Last modified: 06.28.2018
This Policy applies to information we collect on this Site and information obtained by email, text, and other electronic messages between you and this Site.
This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by BeOriginal or any third party.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, including this Policy, your choice is not to use our Site.
This Policy may change from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
1. Release of Information
We do not sell or rent Personally Identifiable Information (as defined in Section 2 of this Policy) collected during your use of our Site without your permission. We do, however, provide some of our services through contractual arrangements with affiliates, services providers, partners, sponsors and other third parties (each a “Service Partner”), and as a result, certain information — including your Personally Identifiable Information— will be transferred to Service Partners in connection with the operation of this Site and/or the delivery of services to you.
We will encourage our Service Partners to adopt and post privacy policies. However, the use of your Personally Identifiable Information by our Service Partners is governed by the privacy policies of those Service Partners, and is not subject to our control.
2. The Information We Collect
We collect several types of information from and about users of our Site, including the information by which you may be personally identified, such as your name, postal address, e-mail address, telephone number, or ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“Personally Identifiable Information”). We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us.
At the time you register on our Site, purchase a BeOriginal membership on our Site or agree to participate in any sweepstakes, contest or other promotion (including those offered by our Service Partner(s)) we may collect and store your name, address, credit card numbers and other Personally Identifiable Information. In addition, we may also collect information from you at other points on our Site that state that such information is being collected. The information we collect may include the following:
(a) Application information—information that you provide to us through our Site and through other means, including but not limited to information that you provide by filling in forms on our Site, information provided at the time you submit material to us, and information provided when you request any other service from us. Examples include your email address, physical address, zip code and phone number.
(b) Transaction and Experience information—information about your transactions with us, as well as information about our communications with you. Examples include your account history, search queries, your requests for information from us and our responses, your responses to our surveys or research questions or other communications, records and copies of your correspondence (including email addresses) and when you report a problem with our Site.
(c) Information from Outside Sources—information from outside sources regarding your credit, background and other relationships. Examples include your employment history and public record information.
We need this information to activate your membership and, to the extent applicable, provide membership benefits and related and/or requested goods and services, and to let you know of additional goods and services about which you might be interested. We may also use this information to customize your experience using our Site and to communicate with you information about upcoming events and services offered by us and by our Service Partners. In addition, we may use this information to operate, maintain and improve our Site and our services generally.
We may also share the information we collect about you with credit card companies, banks, government agencies and other third parties, including our Service Partners. If you obtain goods and/or services provided by one of our Service Partners, we may exchange with the Service Partner Personally Identifiable Information about you regarding such transaction(s).
In addition to Personally Identifiable Information, we automatically gather general statistical information about our Site and visitors, such as IP addresses, browsers, pages viewed, number of visitors, goods and services purchased, etc., but in doing so we do not reference you by individual name, e-mail address, physical address, or telephone number. We use this data in the aggregate to determine how visitors use parts of our Site so we can improve our Site.
We may match user information we collect with offline data available from other sources in order to carry out our services and conduct target advertising and promotions more effectively.
3. Cookies and Other Tracking Technologies
In some instances, our Service Partners and advertisers appearing at our Site may use their own cookies. Preference and options configurations in your browser determine if and how a cookie will be accepted. You can change those configurations on your computer if you desire. By changing your preferences, you can accept all cookies, you can be notified when a cookie is set, or you can reject all cookies. If you do so and cookies are disabled, you may be required to reenter your information more often and certain features of our Site may be unavailable.
Pages of our Site and our e-mails may also contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
4. How We Use Information
We use your information, including Personally Identifiable Information, to improve our marketing and promotional efforts, to statistically analyze Site usage, to improve our content and membership offerings and to customize our Site’s content, layout, and services. We may use information that we collect about you or that you provide to us, including any Personally Identifiable Information, to present our Site and its contents to you, to provide you with information, products, or services that you request from us, and to fulfill any other purpose for which you provide it. We may also use your information to provide you with notices about your membership, including expiration and renewal notices, 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 changes to our Site or any products or services we offer or provide though it, to allow you to participate in interactive features on our Site, and in any other way we may describe when you provide the information.
We may use and/or disclose your information, including Personally Identifiable Information, with those who need it to do work for us, including but not limited to third party banking, processing agents and distribution institutions who receive the information needed to verify and authorize your credit card or other payment information as necessary to process your transactions. We may use and/or disclose such information to resolve disputes, investigate problems, or enforce any agreement that we may have with you. We may use and/or disclose or access your information whenever we believe in good faith that the law so requires or if we otherwise consider it necessary to do so to maintain service and improve our products and services.
