Your Rights and Choices

The California Consumer Privacy Act of 2018 (“CCPA”) provides California consumers specific rights concerning their personal information, including, the right to request that we disclose what personal information we collect, use, disclose, and sell. This Section describes your rights and how you may exercise those rights as well as describes how we and third parties handle your personal information.

You or your authorized agent can request: 1) a disclosure of your personal information we collect, use, disclose, or sell; 2) to delete your personal information we collect, or maintain; and 3) to opt-out of the sale of your personal information. If you choose to submit a request through an authorized agent, we will require proof that the authorized agent has your written permission to submit a request on your behalf. Additionally, we may require you to verify your identity with us through the verification process detailed below.

If you choose to exercise these rights, we will not discriminate against you because of it. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and will be described to you in writing. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Requests to Know and Requests to Delete

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. Once we receive and confirm your verifiable consumer request, 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.

·         The specific pieces of personal information we collected about you.

·         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.

You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

You may submit a request to know or request to delete, free of charge, online through our interactive webform here or through our toll-free number at 1-866-ROMANCE. Note that for requests to delete, we may require you to separately confirm that you want your personal information deleted. To verify your identity, we require you provide your name and email. For some requests, we may also require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. Once submitted, you will receive an email within 10 business days that we will use to verify your identity and provide confirmation of your request. If we cannot verify your identity within 45 days, we may deny your request. We will respond to your request to know or request to delete within 45 days from the day we receive the request. If necessary, we may extend the time period to a maximum total of 90 days from the day we receive the request. In such case, you will receive an email notifying you of the extension and explaining the reason for the extension. Any disclosure in response to a request to know will cover the 12-month period preceding the business’s receipt of the request and will be delivered in a readily useable format, by mail or electronically at your option.

Your request to know or request to delete may be denied for any reason allowable under the CCPA. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

·         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, or otherwise perform our contract with you.

·         Comply with a legal obligation.

·         Make other internal and lawful uses of that information that are compatible with the context in which you provided it or any other purpose permitted by the CCPA.

Similarly, we may deny requests:

·         For specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks.

·         To access or delete information that is de-identified.

·         If your identity cannot be verified to a degree of certainty required by the CCPA.

 

Requests to Opt-Out

If you are 16 years of age or older, you have the right to opt-out from a sale of your personal information, however, due to the nature of our products and services, we do collect or sell the personal information of consumers we actually know are less than 18 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you may submit a request at Do Not Sell My Personal Information or through our toll-free number at 1-866-ROMANCE. We will act upon your request no later than 15 days from the date we received the request. Note that we may deny a request to opt-out if we have a good-faith, reasonable, and documented belief that the request is fraudulent. 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 online here.

Collection of Personal Information

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 (“personal 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).	YES
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.	YES
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 may obtain the categories of personal information listed above from the following categories of sources:

·         Directly from you when you provide it to us, such as:

o   Information that you provide by filling in forms. This includes information provided when you establish or update a pureromance.com account, sign up for Pure Romance e-mail, enter a contest, participate in a survey, shop online, check the status of an order, request a catalog, purchase and send an e-gift card or create or send a wish list or gift reminder

o   Records and copies of your correspondence (including email addresses), if you contact us.

o   Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

o   Information to provide to us when you apply for or become a consultant.

·         Through your online activity, such as browsing our Website, placing products in the online cart or clicking on our advertisements, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

o   Information from tracking technologies, such as browser cookies, flash cookies, or web beacons.

o   Details of website visits, such as traffic data, location data, logs, resources used to access the website.

o   Information about the user’s computer and internet connection, such as IP address, operating system, or browser type.

·         From third parties, such as service providers, vendors, contractors, advertisers, ad networks and servers, content providers, application providers or data brokers.

Use of Personal Information

We may collect or share the personal information we collect for one or more of the following business or commercial purposes:

·         To present our Website and its contents to you. The information automatically collected helps us better understand a visitor's experience to the Website and improve upon that experience by recognizing and delivering more of the features, services and products our visitors prefer. It also tells us about the technical efficiencies of our Site and services (e.g., the time it takes a visitor to connect to our Site or download pages).

·         To create user profiles in order to carry out our business and to provide our goods and services and to conduct advertising and promotions more effectively, sometimes using personal or business interests, experience or requests to customize our service for you

·         To provide you with information, products, or services that you request from us, such as when we process, complete and fulfill your order.

·         To fulfill any other purpose for which you provide it.

·         To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

·         To notify you about problems with an order, respond to your request, answer your inquiries or forward your information to one or more Pure Romance Consultants so that they may contact you in response to your communications to us

·         To improve our marketing and promotional efforts, to statistically analyze Website usage, to improve our content and product offerings and to customize our Website’s content, layout, and services.

·         To contact you about Pure Romance products, promotions and event that may be of interest to you.

·         To contact you regarding administrative notices, new product offerings and communications relevant to your use of the Site

·         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 is among the assets transferred.

Sharing Personal Information

In the preceding 12 months, we have disclosed and/or sold personal information to third parties for a commercial or business purpose, as authorized under applicable law. When we disclose or sell personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We do not sell the personal information of minors under 16 years of age without affirmative consent.

 

In the preceding twelve (12) months, we have disclosed and sold the following categories of personal information for a business purpose to the following categories of third parties indicated in the chart below.

 

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	Contractors, vendors, service providers, financial service providers and other third parties we use to support our business	None
B: California Customer Records personal information categories.	Contractors, vendors, service providers, financial service providers and other third parties we use to support our business	None
C: Protected classification characteristics under California or federal law.	Contractors, vendors, service providers, financial service providers and other third parties we use to support our business	None
D: Commercial information.	Contractors, vendors, service providers, financial service providers and other third parties we use to support our business	None
E: Biometric information.	Contractors, vendors, service providers, financial service providers and other third parties we use to support our business	None
F: Internet or other similar network activity.	Contractors, vendors, service providers, financial service providers and other third parties we use to support our business	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.	Contractors, vendors, service providers, financial service providers and other third parties we use to support our business	None

 

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].