Privacy Policy

Adam’s Polishes Privacy Policy

Effective Date: February 26th, 2020

Adam’s Polishes and its affiliates (“Adam’s” or “we,” “us,” or “our”) is committed to privacy and will only use information that identifies, relates to, describes, references is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“Personal Information”) in accordance with the terms of this Privacy Policy (“Policy”).

This Policy describes how we collect, use, protect and disclose Personal Information we obtain when you use the websites that Adam’s owns or controls (today or in the future), including, https://adamspolishes.com, as well as related websites, including out subdomains (collectively, the “Sites”), when you provide us Personal Information either online or offline, when you purchase products from us, or when you use any services that we offer through the Sites, in store or offline (all of the foregoing are collectively referred to in this Policy as “Services”). You can access the Sites in many ways, including from a computer or mobile phone, and this Policy will apply regardless of the means of access. This Policy also governs the use of Personal Information we obtain from you from any third party. Adam’s cannot control the privacy policies or practices of sites or of companies that we do not own or control and cannot control the actions of people we do not employ or manage.

Please read this Policy carefully. This Policy is a legally binding contract between us and anyone who accesses or uses any of the Services. This Policy is incorporated into and is subject to our Terms of Use for the Sites. In the event of a conflict between this Policy and our Terms of Use, the Terms of Use will control. If you have any questions about this Policy, please contact us through the contact information available on our Contact page. If you do not want us to collect, use or share your Personal Information in the ways described in this Policy, please do not use the Services. By using the Services, you consent to the collection and use of your information (including your Personal Information) by us as identified in this Policy.

Personal Information We Collect

The information we learn from and about our customers helps us to personalize and continually improve your experience with us. This section describes what Personal Data we collect and the different ways we collect it. Please note, Personal Information does not include information that is publicly available information from government records or deidentified or aggregated consumer information. Generally, in the past 12 months, we have collected the following categories of Personal Information:

Category	Examples	Collected?
Identifiers	A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, current or past job history, or other similar identifiers.	YES
Personal information categories covered by certain laws (including the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport 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.	YES
Protected classification characteristics under certain laws.	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
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies	YES
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
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.	YES
Geolocation data.	Physical location or movements.	YES
Sensory data	Audio, electronic, visual, thermal, olfactory or similar information.	NO
Professional or employment-related information	Current or past job history or performance evaluations.	YES
Non-public education information (per the Family Education 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
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	NO

More specifically, we may collect the following Personal Information from or about you:

Information we Collect From You

In order to use some of our Services, we ask you to provide certain Personal Information and in some cases require you to register for an account. Where applicable, we indicate whether you must provide us with your Personal Information in order to use the Services you want to use. If you do not provide the Personal Information, you may not be able to benefit from our Services if that information is necessary to provide you with the applicable Services or we are legally required to collect it.

When you register for an account, we will collect the Personal Information you provide, such as your name, contact information (including mailing and billing addresses), email address, mobile phone number, date of birth, phone number, username and password.

When you make a purchase from us, we will ask you to provide your credit or debit card number or other financial account number. This information is collected and processed by a third party on our behalf. Please see the section titled “Collection/Processing of Payment Card Information” for more details. We may also collect and maintain information about your transaction history.

Personal Information Collected from Third Parties

We may receive your Personal Information from our affiliated companies and other third parties such as social media sites, ad networks and analytics providers.

We may also receive your Personal Information from others that refer you to our Services.

Personal Information Automatically Collected

When you use our Sites, our servers automatically record information that your browser or device sends whenever you visit a website or utilize an application. This information may include your IP address, the type of device you are using, the internet service provider or mobile carrier you are using, your device identifiers, your mobile telephone number, your geographic location and your activities within the Services, including the links you click, the pages or screens you view, your session time, the number of times you click a page/screen or use a feature of the Services, the date and time you click on a page or use a feature and the amount of time you spend on a page or using a feature.

Like many websites, our Sites also use “cookie” technology to collect additional website usage data and to improve the Sites and our Services. A cookie is a small data file that we transfer to your computer’s hard disk. A session cookie enables certain features of the Sites and is deleted from your computer when you disconnect from or leave the Sites. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Sites. We may use both session and persistent cookies to better understand how you interact with our Sites, to monitor aggregate usage by our uses and web traffic routing on out Sites, and to improve our Sites and Services. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all of the services or functionalities of the Sites. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.

We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or after you visit our Sites, the pages or other content you view or otherwise interact with on our Sites and the dates and times that you visit, access or use our Sites. We may also use these technologies to collection information regarding your interaction with email messages, such as whether you opened, clicked on or forwarded a message, to the extent permitted under applicable law.

