Conopco d/b/a Schmidt’s Naturals, (“Schmidt’s Naturals™,” “we,” “us” or “our”) respects your concerns about privacy and values the relationship we have with you. This Schmidt’s Naturals™ Privacy Statement (“Privacy Statement”) describes the types of personal information that we collect about our customers, how we use this information, with whom we share it, and the choices available to our customers regarding our use of this information. In this Privacy Statement, we also describe the measures we take to protect the security of the information that we collect and how our customers can contact us about our privacy practices. We collect information from you when you: (a) access or use the Site; (b) access and/or download any of the text, audio, video, photographs, graphics, artwork, testimonials and/or other Schmidt’s Naturals™ content featured on the Site, including information concerning Schmidt’s Naturals’™ products and services (collectively, “Content”); (c) utilize the searchable directory of retail outlets that carry Schmidt’s Naturals™ products (“Store Locator”); (d) register for, and obtain information about, the Schmidt’s Naturals™ Recycling Club (“Recycling Club”); (e) register to enter one or more promotions, giveaways, sweepstakes, referral programs and/or any other program that enables users to apply to receive product discounts that may be offered by Schmidt’s Naturals™ from time-to-time (collectively, “Promotions”); (f) access links to Schmidt’s Naturals’™ social media pages/accounts featured on third-party social media websites, such as Facebook®, Instagram®, SnapChat®, Twitter® and YouTube® (collectively, “Social Media Pages”); (g) register to receive Schmidt’s Naturals™ e-mails containing promotional offers and Product updates (“Newsletter”); (h) purchase Schmidt’s Naturals™ products, services and/or merchandise featured on the Site (collectively, “Products”); and/or (i) register for a subscription service associated with the Products (“Subscription Services” and together with the Site, Content, Store Locator, Recycling Club, Social Media Pages, Promotions, Newsletter and Subscription Services, the “Site Offerings”).
Capitalized terms not defined herein shall have the meanings set forth in the Schmidt’s Naturals™ Website Terms of Service (“Terms of Service”). IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY STATEMENT IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.
Facebook® and Instagram® are registered trademarks of Facebook, Inc. (“Facebook”). Snapchat® is a registered trademark of Snap Inc. (“Snap”). Twitter® is a registered trademark of Twitter, Inc. (“Twitter”). YouTube® is a registered trademark of Google, Inc. (“Google”). Please be advised that Schmidt’s Naturals™ is not in any way affiliated with Facebook, Google, Snap or Twitter, and the Site Offerings are not endorsed, administered or sponsored by any of the foregoing entities.
SECTION 1 – INFORMATION THAT WE COLLECT AND INFORMATION THAT YOU PROVIDE
Personal Information. We may obtain personal information about you from various sources. You may choose to provide personal information to us in a number of ways, such as when you register for access to certain Site Offerings, participate in a Promotion and/or when you make a purchase on the Site. The types of information that you provide to us may include, without limitation and depending on the applicable registration form: (a) your name; (b) your mailing/billing address; (c) your e-mail address; (d) your telephone number; (e) your credit card information (where purchasing Products and/or utilizing the Subscription Services); (f) your date of birth; and/or (g) any other information requested on the Form. For purposes of this Privacy Statement, item (e) in the preceding sentence shall be referred to as “Sensitive Information.” We may also collect information about your purchase history.
Computer IP Addresses/Browser Type. We may collect certain non-personally identifiable information about you and your desktop computer when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T).
Cookies. When a user visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable user’s computer and/or mobile device, as applicable. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience on the Site. To find out more about Cookies, please visit www.cookiecentral.com.
Mobile Device Information. We may collect certain non-personally identifiable information about you and your mobile device when you access the Site and/or visit certain Site pages. This non-personally identifiable information includes, without limitation, the following information pertaining to your mobile device and your use of the Site: (a) mobile device platform type; (b) mobile device identifier; (c) SDK version; (d) API key; (e) iOS Identifier for Advertising (if applicable); (f) iOS Identifier for Vendors (if applicable); (g) Media Access Control (MAC) address; (h) International Mobile Equipment Identity (IMEI); (i) the model type, manufacture and iOS version of the mobile device; (j) your Site session start/stop time and date; and (k) the actions taken while utilizing the Site.
SECTION 2 – BEHAVIORAL TRACKING; CALIFORNIA DO NOT TRACK NOTICE
Behavioral Tracking/California Users
California law requires website and online service operators to disclose whether they and/or third-parties may collect personal information about their users’ online activities over time and across different sites when the users use the applicable operator’s website or service. Schmidt’s Naturals™, as well as third-parties that have content or services on the Site (as further detailed below), such as a social feature, analytics service or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. These third-parties do not necessarily change their tracking practices in response to “do-not-track” signals from your web browser and we do not obligate these third-parties to honor “do-not-track” signals. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.
California law also requires that website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers with the ability to exercise choice regarding the collection and use of personal information about a consumer’s online activities over time and across third-party websites. We currently do not change our tracking practices in response to “do-not-track” signals or other similar mechanisms.
