuss with you whether you wish to provide affirmative authorization (the "right to opt-in") for us to sell information based on your child’s use of the Website and its features.  Consumers who opt-in to personal information sales may opt-out of future sales at any time.  Under no circumstances, however, is our Website to be used by any consumer under the age of 16 before we are contacted so that we may obtain affirmative authorization to collect personal information from you.  

Notice of Financial Incentives

As permitted by the CCPA, we may offer you certain financial incentives and benefits by joining our loyalty program. The information that we collect for enrollment in the program (listed above) allows us to tailor our communications and products and services suggestions for you. This, in turn, helps us establish a stronger relationship with you – something we deeply value.

If you participate in our loyalty program, there are two types of financial incentives:

• Points. You can earn points when you purchase products from our online store that can be used to discount the price of future purchases with us. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value. We estimate the value of personal information we request from our loyalty program customers by comparing the amount spent by loyalty program customers to similarly-situated customers who do not participate in the loyalty program over a 12-month period.
• Discounts. We may also send you promotions to discounted products and services. The value of these discounts vary and depend on the type of product you are buying. For example, you could receive $10 off an order when you refer a friend.

In determining the value of this data to us, we consider the profit generated from products that include personal information, which is reasonably correlated to the value provided to the consumer through personalized coupons, promotions, and other discounts or offers.

Participation in the loyalty program is voluntary and requires your prior opt-in consent, which you may revoke at any time. If you wish to leave the loyalty program, please reach out to us using the information in the Contact Information section below.

For full program details, please visit https://credobeauty.com/pages/rewards.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose personal information protected under this section to third parties for their own direct marketing purposes.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Eco-Chic, LLC collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-844-692-7336

Email: ccpa@credobeauty.com

Postal Address:

Eco-Chic, LLC

Attn: Customer Experience

5214F Diamond Heights Blvd., Unit 1558

San Francisco, CA 94131

If you need to access this Policy in an alternative format due to having a disability, please contact arealperson@credobeauty.com and/or 1-844-692-7336.