Our Sites use Google Analytics (and in the future may use other similar services), a web analytics service provided by Google, Inc. (“Google”), to better assist us in understanding how the Sites are used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Sites, including your computer’s IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating customer use of the Sites, compiling reports on Site activity for our use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of these cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Sites. The use of cookies by Google Analytics is covered by Google’s privacy policy. From time to time, we may enter into agreements with other third party providers for web analytic and other similar services. If we enter into such an agreement, we may share your information, including your Personal Information, with the provider or such provider may have access to and collect your information on our behalf. Your information, including Personal Information, may be stored with the provider.

Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

Information Collected by Third Parties

We may display third-party content on the Sites, including third-party advertising. Third-party content may use cookies, web beacons or other mechanisms for obtaining data in connection with your viewing of the third-party content on our Sites. Additionally, we may implement third-party buttons, such as Facebook “share” buttons, that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by Adam’s. Please consult such third party’s data collection, use and disclosure policies for more information.

Our Sites may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer or mobile device, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third party sites or services to which links or access are provided through our Sites. We encourage you to read the privacy policies or statements of the other websites you visit.

How We Use the Personal Information We Collect

We may use your Personal Information for various purposes, including, but not limited to, the following:

Non-Marketing Purposes

We may use the information we collect for non-marketing purposes including (1) validating your identity; (2) sending you push notifications or e-mails to provide you with alerts and updates about your account and the Services; (3) processing your transactions; (4) conducting statistical or demographic analysis; (5) complying with legal and regulatory requirements; (6) customizing your experience with the Services; (7) protecting and defending Adam’s and its affiliates against legal actions or claims; (8) preventing fraud; (9) debt collection; (10) satisfying contractual obligations; (11) cooperating with law enforcement or other government agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; and (12) for other business purposes permitted under applicable law (collectively, “Non-Marketing Purposes”).

Marketing Purposes

We may use the Personal Information we collect for our own marketing purposes including notifying you of special promotions, offers and events via push notifications, email and other means, subject to compliance with applicable laws. We may also link Personal Information (including your name, mobile phone number, and email address) with non-personal information (including Personal Information automatically collected as described in this Policy) and use such information for our own marketing purposes. If you do not want to use your Personal Information for marketing purposes, you may opt-out in accordance with the procedures described in the “Managing Your Personal Information” section below.

Other Purposes

We may also use information in the aggregate to understand how our users as a group use the Services. Adam’s will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated or incompatible purposes without providing you notice.

Who We Share Personal Information With

For business purposes, we may share certain Personal Information we receive from and about you, and about your transactions with us, with our affiliates and certain third parties. Doing so allows us to provide the Services you request. This section describes the types of third parties we may share your Personal Information with and the purposes for that sharing. Generally, in the past 12 months, we have disclosed the following categories Personal Information to third parties for business purposes:

Category	Disclosed?
Identifiers	YES
Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))	YES
Protected classification characteristics under California or federal law.	YES
Commercial information	YES
Biometric information	NO
Internet or other similar network activity	YES
Geolocation data.	YES
Sensory data	NO
Professional or employment-related information	YES
Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	NO
Inferences drawn from other personal information.	NO

Third Party Service Providers

Your Personal Information may be shared with or collected by third party service providers who provide us with services, including, but not limited to, shipping products, data hosting or processing, credit card processing, or processing or fulfilling transactions. We require these third party service providers to exercise reasonable care to protect your Personal Information and restrict their use of your Personal Information to the purposes for which it was provided to them.

Third Party Marketing Partners

We may share certain limited Personal Information with other companies with whom we have joint marketing or similar agreements, or other businesses with whom we have a contractual relationship (“Joint Marketing Partners”) who may contact you with marketing and promotional offers. If you would like us to stop providing your information to these Joint Marketing Partners, you may opt-out in accordance with the procedures described in the “Managing Your Personal Information” section below.

Anonymous Information

We may provide anonymized information to third parties. Any anonymized information we provide to third parties is not considered Personal Information and is not subject to the terms of this Policy.

Sale of our Business; Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us. We reserve the right, in connection with these types of transactions, to transfer or assign your information and other information we have collected from our customers to third parties or to authorize third parties to use any such information retained by us. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Compliance with Laws and Law Enforcement

Adam’s cooperates with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect the property and rights of Adam’s or a third party, to protect Adam’s against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Services and any equipment used to make the Services available, or to comply with applicable law.

Selling Personal Information

We do not sell your Personal Information and have not done so in the past 12 months.

Collection/Processing of Payment Card Information

If you use our Services to purchase products or otherwise engage in any transaction involving payment, you may be asked to provide payment information, including, but not limited to, payment card information. We will not ask you, and you are not permitted, to provide any payment card information via email, text or other electronic means (excluding through the dedicated forms on the Sites). Any payment card information you properly provide to us is used exclusively to process payments for products you receive from us. All payment card transactions are processed by our credit card servicing company, Shopify, Inc.. Shopify directly collects and processes any payment card transaction information you enter on the Sites. We transmit any payment card information you provide us over the phone or through the mail to Shopify for processing through a secure site. Under no circumstances do we collect or keep payment card information on our servers. For more information about Shopify’s privacy practices, please see Shopify’s privacy policy, available at https://www.shopify.com/legal/privacy.