We may use your information, including Personally Identifiable Information, to deliver content to you that, in some cases, is targeted to your interests, such as targeted banners, new services and promotions. You can opt out of receiving this content by telling us when you give us your Personally Identifiable Information or at any time by sending an email to email@example.com to notify us that you no longer wish to receive such content.
We may use your information, including Personally Identifiable Information, to contact you regarding administrative notices, new membership offerings, surveys, and communications relevant to your use of the Site. You can opt out of receiving this information by telling us when you give us your Personally Identifiable Information or at any time by sending an email to firstname.lastname@example.org to notify us that you no longer wish to receive such information.
We may use your information, including Personally Identifiable Information, to contact you regarding contests, sweepstakes and other promotional offers from selected third parties. You can opt out of receiving this content by telling us when you give us your Personally Identifiable Information or at any time by sending an email to email@example.com to notify us that you no longer wish to receive such content. If, after receiving information regarding offers from selected third parties, you do not opt out to receive information from them, we may share your information with the applicable third parties.
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act and thus will not distribute your Personally Identifiable Information to outside parties without your consent or as specifically described above.
We employ reasonable and current security methods to prevent unauthorized access, maintain data accuracy, and ensure correct use of your information. Your Personally Identifiable Information is protected in several ways. Please be aware, however, whenever you voluntarily disclose personal information online—for example on message boards, through e-mail or in chat areas—that information can be collected and used by others. No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.
6. How You Can Update, Correct or Delete Your information
You can access the information that we collect online and maintain through normal updating methods. To update, correct or delete this information, you can contact us by email at the following address:
Be Original Americas, Inc.
Attn: Privacy Compliance Officer
665 Broadway, Suite 704
You may also contact us by e-mail at firstname.lastname@example.org.
Please include your name, address, and e-mail address when you contact us.
We encourage you to promptly update your Personally Identifiable Information if it changes. Also, please note that it may be impossible to completely delete your information without some residual information because of backups.
7. Children Under 13
You must be at least 13 years old to have our permission to use this Site. Our Policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 13 years of age.
We have no way of distinguishing the age of individuals who access our Site, and so we carry out the same policy for individuals of all ages. If a child has provided us with Personally Identifiable Information without parental or guardian consent, the parent or guardian should contact us at the address provided in Section 6 above to remove the information and to opt out of promotional opportunities.
8. Third Party Privacy Practice
If you have any questions about this Policy, the practices of this Site, or your dealings with this Site, please contact us by sending a letter to:
Be Original Americas, Inc.
Attn: Privacy Compliance Officer
665 Broadway, Suite 704
You may also contact us by e-mail at email@example.com.
11. Notice of Compliance to California Residents
California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (“CalOPPA”) and the California Business and Professions Code. As required by CalOPPA, this Policy identifies the categories of Personally Identifiable Information that we collect through the Site about individual consumers who use or visit the Site and the categories of third-party persons or entities with whom such Personally Identifiable Information may be shared. Depending on your activity at the Site, certain “personally identifiable information” (as that term is defined in the CalOPPA) may be collected, in addition to information set forth in other sections of this Policy. For purposes of CalOPPA, the term “personally identifiable information” means individually identifiable information about an individual consumer collected online by us from an individual and maintained by us in an accessible form, and may include any of the following:
(1) A first and last name;
(2) A home or other physical address, including street name and name of a city or town;
(3) An email address;
(4) A telephone number;
(5) A social security number;
(6) Any other identifier that permits the physical or online contacting of a specific individual;
(7) Information concerning a user that the Site collects online from the user, and maintains in personally identifiable form, in combination with an identifier described within this Policy.
See Section 6 of this Policy for a description of the process maintained by us for how to review and request changes to any of your Personally Identifiable Information that is collected through the Site.
12. California Shine the Light Law Compliance Statement
Under California S.B. 27 (“Shine the Light Law”), California residents have the right under certain circumstances to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of “personally identifiable information” shared. To make such a request, please send an email to firstname.lastname@example.org and please include the phrase “California Privacy Request” in the subject line, the domain name of the website that you are inquiring about, along with your name, address and email address. We will respond to you within thirty (30) days of receiving such a request.