Our Policies

Policies

Privacy Policy

Effective as of March 3, 2022.

This Privacy Policy describes how Natals, Inc. (“Ritual”, “we”, “us” or “our”) handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website https://ritual.com (“Site”), as well as through social media, our marketing activities, our live events, and other activities described in this Privacy Policy (collectively, the “Services”).

UNITED KINGDOM USERS: Please see the Notice to UK users section below for additional information for individuals located in the United Kingdom (“UK”).

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Services includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
  • Profile data, such as the username and password that you may set to establish an online account on the Site, and any other information that you add to your account profile.
  • Pregnancy status data, such as whether you are trying, not trying, expecting or just had a baby.
  • Communications data, based on our exchanges with you, including when you contact us through the Site, social media, or otherwise.
  • Transactional data, such as information relating to or needed to complete your orders on or through the Site, including order numbers and transaction history.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Payment data needed to complete transactions, including payment card information or bank account number.
  • Promotion data, including information you share when you enter a competition, promotion, or complete a survey. Please note that if you participate in a sweepstakes, contest, or giveaway through the Service, we may ask you for your contact data to notify you if you win, to verify your identity, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
  • Private sources, such as data providers, social media platforms, and data licensors.
  • Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
  • Marketing partners, such as joint marketing partners and event co-sponsors.
  • Third-party services (such as Apple or Google) that you use to log into, or otherwise link to, your Ritual account. This data may include your username, profile picture, and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Site, our communications, and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Site, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will store a record of your preferences with respect to the use of those technologies in connection with the Site.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

How we use your personal information

We may use your personal information for the following purposes:

Service delivery, which may include using your personal information to:

  • provide and operate the Service

  • establish and maintain your Ritual user profile

  • remember devices from which you have previously logged in

  • discern whether you are logged in when you visit password-protected areas of the Site

  • provide support for the Service, and respond to your requests, questions, and feedback

  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages

  • Categories of personal information involved

    • Contact data
    • Profile data
    • Communications data
    • Transactional data
    • Payment data

Security, which may include using your personal information to:

  • enable security features of the Service, such as by sending you security codes via email or SMS

  • remember devices from which you have previously logged in

  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages

  • Categories of personal information involved

    • Contact data
    • Device data
    • Online activity data

Service personalization, which may include using your personal information to:

  • understand your needs and interests

  • personalize your experience with the Service and our Service-related communications

  • remember your selections and preferences as you navigate the Site

  • Categories of personal information involved

    • Contact data
    • Profile data
    • Pregnancy status data
    • Device data
    • Online activity data

Direct marketing, which may include using your personal information to:

  • send you direct marketing communications (you may opt-out of our marketing communications as described in the Opt-out of marketing section below)

  • personalize our marketing communications according to your needs and interests

  • monitor your interaction with our communications (such as whether you opened them)

  • facilitate your invitations to friends who you want to invite to join the Service

  • Categories of personal information involved

    • Contact data
    • Profile data
    • Communications data
    • Transactional data
    • Marketing data

Interest-based advertising, which may include using your personal information to:

  • share aggregated, de-identified, or otherwise anonymized data with third parties, including to promote our business through interest-based advertising on third party channels

  • share information about our users with our third-party advertising partners to facilitate interest-based advertising to those or similar users on other online platforms

  • allow our third-party advertising partners to collect information about your interaction with the Site, our communications, and other online services over time and use that information to serve online ads that they think will interest you

  • Categories of personal information involved

    • Contact data
    • Device data
    • Online activity data

Promotions and contests, which may include using your personal information to:

  • administer promotions and contests

  • communicate with you about promotions or contests in which you participate

  • Categories of personal information involved

    • Promotion data
    • Contact data
    • Profile Data
    • Communications data

Service analytics, which may include using your personal information to:

  • analyze your usage of the Service in an aggregated, de-identified, and/or anonymized form
  • improve the Service
  • improve the rest of our business
  • help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails

For more information, see our Cookie Notice.