Third Party Activity
As mentioned above, we allow third-party companies to collect certain information when you visit the Site. These companies may utilize cookies, pixels or other technologies to collect and use both personally identifiable information (e.g., your name, phone number, physical or electronic address, etc.) and non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, etc.) during your visits to the Site, as well as when you visit other websites, in order to provide advertisements about goods and services likely to be of greater interest to you. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third parties in connection with the Site.
Users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. To learn more about this behavioral advertising practice, as well as to learn about other options for opting-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info and/or Networking Advertising Initiative at www.networkadvertising.org/choices.
You can opt-out of Google® Analytics and customize the Google® Display Network ads that you receive by visiting the Google® Ads Settings (http://www.google.com/settings/ads) page. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for your web browser. The Google® Analytics Opt-Out Browser Add-on provides users with the ability to prevent their data from being collected and used by Google® Analytics.
For more information on the privacy practices of Google®, please visit the Google® Privacy & Terms (http://www.google.com/intl/en/policies/privacy/) web page.
Google’s® Use of the DoubleClick Cookie
You may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting the Google® Ads Settings (http://www.google.com/ads/preferences/) web page.
SECTION 3 - HOW WE USE THE INFORMATION
We may use your personal information, as well as information collected through automated means, for market research, data analytics and system administration purposes, such as to determine whether you have visited the Site before or are new to the Site. In addition, we may use this information to tailor ads displayed to you on the Site (and elsewhere), for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our Terms of Service, as well as to improve the design and content of the Site Offerings. We also may use this information in the aggregate to analyze usage of the Site Offerings.
Other than as set forth in this Privacy Statement, Schmidt’s Naturals™ will never share, sell, rent, exchange or barter your personal information to or with any third-party for financial gain or marketing purposes. By making that personal information available to Schmidt’s Naturals™, you grant Schmidt’s Naturals™ the right, subject to applicable state and federal law, to use that personal information (other than Sensitive Information) to contact you by telephone, email and to send you various marketing messages that contain promotional offers from Schmidt’s Naturals™, as well as offers from Schmidt’s Naturals’™ third-party partners, that Schmidt’s Naturals™ believes may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message, or see the “Opt-Out/Unsubscribe” section below. Without limiting the foregoing, we may use the information that you provide to:
- Provide the Site Offerings and/or Products to you.
- Respond to your inquiries and provide customer service functions.
- Assist with online Product selection and replenishment.
- Process your payment card and/or gift card transactions.
- Operate, evaluate and improve the Site Offerings and/or our business in general (including:
- (a) developing new products and services;
- (b) managing our communications;
- (c) analyzing our Products and/or Site Offerings;
- (d) performing data analytics;
- and (e) performing accounting, auditing and other internal functions).
- Operate and communicate with you about the Site Offerings.
- Tailor ads displayed to you on the Site, and elsewhere, to your interests and history with us.
- Create and manage your online account, including access to your online purchase history.
- Comply with applicable legal requirements, relevant industry standards and our policies.
- Communicate with you about, and administer your participation in, special events, Promotions and other offers.
We may also use the information in other ways for which we provide specific notice at the time of collection.
By submitting your personal information by and through the Site Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
Where you provide “prior express written consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive, from Schmidt’s Naturals™, telephone calls, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Site Offerings or purchase Products, and your consent simply allows Schmidt’s Naturals™ to contact you via these means. Please be advised that by agreeing to this Privacy Statement, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (i) have your telephone number reassigned to another person or entity; (ii) give up your telephone number so that it is no longer used by you; (iii) port your telephone number to a landline or vice versa; or (iv) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify us of the Phone Number Change via e-mail at: [email protected], or by using one of the methods set forth in the “Contact Us” section below.
SECTION 4 – INFORMATION THAT WE SHARE
We do not rent lists or sell or otherwise disclose personal information that we collect about you, except as described herein. We may share your personal information with:
- Our corporate affiliates.
- Third-party service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfill orders, and those that provide web hosting, advertising and/or marketing services. Without limiting the foregoing, if you choose to purchase Products, the credit or debit card information provided will either be collected directly by our third-party service provider(s), or we will share that payment information with our contracted third-party service provider(s). Schmidt’s Naturals™ requires that its third-party payment processing service provider(s) has/have in place privacy policies and practices consistent with this Privacy Statement; provided, however, that we cannot guarantee the privacy practices of our third-party payment processing service provider(s).
- Other third-parties with your consent.
In addition, we may disclose information about you (including Sensitive Information): (a) if we are required to do so by law or legal process; (b) to law enforcement authorities or other government officials pursuant to a subpoena or other valid request; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; (c) in the event that we believe that the Site Offerings are being or have been used in violation of the Terms of Service and/or to commit unlawful acts; or (d) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
We also reserve the right to transfer personal information we have about you in the event that we sell or transfer all or a portion of our business or assets, or are the subject of bankruptcy proceedings. Should Schmidt’s Naturals™ become involved in a bankruptcy proceeding, or in the event that such a sale or transfer occurs, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
SECTION 5 – SOCIAL MEDIA WEBSITES/INTERACTIVE SERVICES
If you engage in any interaction with Schmidt’s Naturals™, other Site users or any third-party on any Social Media Pages or via any interactive features of the Site (“Interactive Services”), you should be aware that: (a) the personal information that you submit by and through such Social Media Pages and/or Interactive Services, as applicable, can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Schmidt’s Naturals™ responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Schmidt’s Naturals’™ social media accounts.
