If you are a resident of the State of California, you should consult the sections of this policy pertaining to the “California Privacy Rights” including rights under the California Consumer Privacy Act (“CCPA”), which came into effect on January 1, 2020.
1- Information We Collect
“Personal Information” is information that may be used to directly or indirectly identify an individual (which in some cases, may include certain device information). The Personal Information we collect may include: names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol (IP) address, telephone numbers, email addresses or other similar identifiers. We may combine the Personal Information that we obtain about individuals from more than one source.
The Personal Information we collect about users is provided to us by the individuals themselves. We collect and process Personal Information about individuals to (i) provide information about us and our Services and Products; (ii) provide answers to inquiries, questions and feedback; (iii) maintain regular communication with users to inform them of updates and other information regarding us and our Services and Products; (iv) verify the identity of our users; (v) open, maintain, administer and service users’ accounts, including rewards programs; (vi) provide our Services, including processing transactions for our Products; (vii) improve our Site; and (viii) fulfill our legal and professional obligations.
We collect Device Information using the following technologies:
“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
3 - How Do We Use Your Personal Information?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to, communicate with you, screen our orders for potential risk or fraud and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
Sharing you personal Information
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising anytime at the links below.
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info.
Do not track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information with the subject “GDPR Data Request”.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
The Site is not intended for individuals under the age of 18 unless with parent or guardians permission.
2- Notifications and Communications from The Präna Company
We may send you email notifications from time to time. Some notifications are marketing communications relating to us and our Services or Products, including our referral program. You may always stop receiving marketing communications from us by following the “Unsubscribe” link provided on the bottom of an email or contacting us at firstname.lastname@example.org.
Legal or Security Communications
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection. In other cases, these notifications involve changes to various legal agreements or policies. Generally, you may not opt out of such emails. We may also send out communications for verification purposes to comply with the CCPA.
We may also send you responses to emails you send us, if appropriate.
3 - Your Rights
Opting Out of Communications
As described above, we may use the Personal Information we collect from you to send you via e-mail newsletters or other communications from us, including those promotional in nature. If you do not want to receive such communications, you can opt out by using the unsubscribe link at the bottom of our communications. You may also at any time opt out of receiving communications from us by sending an e-mail to email@example.com with the subject line “Opt Out.”
California Privacy Rights
The following section pertains to the rights of individuals or households in California (“California consumers”).
Civil Code Section 1798.83
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give you a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
Rights under the CCPA
As of January 1, 2020, the CCPA (California Civil Code Section 1798.100 et seq.) provides California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of Personal Information are generally described above but differ for individual consumers depending on the Services used by such consumers.
Under the CCPA, qualifying California consumers may have the following rights:
Right to Know and Right to Delete.
A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.
When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 business days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.
Our obligation to delete Personal Information is not required regarding information necessary, among other things: (1) to provide our Services or Products; (2) to detect and resolve issues related to security or functionality; (3) to comply with legal obligations, including our responsibilities and obligations, and privileges; (4) to exercise free speech or to ensure another’s exercise of free speech; or (5) for internal purposes that a consumer might expect.
Right for Disclosure of Information.
A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect.
Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers. Our obligations to disclose information are also subject to legal restrictions placed on us, including our duty to protect information from disclosure, or restrictions placed by legal or court authority.
4 - Submitting Requests
If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows:
Mailing Address: The Präna Company 500 W Colorado St, Unit C, Suite 387 Glendale, CA 91204
E-mail Address: firstname.lastname@example.org
If we receive any request we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or email.
In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, e-mail address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than outline above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.
California Do Not Track Disclosures
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
We limit access to the Personal Information we have you to those employees who have a legitimate business need to access such information. We take commercially reasonable steps to protect your Personal Information against unauthorized disclosure or loss. However, no data transmission over the Internet or any security measures can be guaranteed to be 100% secure.
Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us. You engage in such transmissions at your risk. If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at email@example.com. YOUR responsibilities we ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at firstname.lastname@example.org.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at email@example.com or by mail to 500 W Colorado St, Unit C, Suite 387, Glendale, CA 91204.
EFFECTIVE DATE: January 1, 2021