  • Categories of personal information involved
    • Device data
    • Online activity data

Compliance with law and co-operation with authorities, which may include using your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities

  • audit our internal processes for compliance with legal and contractual requirements or our internal policies

  • prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft

  • cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to other users, including suspected fraud, or situations involving potential threats to the physical safety of any person

  • Categories of personal information involved

    • Any and all data types relevant in the circumstances

Protection and enforcement of rights, which may include using your personal information to:

  • protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims)

  • enforce the terms and conditions that govern the Service and/or Site

  • prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft

  • Categories of personal information involved

    • Any and all data types relevant in the circumstances

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information below.

  • Categories of personal information involved
    • Any and all data types relevant in the circumstances

To create aggregated, de-identified and/or anonymized data from your personal information by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

  • Categories of personal information involved
    • Any and all data types relevant in the circumstances

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent.

  • Categories of personal information involved
    • Any and all data types relevant in the circumstances

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for their use consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe or Paypal, who may use your payment data in accordance with their privacy policies. Their privacy policies may be found at https://stripe.com/privacy (for Stripe) and https://www.paypal.com/us/webapps/mpp/ua/privacy-full (for Paypal).

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Parties to corporate events. We may disclose personal information in the context of actual or prospective corporate events (e.g., investments in Ritual, financing of Ritual, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Ritual as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in California, and the United Kingdom can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Site, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Notice.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in the UK should read the important information provided below about transfer of personal information outside of the UK.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

California privacy rights notice

This section describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected
    • The categories of sources from which we collected Personal Information
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with which we share Personal Information
    • The categories of Personal Information that we sold or disclosed for a business purpose
    • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose
  • Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion. You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales. You can opt-out of any sale of your Personal Information.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to information, access, and deletion. You may submit requests to exercise your right to information, access, or deletion by submitting these requests online using our privacy request form, or by emailing us at [email protected].

Notice of right to opt-out of the “sale” of your Personal Information. Like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the advertising partners that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information by visiting the "Do Not Sell My Personal Information" link at the bottom of this webpage.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury or other information.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use, and disclose. The list below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code § 1798.140), and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. The terms in the list refer to the categories of information, sources, purposes and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Statutory category: Identifiers (online)

  • Personal Information (“PI”) we collect in this category:
    • Contact data
    • Profile data
    • Data about others
  • Source of PI:
    • You
    • Third-party sources
  • Business/commercial purpose for PI collection:
    • Service delivery
    • Marketing & advertising
    • Compliance & protection
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • Affiliates
    • Service providers
    • Payment processors
    • Advertising partners
    • Third parties designated by you
    • Professional advisors
    • Authorities and others
    • Business transferees
    • Business and marketing partners
  • Categories of third parties to whom we “sell” PI:
    • Advertising partners (to facilitate online advertising)
    • Business and marketing partners

Statutory category: Identifiers (other)

  • Personal Information (“PI”) we collect in this category:
    • Profile data
    • Device data
  • Source of PI:
    • You
    • Third-party sources
    • Automatic collection
  • Business/commercial purpose for PI collection:
    • Service delivery
    • Marketing & advertising
    • Compliance & protection
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • Affiliates
    • Service providers
    • Payment processors
    • Advertising partners
    • Third parties designated by you
    • Professional advisors
    • Authorities and others
    • Business transferees
    • Business and marketing partners
  • Categories of third parties to whom we “sell” PI:
    • Advertising partners (to facilitate online advertising)
    • Business and marketing partners

Statutory category: California Customer Records (as defined in California Civil Code §1798.80)

  • Personal Information (“PI”) we collect in this category:
    • Contact data
    • Transactional data
    • Data about others
  • Source of PI:
    • You
    • Third-party sources
  • Business/commercial purpose for PI collection:
    • Service delivery
    • Marketing & advertising
    • Compliance & protection
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • Affiliates
    • Service providers
    • Payment processors
    • Advertising partners
    • Third parties designated by you
    • Professional advisors
    • Authorities and others
    • Business transferees
    • Business and marketing partners
  • Categories of third parties to whom we “sell” PI:
    • Advertising partners (to facilitate online advertising)
    • Business and marketing partners