We are not responsible for the personal information that you choose to submit on any Social Media Websites or via the Interactive Services. The Social Media Websites operate independently from Schmidt’s Naturals™, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.
SECTION 6 - CONSENT
We will not collect, use or disclose your personal information without your consent. In some cases, we will ask for your consent explicitly. For example, we may ask for your express consent when seeking personal information for marketing purposes, and provide you with an opportunity to decline.
However, in some cases, we may infer consent from your actions and/or behavior. For example, when you provide us with personal information to access the Site, complete a transaction, verify your credit card information, place an order, arrange for a delivery or return a purchase, you consent to our collecting your information. By using the Site, you consent to our collecting, using and disclosing of your personal information in accordance with this Privacy Statement.
We may ask you to provide additional consent if we need to use your personal information for purposes not covered by this Privacy Statement. You are not obliged to provide such consent, but if you decide not to, then your participation in certain activities may be restricted. If you provide additional consent, the terms of that consent shall prevail in the event of any conflict with the terms of this Privacy Statement.
SECTION 7 – OPT-OUT/UNSUBSCRIBE
At any time, you can direct us not to send you marketing communications by email, telephone or otherwise, by: (a) clicking on the unsubscribe link within the marketing emails you receive from us; (b) otherwise following the instructions included in the applicable e-mail message or other communication; or (c) contacting us via email at: [email protected]; or sending U.S. mail to us at: Schmidt's Deodorant, 12602 NE Marx Street Portland Oregon US 97230.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, participation in any Promotions and/or purchase of Products, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related, Promotions-related, Products-related and/or inquiry response-related messages from Schmidt’s Naturals™, you must cease requesting and/or utilizing the Site Offerings, cease participating in Promotions, cease requesting Products and/or cease submitting inquiries to Schmidt’s Naturals™, as applicable.
SECTION 8 - SHOPIFY
Our online store is hosted on Shopify Inc. (“Shopify”). Shopify provides our Site with the online e-commerce platform that allows us to sell our Products to you. When you make a purchase by and through our online store, your data is stored through Shopify’s data storage databases and the general Shopify application. Shopify has represented to us that it stores your data on a secure server behind a firewall.
For more insight, please read Shopify’s Terms of Service (https://www.shopify.com/legal/...) and/or Privacy Statement (https://www.shopify.com/legal/...), each of which Shopify has the right to modify from time to time.
SECTION 9 - THIRD-PARTY WEBSITES/SERVICE PROVIDERS; INTERNATIONAL TRANSFERS
This Site may contain links to third-party owned and/or operated websites including, without limitation, the Social Media Websites. Schmidt’s Naturals™ is not responsible for the privacy practices or the content of such websites. Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Statement or our Terms of Service.
These third-party websites have separate privacy and data collection practices and Schmidt’s Naturals™ has no responsibility or liability relating to them. In addition, the third-party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services that they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information that we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so that you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain service providers may be located in or have facilities that are located in a different jurisdiction than either you or Schmidt’s Naturals™. If you elect to proceed with a transaction that involves the services of a third-party service provider, please be advised that your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Without limiting the foregoing, if you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site, and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Statement.
SECTION 10 – CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits customers who 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: (a) send us a written request by email to: [email protected]; (b) call us at: (855) 866-9748; or (c) send us a written request by U.S. mail to: 12602 NE Marx Street, Portland, OR 97230.
SECTION 11 - SECURITY
We endeavor to safeguard and protect our users’ personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where we ask users to enter Sensitive Information, if ever, and when we store and transmit such Sensitive Information, that information is encrypted with advanced TLS (Transport Layer Security).
Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need user personal information to perform a specific job are granted access to user personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store user personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
SECTION 12 - DELETING, MODIFYING AND UPDATING YOUR INFORMATION
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: [email protected] We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your personal information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the personal information that we have on file for you.
Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
SECTION 13 - MINORS
Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Schmidt’s Naturals™ does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Schmidt’s Naturals™ encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
SECTION 14 - CHANGES TO THIS PRIVACY STATEMENT
SECTION 15 – CONTACT US
If you have any questions or comments about this Privacy Statement, or if you would like us to update any information that we have about you or your preferences, please contact us by email at: [email protected]; call us at: (855) 866-9748; or send us U.S. mail to: 12602 NE Marx Street, Portland, OR 97230.
SECTION 16 - FILING A COMPLAINT WITH THE FEDERAL TRADE COMMISSION
To file a complaint regarding our privacy practices, you can do so through the FTC Complaint Assistant.