Managing Your Personal Information

You may decline to share certain information with us, in which case, we may not be able to provide you some of the Services we offer. To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Email Opt-Out

From time to time (and with your consent when required), you may receive periodic mailings or emails from us with news or other information on events, products, services, discounts, special promotions, upcoming events or other offers from us or on our behalf. If at any time you wish to stop receiving emails or mailings from us please contact us through the contact information available on our Contact page and we will remove you from our mailing list. If you send us an email, include the phrase “Privacy Opt-Out: Adam’s Polishes Marketing Emails” in the subject line.

Alternatively, for email communications, you may opt out of receiving such communications by following the unsubscribe instructions set forth in our marketing emails. Your unsubscribe request or email preferences change will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing emails from us.

Marketing/Joint Marketing Opt-Out

If you wish to opt-out of receiving solicitations from us, or do not want us to share your Personal Information with our affiliates or partners for marketing purposes, you contact us through the contact information available on our Contact page.

Behavioral Advertising Opt-Out

If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your Personal Information. To do so please visit the NAI Opt-Out Page: http://www.networkadvertising.org/choices. Please note that even if you choose to remove your information (opt out), you will still see advertisements while you are browsing online. However, the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Security

We are committed to protecting the security of the Personal Information you provide to us and that we collect about you. We maintain commercially reasonable safeguards to maintain the security and privacy of personal information that you provide to us. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the internet. Your information may be intercepted without our consent, collected illegally and used by others without your consent. We cannot guarantee the security of any information you disclose online, and you do so at your own risk.

Underage Persons

The Services are for use by persons who are at least 18 years of age. If you are younger than 18, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of Personal Information from persons under the age of 13. If we learn that we have collected the Personal Information of someone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information, you may contact us through the contact information available on our Contact page and ask us to remove your child’s Personal Information from our systems.

Notice to Individuals in Europe

Adam’s Services are not intended for individuals located in Europe. If you are located in Europe, please do not provide us with any Personal Information.

California Privacy Rights

If you are a California resident, you have certain rights regarding your Personal Information under California’s Shine the Light Law and the California Consumer Privacy Act (“CCPA”). This section describes your rights under those laws.

Rights Under California’s Shine the Light Law

Under California’s Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California’s Shine the Light Law, you have the right to send us a request at the designated email address listed below to receive the following information:

the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
the names and addresses of the third parties that received the information; and
if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized form that is not specific to you. The designated email address for these requests is orders@adamspolishes.com.

Rights Under CCPA

Please note, the rights described in this section only applies to Personal Information covered by the CCPA. Among other types of Personal Information, the CCPA does not cover information that is publicly available from government records, deidentified or aggregated consumer information, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Access Requests. Under the CCPA, you have the right to request that Adam’s disclose certain information to you about our collection and use of Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (information on how to submit requests is provided below), we will disclose to you, based on what you request:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business and/or commercial purposes for collecting or selling that Personal Information.
The categories of third parties with whom we shared that Personal Information.
The specific pieces of Personal Information we collected about you (also known as a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (1) sales, identifying the Personal Information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Requests. Under the CCPA, you have the right to request that Adam’s delete any of your Personal Information that we collected from or about you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (information on how to submit requests is provided below), 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 services providers to:

Complete the transaction for which we collected the Personal Information, provide a good or service 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.).
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.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
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.

How to Submit a Request. To submit an access, data portability or deletion request, please submit a verifiable consumer request to us by either:

Calling us at 866-965-0400; or
Emailing us at orders@adamspolishes.com.

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 information request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

When submitting a verifiable consumer request you must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person; and
Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your requests 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. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Responses to Requests. We attempt to respond to verifiable consumer requests within 45 days. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.

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 prior to the date we receive the verifiable consumer request. The response we provide will also provide 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.

Rights Regarding the Sale of Personal Information. At this time, Adam’s does not sell any Personal Information. The CCPA does grant consumers rights with respect to the sale of their Personal Information, and if we decide to sell Personal Information in the future we will update this Privacy Policy and our Sites to make those rights available to you.

Non-Discrimination for Submitting Requests. We will not discriminate against you for exercising any of your rights under the CCPA. 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.

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 contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Changes to this Policy

We may revise this Policy from time to time in our sole discretion. We will notify you of any material revisions by placing notice of the revised Policy on our website or any place through which you access the Services. Your continued access or use of the Services following any amendments to the Policy constitutes your acceptance of the Policy as amended. It is your sole responsibility to monitor our website for changes to the Policy.

Contact Us

If you would like to update or correct your information or modify your communication preferences, or if you have questions regarding this Policy or our use of Personal Information, please contact us through the contact information available on our Contact page.