PRIVACY POLICY
YOU SHOULD CAREFULLY READ THIS PRIVACY POLICY.
By accessing, browsing, and/or otherwise using the Sites and/or Site Offerings, you are creating a binding contract between you and us, and you are acknowledging that you have read, understood, and agreed to be bound by this Privacy Policy, in its entirety. If you do not agree with the terms and conditions of this Privacy Policy in their entirety and/or would prefer that we not collect, use, or share your Personal Data as described herein, you should not use the Sites and/or Site Offerings, or otherwise provide us with any information.
INTRODUCTION
This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Data is collected and used in connection with our Sites.
When we refer to “Personal Data” in this Privacy Policy, we are referring to any information that may be used, either alone or in combination with other information, to personally identify an individual, as well as the personal or material circumstances of an identified or identifiable individual. Different states, countries, and jurisdictions define Personal Data (and similar terms, such as personal information and personally identifiable information) to include different things, but Personal Data includes information, such as first and last name, email address, home or other physical address, telephone number, and other contact information. It may also include your computer or mobile device IP address and geo-location information, if such data can be linked to a particular person.
This Privacy Policy applies only to Personal Data and other information provided by you and/or collected by us through the Sites. It does not apply to Personal Data and/or other information that we, or other parties, may collect through other means, such as through any business relationship between you and us. In this circumstance, there will be a separate privacy policy that applies to the relevant processing of personal data.
LEGAL BASIS
We collect Personal Data that you provide to us (during the registration, email submission, and/or checkout process) to fulfill your request to receive additional information or for the purpose of handling the contractual relationship that you have with moretohair®. We only use and store your Personal Data if we have a legal basis for doing so, including where you have given us your express consent, where we have a legitimate business interest or pursuant to a contractual relationship between you and moretohair®. Please be advised that users may withdraw consent at any time by using the options made available in this Privacy Policy.
TERMS OF USE
This Privacy Policy forms part of, and is fully incorporated into, our Terms and Conditions (“Terms”), which are available By using the website, you are creating a binding contract on the terms and conditions set out in the Terms.
Jurisdiction-specific terms
Note that there are some specific terms applicable if you are located in (1) EUROPEAN UNION AND UNITED KINGDOM, (2) CALIFORNIA, (3) FLORIDA. If you are from any of these jurisdictions, please ensure you review those sections along with the main sections of the Privacy Policy. Anything in those sections will override any contradictory statements provided in the main section of the Privacy Policy.
. If you are under eighteen (18) years of age (or the legal age of majority in your jurisdiction, if greater than eighteen (18)), you may not, under any circumstances, enter into any transactions on the Sites or provide personal information to us for any purpose, except through your legal guardian under applicable law once your legal guardian has reviewed and agreed to these Terms and Conditions in their entirety. The Sites are not directed to children under thirteen (18) years of age. IF YOU ARE UNDER 18, YOU MAY NOT ACCESS AND/OR USE THE SITES AND/OR SITE OFFERINGS. By accessing or using the Sites, you represent and warrant that you meet all of these requirements.
By accessing or using the Sites, you are acknowledging that you have read, understand, and agree, without limitation or qualification, to be bound by the Terms and Conditions. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS IN THEIR ENTIRETY, YOU MAY NOT ACCESS AND/OR USE THE SITES AND/OR SITE OFFERINGS.
ADDITIONAL RIGHTS APPLICABLE TO RESIDENTS OF THE EUROPEAN UNION AND THE UNITED KINGDOM
For our users who are residents of the European Union (“EU”) or the United Kingdom (“UK”), this Privacy Policy is intended to comply with the EU’s General Data Protection Regulation (“GDPR”) and the United Kingdom General Data Protection Regulation (“UK-GDPR”).
Data Subject Rights: If you are an EU resident or a UK resident, you have the following rights, subject to certain limitations and exceptions imposed by the GDPR and UK-GDPR, respectively:
- Right to Access – this is the right to request copies, in a machine readable format, of those portions of your Personal Data that we have collected.
- Right to Correct – this is the right to have Personal Data in our possession or control corrected if it is accurate or incomplete.
