Effective Date: April 30, 2021
Please be aware that our services and systems are housed on servers in the United States, and the information we collect (including through Cookies, as defined below) is processed and stored in the United States, which may not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE SERVICES AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO AND PROCESSING OF THE INFORMATION IN THE UNITED STATES.
1. COLLECTION OF YOUR INFORMATION
ItchFreeZone may collect personally identifiable information from you in various ways, depending on your use of the Services. Examples include:
- When you sign up to mailing lists at ItchFreeZone websites or ItchFreeZone retail store/kiosk locations;
- When you complete an online, retail or telephone purchase;
- When you enter an ItchFreeZone sponsored sweepstakes or giveaway;
- When you submit a product or warranty claim; and
- When you contact ItchFreeZone, such as by contacting our customer service or submitting information via a web form.
Personally identifiable information refers to information about you that can be used to contact or identify you or your household. It includes, but is not limited to, your name, phone number, email address, postal address and social networking information. If you choose to make a purchase using a credit card or gift card, ItchFreeZone or its third party payment processors may also collect billing information such as credit card numbers or gift card numbers.
ItchFreeZone may also collect certain non-identifying information, or aggregate information, such as anonymous demographic information including zip codes, dates of birth, customer preferences, information about customer computer hardware and software, as well as information about the links and pages that users access within an ItchFreeZone website. Certain non-identifying information may be considered personally identifiable information if combined with other information which may enable you to be identified (such as a zip code with a street address); however, the same information when taken alone or combined with other non- identifying information, will be considered non-identifying information.
In particular, we have collected the following categories of personal information from users in the last twelve (12) months. We obtain these categories of personal information with the methods described in more detail below.
|Category||Examples||Is Any of This Information 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.
Note: Some personal information included in this category may overlap with other categories.
|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.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
Additionally, the following types of personal information are excluded from the CCPA’s scope:
- Certain health or medical information otherwise covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
1.1 Social Media
Some of this information is collected from your use of, and interactions with, us and others on social media. Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through ItchFreeZone operated public message boards or on third-party social media sites, such information may be collected and used by others. We are not responsible for the personal information that you choose to submit or link on any social media. We encourage you to review the privacy policies and settings of any third-party social media services that you interact with.
1.2 Information Automatically Collected
When you visit our website, we automatically collect the name of the website you visited from (called the “referring page”) and the name of the website you chose to visit immediately after ours (called the “exit page”), and information about other third-party websites you have recently visited. This information is used to improve our Services, but we cannot identify you from any information we receive from Cookies. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our websites are not currently set up to respond to those signals for tracking on our websites.
1.3 Participation in Interest-Based Advertising
ItchFreeZone may also participate in interest-based advertising using similar tracking technology. This means that you may see advertising on our websites tailored to how you browse or shop, or you may see advertising for ItchFreeZone and its properties on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to advertising networks that use your web browsing history to choose which ads to display on their network websites; these ads may include advertising for ItchFreeZone and its websites, but we do not share personal information about you with those third-party advertising networks. Other websites where you see our ads, such as Facebook, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites such as Facebook, and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information.
1.4 External Links
2. USE OF YOUR INFORMATION
2.1 Business Purposes
ItchFreeZone may store and use your personally identifiable information for one or more of the following business purposes (each a “Business Purpose”):
- product or service fulfillment,
- to provide you with support, to communicate with you and respond to your inquires,
- marketing, promotional and advertising purposes, such as to inform you of products or services available from ItchFreeZone,
- internal operations, such as improving your customer experience and to improve our Services,
- to share with trusted third-party service providers to help ItchFreeZone perform activities to improve your customer experience, such as statistical analysis, sending you email or postal mail, processing credit card transactions, providing customer support or arranging for deliveries,
- to respond to law enforcement requests and as required by applicable law, court order or governmental regulations,
- to prevent illegal activity, fraud, and abuse, and
- 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 case personal information held by use about our users is among the assets transferred or liquidated.
ItchFreeZone may also contact you via surveys to conduct research or to solicit your opinion on current services or new services that may be offered. We are part of a global company and may share information with our parent and affiliated companies.
ItchFreeZone is not limited in our use of aggregate information that does not permit direct association with any specific individual, such as the number of users of our Services, the geographic distribution of our users, the amount of information located and/or removed, etc. For example, ItchFreeZone may use aggregate information concerning which links and pages users access within an ItchFreeZone website for many reasons including to determine which ItchFreeZone products and services are the most popular. This data may be used to deliver customized content and advertising to customers whose behavior indicates that they are interested in a particular subject area.
2.2 Information Sharing Practices
When we disclose personal information for a Business Purpose, we work with our service providers to ensure that your personal information is processed only as needed to fulfill the Business Purpose. All such third parties are prohibited from using your personal information except to provide these services to ItchFreeZone, and they are required to maintain the confidentiality and privacy of your information.