Statutory category: Commercial information

  • Personal Information (“PI”) we collect in this category:
    • Transactional data
    • Marketing data
    • Online activity data
  • Source of PI:
    • You
    • Third-party sources
    • Automatic collection
  • Business/commercial purpose for PI collection:
    • Service delivery
    • Marketing & advertising
    • Compliance & protection
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • Affiliates
    • Service providers
    • Payment processors
    • Advertising partners
    • Third parties designated by you
    • Professional advisors
    • Authorities and others
    • Business transferees
    • Business and marketing partners
  • Categories of third parties to whom we “sell” PI:
    • Advertising partners (to facilitate online advertising)
    • Business and marketing partners

Statutory category: Financial Information

  • Personal Information (“PI”) we collect in this category:
    • Transactional data
    • Payment data
  • Source of PI:
    • You
    • Third -party sources
  • Business/commercial purpose for PI collection:
    • Service delivery
    • Marketing & advertising
    • Compliance & protection
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • Affiliates
    • Payment processors
    • Professional advisors
    • Authorities and others
    • Business transferees
  • Categories of third parties to whom we “sell” PI:
    • None

Statutory category: Internet or Network Information

  • Personal Information (“PI”) we collect in this category:
    • Marketing data
    • Device data
      • Online activity data
  • Source of PI:
    • Automatic collection
  • Business/commercial purpose for PI collection:
    • Service delivery
    • Marketing & advertising
    • Compliance & protection
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • Affiliates
    • Service providers
    • Payment processors
    • Advertising partners
    • Third parties designated by you
    • Professional advisors
    • Authorities and others
    • Business transferees
    • Business and marketing partners
  • Categories of third parties to whom we “sell” PI:
    • Advertising partners (to facilitate online advertising)
    • Business and marketing partners

Statutory category: Inferences

  • May be derived from:
    • Contact data
    • Profile data
    • Transactional data
    • Marketing data
    • Device data
    • Online activity data
  • Source of PI:
    • N/A
  • Business/commercial purpose for PI collection:
    • Service delivery
    • Marketing & advertising
    • Compliance & protection
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • Affiliates
    • Service providers
    • Advertising partners
    • Authorities and others
    • Business transferees
    • Business and marketing partners
  • Categories of third parties to whom we “sell” PI:
    • Advertising partners (to facilitate online advertising)
    • Business and marketing partners

Statutory category: Protected Classification Characteristics

  • We do not intentionally collect this information, but it may be revealed in identity data or other information we collect.
  • Source of PI:
    • N/A
  • Business/commercial purpose for PI collection:
    • N/A
  • Categories of third parties to whom we “disclose” PI for a business purpose:
    • N/A
  • Categories of third parties to whom we “sell” PI:
    • N/A

Your California privacy rights. California residents may send us requests to [email protected]tual.com for identification of third parties to whom we have disclosed your personal information during the preceding calendar year for such third parties’ direct-marketing purposes. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Notice to UK users

The information provided in this Notice to UK users applies only to individuals in the UK.

Controller. Natals, Inc. (d/b/a Ritual) is the controller in respect of the processing of your personal information covered by this Privacy Policy for the purposes of the so-called “UK GDPR” (i.e., the General Data Protection Regulation (EU) 2016/679 as it forms part of UK law post-Brexit). See the Contact Us section above for contact details.

Our UK GDPR Representatives. Our representative in the UK appointed under the UK GDPR is:
Email: [email protected]
Post: GDPR Local Ltd
1st Floor Front Suite 27-29
North Street, Brighton England BN1 1EB

Personal Data.

  • For UK users, references to your “personal information” in this Privacy Policy should be understood to include a reference to your “personal data” (as defined in the UK GDPR).
  • So, what is “personal data”? – essentially, personal data is information about an individual, from which that individual is either directly identified or can be identified.
  • It does not include ‘anonymous data’ (i.e., information where the identity of the relevant individual has been permanently removed and that individual is no longer identified or identifiable).

Legal bases for processing. In respect of each of the purposes for which we use your personal information, the UK GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the list below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).

In addition, for any special categories of personal data we process (e.g., data related to your health, such as pregnancy status data), we also have to establish a condition to processing such data, because it is considered to be more sensitive in nature – for example, we may look to obtain your explicit consent to the Processing of those special categories of personal data for one or more specified purposes (“Explicit Consent”).
We have set out below, in a list format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes, what they cover, and the data types involved, see How we use your personal information.