- Right to Erasure – this is the right to ask us to delete or remove your Personal Data from our systems, though note that this right is not absolute, for example where processing is necessary to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
- Right to Restrict Use – this is your right to block us from using, or to limit the ways we can use, your Personal Data.
- Right to Data Portability – this is your right to request that certain of your Personal Data be transferred to a different provider.
- Right to Object – this is your right to object to our use of your Personal Data, including when we use it for our legitimate interests, including for marketing purposes.
If you have questions relating to the above rights, you can contact us at [email protected]
If you are a resident of the EU and are not satisfied with how we have responded to any request that you submit to us regarding the above rights, you may be able to raise your complaint with the Data Protection Authority in your jurisdiction. You can find your national Data Protection Authority here.
PRIVACY PROVISIONS FOR CALIFORNIA RESIDENTS
These Privacy Provisions for California Residents (“CA Privacy Provisions”) supplement the information contained in the Privacy Policy set forth above. These CA Privacy Provisions apply solely to residents of the State of California (“User(s)”). We adopt these CA Privacy Provisions in compliance with the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020 (the “CCPA”). Any terms defined in the CCPA (such as “personal information”) have the same meaning when used in these CA Privacy Provisions.
Shine the Light. California Civil Code Section 1798.83 permits our customers who are California State residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. We may, in certain limited instances, disclose your Personal Data to third parties who perform administrative functions on our behalf. California State residents may request the following information regarding our disclosure of your Personal Data to third parties: (a) how your Personal Data was disclosed to third parties; (b) a list of certain categories of Personal Data that we have disclosed to certain third parties during the immediately preceding calendar year; and (c) a list of certain categories of third parties that received Personal Data from us during that calendar year. To make such a request, please send an email to [email protected] Please note that we are only required to respond to one request per customer each year.
Privacy Rights for California Minors in the Digital World. In addition, if you are a California State resident under eighteen (18) years of age and have registered as a user in violation of this Privacy Policy and our Terms of Use, California Business and Professions Code Section 22581 permits you to remove content or Personal Data that you have publicly posted on the Sites. If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal, you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and, as such, there may be circumstances in which the law does not require us to enable removal of content.
Categories of Information We Collect. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or device (“personal information”). In particular, we have collected the following categories of personal information from Users within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers. | A real name, postal address country city etc, online identifie, email address, account name, telephone number, or other similar identifiers. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may with other categories. | NO |
C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
E. Internet or other similar network activity. | Browsing history, search history, information on a User’s interaction with a website, application or advertisement. | NO |
F. Sensory Data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
L. Sensitive Personal Information. | Account log-in information and credit card numbers. | YES |
We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):
- Directly from our Users. For example, from online registration forms that our Users submit to us in connection with the products and/or services that we offer by and through the Sites (Category A, B, C, D, E, and F).
- Indirectly from our Users. For example, through information we collect from our Users in the course of providing our products and/or services to them (Category A, B, C, D, E, and F).
- Directly and indirectly from activity on the Sites. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Sites-related usage details and analytics as same are collected automatically by us and our third party partners (Category E)
- When our Users interact with us on our social media accounts, including commenting on and/or liking our posts(Category E)
- From third parties that interact with us in connection with the products and/or services that we offer to our Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis (Category A, B, C, D and E)
Use of Personal Information
We may use or disclose each of the categories of personal information set forth above for one or more of the following business or commercial purposes (with the specific categories of personal information indicated in parenthesis):
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your purchase of products and/or services, we will use that information to process your order (Category A, B, C, D, and F).
- To provide you with information, products or services that you request from us (Category A, B, C, D, and F).
- To create, maintain, customize and secure your account with us (Category A, B, C, D, E, and F).
- To provide you with e-mail, direct mail and telemarketing messages concerning certain MORETOHAIR® products and/or services, as well as third-party products and/or services, that we believe may be of interest to you (Category A, B, C, D, E, and F).
- To deliver relevant Sites-related content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (Category A, B, C, D and E).
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Sites’ respective Terms and Conditions (Category A, B, C, D, E, and F).
- To improve the Sites and better present their respective contents to you (Category A, B, C, D, E and F).