ItchFreeZone does not sell, rent, or lease your personally identifiable information to third parties. ItchFreeZone may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personally identifiable information would not be transferred to the third party.
2.3 Legal Requirements
ItchFreeZone will disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or to comply with legal process served; (b) protect and defend the rights or property of ItchFreeZone; or (c) act under exigent circumstances to protect the personal safety of users of and ItchFreeZone website or the public.
Additionally, ItchFreeZone may disclose personally identifiable information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
2.4 Organizational Transitions
2.5 Payment Processors
If you purchase or pay for products or services via the Services, the transaction may be handled by our service providers or third party vendor(s) responsible for processing your payment. These entities have their own privacy policies and those terms will apply to you. Please be sure to review them at the links provided during payment processing.
2.6 Disclosures of Personal Information in the Last Twelve Months
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a Business Purpose as further described in Section 2.1 (Business Purposes):
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category D: Commercial information.
- Category F: Internet or other similar network activity.
We disclose your personal information for a Business Purpose to the following categories of third parties:
- Analytics providers.
- Social media.
- Advertisers and other third-party marketing service providers.
- Affiliated persons or third-party service providers assisting us in the operation, management, improvement, research and analysis of the Services.
Please note: Affiliated persons or our third party service providers may augment, extend, and combine non-personally identifiable information with data from additional third party sources in order to assist us in our operation of the Services.
3. SECURITY PROTECTIONS FOR YOUR INFORMATION
ItchFreeZone takes the security of your personal information very seriously. ItchFreeZone uses reasonable administrative, physical, and technical safeguards to secure the personal information you share with us. Despite these safeguards and our additional efforts to secure your information, ItchFreeZone cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third-parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information.
The security of the account you create on any ItchFreeZone website relies on your protection of your user profile information. You are responsible for maintaining the security of your user profile information, including your password and for any and all activities that occur under your account. You may not share your password with anyone. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on an ItchFreeZone website.
Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us immediately by emailing email@example.com. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and report it immediately by emailing firstname.lastname@example.org.
4. YOUR CHOICE AND OPTIONS RELATED TO OUR COLLECTION
4.1 You Can Choose Not to Provide Personal Information
You may always decline to provide your personal information to us. Registering for an account or otherwise providing your personal information is not required to access some of our online content. If you choose not to provide certain personal information to us, some of your experiences may be affected (for example, we cannot complete an order without your billing and shipping information).
4.2 You May Decline Other Requests
4.3 Your Online Tracking Choices
You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website (http://www.networkadvertising.org/choices/) and DAA website (http://www.aboutads.info/choices/).
4.4 You May Unsubscribe from Certain Correspondence
You can opt-out or unsubscribe from receiving e-mail correspondence from ItchFreeZone at any time by contacting email@example.com or by following the instructions contained in any e-mail received. It may take time to process opt-out requests, so it is possible you will receive emails from ItchFreeZone after your opt-out request.
Please remember that even if you opt out of receiving marketing e-mails, we may still send you important service information related to your account and the Services. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses.
4.5 Right to Access Specific Information and Data Portability Right
You may have the right under the CCPA to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information that we have collected about you.
- The categories of sources for the personal information that we have collected about you.
- Our business or commercial purpose for collecting or making available that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information that we have collected about you (also called a data portability request).
- If we disclosed your personal information for a Business Purpose, the Business Purpose for which such personal information was disclosed, and the personal information categories that each category of recipient obtained.
4.6 Right to Delete
You may have the right under the CCPA to request that we delete your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or vendor(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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation or legal order.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
4.7 Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make such a request for access or data portability twice within a twelve-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. 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.
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.
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.
5. CHILDREN’S PRIVACY
ItchFreeZone’s websites are not targeted for use by children under the age of 13. ItchFreeZone does not knowingly collect personal information from children in connection with the features of our websites without the consent of a parent or guardian. ItchFreeZone requests that all visitors under 13 to our websites to not disclose or provide any personally identifiable information. Upon notification that a child under 13 has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records.
5.1 Special Notice for California Residents
6. USERS OUTSIDE THE UNITED STATES
ItchFreeZone is based in the United States, and our website is hosted there. If you are visiting our website from another country, the laws governing our website’s collection and use of personal information may be different from the laws of your country. If you decide to visit our website, or share your personal information with ItchFreeZone, you are agreeing to be governed by the laws of the United States, and you are expressly consenting to the transfer of your data to the United States.
7. CALIFORNIA SHINE THE LIGHT LAW
California Civil Code § 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to firstname.lastname@example.org.
9. CONTACT INFORMATION