Purpose: Service delivery

  • Contractual Necessity

Purpose: Security

  • Compliance with Law
  • Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Site, our Services and associated IT services, systems and networks.

Purpose: Service personalization

  • Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalized to you and that remembers your selections and preferences.
  • Consent, in respect of any optional cookies used for this purpose
  • For any special categories of personal data (e.g., data related to your health, such as pregnancy status data): Explicit Consent

Purpose: Direct marketing

  • Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.
  • Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications
  • For any special categories of personal data (e.g., data related to your health, such as pregnancy status data): Explicit Consent

Purpose: Interest-based advertising

  • Consent
  • Legitimate Interests. We have a legitimate interest in personalizing the advertisements served to you and evaluating the use of our website.

Purpose: Promotions and contests

  • Contractual Necessity to administer the promotions and contests in accordance with the terms or rules thereof (including communicating with you as and where necessary)
  • In respect of promoting these promotions and contests:
  • Legitimate Interests. We have a legitimate interest in promoting these promotions and contests, including associated publicising of our business and operations.
  • Consent – in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given promotional communications.

Purpose: Service analytics

  • Consent

Purpose: Data sharing in the context of corporate events

  • Legitimate interest. We and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate.

Purpose: Compliance with law and co-operation with authorities

  • Compliance with Law.
  • Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting and following legal process and requests, including through co operation with authorities.
  • For any special categories of personal data (e.g., data related to your health, such as pregnancy status data): The processing is necessary for the establishment, exercise or defense of legal claims.

Purpose: Protection and enforcement of rights

  • Compliance with Law.
  • Legitimate interest. We and any relevant third parties have a legitimate interest of ensuring the protection, maintenance and enforcement of our and their rights, property, and/or safety.
  • For any special categories of personal data (e.g., data related to your health, such as pregnancy status data): The processing is necessary for the establishment, exercise or defense of legal claims.

Purpose: To create aggregated, de-identified and/or anonymized data

  • Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Services and how we use Personal Information is as un-privacy intrusive as possible.

Purpose: Further uses

  • The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.
  • Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Special Categories of Personal Data. As noted above, you may choose to provide us with your pregnancy status data. We will only collect such data where you have provided us with your explicit consent to its use for the specific purpose of personalizing your experience. If you do not want us to process your pregnancy-status data, you can always choose not to do so by selecting ‘Prefer not to say’.
We will not use your personal information (whether it is directly special category personal data or not) to create inferences or to otherwise reveal information concerning your health / health conditions, your genetic information, your racial or ethnic origin, your sex life or sexual orientation or any other special category(ies) of personal data without your explicit consent. If you do not provide your explicit consent, we will not carry out any Processing that is designed or intended to treat you differently on the basis of a possible inference or ‘educated guess’ that we could theoretically make about, or that could deduce, these types of special categories (e.g., from your purchase history).

Retention
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights
The UK GDPR gives you certain rights regarding your personal information in certain circumstances. If you are located in the UK, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
  • Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
  • Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
  • Consent withdrawal. Where we rely on your consent and/or explicit consent to process your personal information you may withdraw that consent at any time.

You may submit these requests online using our privacy request form, or by emailing us at [email protected]. We may request specific information from you to help us confirm your identity and process your request.
Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the UK data protection regulator:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/

Data transfers outside the UK. We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal data will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside the UK.
It is important to note that that the U.S. is not the subject of an ‘adequacy decision’ under the UK GDPR – basically, this means that the U.S. legal regime is not considered by the UK government to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant UK laws.
Where we share your personal data with third parties who are based outside the UK, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal data by the UK Government (from time to time).
  • Transfers to territories without an adequacy decision.
  • We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for Personal Data by the UK Government (e.g., the U.S., see above).
  • However, in these cases:
    • we may use specific appropriate safeguards approved by the UK Information Commissioner’s Office or UK Government, which are designed to give personal information the same protection it has in the UK – for example, requiring the recipient of personal information to enter into the relevant form of the so-called ‘International Data Transfer Agreement’ issued or approved from time to time; or
    • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.

Notice to Canadian residents

If you are a resident of Canada, this section applies to you. You have the right to request access to the personal information we hold about you, and to have information that is inaccurate or incomplete updated. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.