- For customer service purposes and to respond to inquiries from you (Category A, B, C, D, and E).
- For testing, research, analysis and product development (Category A, B, C, D, E and F).
- As necessary or appropriate to protect our rights, property or safety, and that of our clients or others (Category A, B, C, D, E and F).
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations (Category A, B, C, D, E and F).
- As described to you when collecting your personal information or as otherwise set forth in the CCPA (Category A, B, C, D, E and F).
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred (Category A, B, C, D, E and F).
We collect or use your sensitive personal information as necessary to perform the services or provide the goods reasonably expected, or as otherwise permitted by the CCPA.
We will not collect additional categories of personal information or use the personal information that we collected for materially different, unrelated or incompatible purposes without providing you with notice.
Disclosure of Personal Information
We disclose each of the categories of personal information set forth above for the business and commercial purposes described in the Use of Personal Information section.
Selling and Sharing of Personal Information
We work with other companies and businesses to deliver advertising to you on other sites and services. In working with other companies and businesses, we may disclose personal information in a way that is “selling” or “sharing” personal information as defined under the CCPA.
We do not sell or share any of your sensitive personal information, and do not sell or share the personal information of consumers.
How Long We Keep Your Personal Information
We generally keep your personal information for as long as necessary to provide our products and services.
When deciding how long we need information, we consider the following factors:
- how long the information is needed to provide our products and services;
- how long the information is needed to comply with legal or regulatory obligations or to resolve disputes or defend against legal claims;
- whether the information is needed for other legitimate purposes such as to prevent harm to us or others, including our rights, property, or products; to enforce our terms and policies, or to promote security and integrity.
Your Rights and Choices
The CCPA provides Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable User request, we will disclose to you:
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we have shared that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- a) sales, identifying the personal information categories that each category of recipient purchased; and
- b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable User request, in accordance with the erasure requests process specified above under “Removing Information” clause, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
- 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 rights, ensure the right of another User to exercise her/his free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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, but only if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with User 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.
Right to Correct
You have a right to request that we correct inaccurate personal information we maintain about you. We will take into account the nature of the personal information and the purposes for which we process it. We may require documentation from you in order to process your request, including your name, email address, phone number, and request details.
Right to Opt Out of Sharing
You have a right to direct us not to “share” your personal information (as those terms are defined under the CCPA). To exercise this right, please click on the following link: Do Not Sell or Share My Personal Information.
With regards to your deletion rights described above, kindly follow the erasure request process specified above under “Removing Information” clause.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable User request related to your personal information.
You may only make a verifiable User request for access or data portability twice within a 12-month period.
The verifiable User request must:
- Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative. If you use an authorized agent to submit a consumer request, the authorized agent must provide documentation or other proof indicating that they are authorized to act on your behalf. For requests to correct, access or delete, we may require you to verify your identity directly with us and directly confirm with us that you provided the authorized agent permission to submit the request.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable User request does not require you to create an account with us. We will only use personal information provided in a verifiable User request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We attempt to respond to all verifiable User requests within twenty one (21) days of the receipt thereof. If we require more time (up to forty-five (45) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable User 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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; and/or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to these Privacy Provisions
We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Sites’ respective homepages.
Contact Information
If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California State law, please do not hesitate to contact us by either:
- Emailing us at: [email protected]
PRIVACY PROVISIONS FOR NON-CALIFORNIA US RESIDENTS
These privacy provisions for residents of the United States (“US Privacy Provisions”) supplement the information contained in the Privacy Policy set forth above. These Privacy Provisions describe how to exercise your rights under the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act.
Your Rights and Choices
Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:
Access to Specific Information and Data Portability Rights
You may have the right to request that we confirm whether or not we have or currently are processing your personal data, and you may have the right to request a copy of your personal data that we have collected from you.
Deletion Request Rights
You may have the right to request that we delete any of your personal data that we collected from or about you, subject to certain exceptions. In some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal data on a de-identified and aggregated basis in such a manner that the data no longer identifies you.
Right to Correct
You may have a right to request that we correct inaccurate personal data we maintain about you. We will take into account the nature of the personal data and the purposes for which we process it. We may require documentation from you in order to process your request, including your name, email address, phone number, and request details.
Exercising Access, Data Portability, Deletion, and Correction Rights
To exercise your access, data portability, deletion, and/or correction rights described above, please submit a verifiable User request to us by either:
- Emailing us at: [email protected]
With regards to your deletion rights described above, kindly follow the erasure request process specified above under “Removing Information” clause.
We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm that the personal data relates to you. Making a verifiable User request does not require you to create an account with us. We will only use personal data provided in a verifiable User request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We attempt to respond to all verifiable User requests within twenty one (21) days of the receipt thereof. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data 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 User 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.
Changes to these Privacy Provisions
We reserve the right to amend these US Privacy Provisions in our discretion and at any time. When we make changes to these US Privacy Provisions, we will notify you by email or through a notice on the Sites’ respective homepages.
Contact Information
If you have any questions or comments about these Virginia Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal data, your choices and rights regarding such use, or wish to exercise your rights under Virginia State law, please do not hesitate to contact us by either:
- Emailing us at: [email protected]
Moreto hair Ltd 515070142
Yordey Haym 17 Hod Hasharon Israel
+97298333121
ADDITIONAL RIGHTS APPLICABLE TO CANADIAN USERS
HOW AND WHY WE COLLECT PERSONAL DATA
Please see our Provisions for California Residents for additional details regarding the categories of Personal Data collected, and the business purposes for such collection.
Providing Personal Data is Your Choice. However, if you choose to make use of certain Site Offerings and/or Site features, you may need to provide certain Personal Data to us. If you choose not to provide mandatory Personal Data, you may still visit parts of our Sites but you may be unable to access certain Site Offerings, options, programs, offers, and services that involve our interaction with you. If you do provide us with Personal Data as described below, you agree that it will be accurate and complete, and it is your responsibility to keep it current.
The types of Personal Data you may be asked to provide, and the circumstances in which we request it, are described below. We present the information below based on the categories of information collected, but please be aware that similar specific pieces of information may apply to multiple categories. For example, your name and email address may be included within each of the “Identification and Contact Information”, “Billing Information” and “User-Provided Information” categories described below.
(i) Account Creation: During your use of our Sites, and in order to use certain Site Offerings, you may choose, or be required, to create an account, referred to herein as an “Account.” We may offer different options to create an Account, including:
1) Direct registration, where you input your Personal Data to complete and submit a registration form directly on our Sites.
2) Upon subscription to our Auto-Replenishment service, an Account will automatically be created for you so that you may access, manage and cancel your subscription.
3) Registration using third party accounts, where you use a “login with…” (or similar) button that we display on our Sites for a designated third party service, referred to herein as a “Third Party Account,” such as Facebook® or Google®. Doing so will enable you to link your Account and your Third Party Account. If you choose this option, then you will be required to approve the connection as well as the types of information (which may include Personal Data) that we will obtain from your Third Party Account and the types of activities that we may perform in connection with your Third Party Account. Please note that in order to use this option, you will need to have, and may need to be signed-in to, an existing Third Party Account.
Where you provide your consent as set forth above, you represent that you are the line subscriber and primary user of the telephone number that you provided (“Active Telephone Number”) and, as such, have the authority to agree to receive SMS text messages on the Active Telephone Number. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when your Active Telephone Number changes. Without limiting the foregoing, if you: (a) have your Active Telephone Number reassigned to another person or entity; (b) give up your Active Telephone Number so that it is no longer used by you; (c) port your Active Telephone Number to a landline or vice versa; or (d) otherwise stop using your Active Telephone Number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify MORETOHAIR® of the Phone Number Change via e-mail at: [email protected], or by using one of the methods set forth in the “Contact Us” section below.
- g) Our legal basis for processing this Personal Data is our legitimate business interests, specifically our ability to provide you with the requested Site Offerings, to offer you our products and services, and to promote our Site Offerings and the content of our Sites.
- h) We will retain this Personal Data for as long as we continue to have a business purpose for doing so (which will be at least as long as you continue to maintain an Account), unless a longer period is required by law. Such business purposes may include legal, taxation, accounting, risk management, and other purposes.