Supplemental Privacy Policy For California Residents

Effective Date: January 1, 2020

Last Updated: July 20, 2020

This Supplemental Privacy Policy for California Residents (“Supplemental Privacy Policy”) is provided by Wander Beauty, Inc. (“Wander Beauty”, “we”, “us” or “our”) and applies solely to the Personal Information that we collect and use relating to consumers and users who reside in the State of California (“users”, “consumers” or “you”). We provide this Supplemental Privacy Policy to comply with California privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”).

1. Personal Information We Collect

For purposes of this Supplemental Privacy Policy, except where a different definition is noted, “Personal Information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:

• Publicly available information that is from government records.
• Deidentified or aggregate consumer information.
• Information outside CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data;
  • 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.

The CCPA describes several categories of Personal Information. The following chart describes those categories and identifies which categories Wander Beauty has collected during the past 12 months.

Category	Examples	Collected?
(A) 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
(B) Personal information categories listed in 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. Some personal information included in this category may overlap with other categories.	YES
(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).	YES
(D) Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies.	YES
(E) 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
(F) Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.	YES
(G) Geolocation data	Physical location or movements.	YES
(H) Sensory data	Audio, electronic, visual, thermal, olfactory or similar information.	NO
(I) Professional or employment-related information	Current or past job history or performance evaluations.	YES
(J) 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
(K) Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	NO

2. How We Collect Personal Information

We obtain the categories of Personal Information listed above from the following categories of sources:

Information You Provide to Us

We may receive Personal Information directly from you when you interact with our websites, purchase products, interact with us or otherwise provide us with your Personal Information. We may also provide additional notices when collecting information from you about our collection, use and disclosure of that Personal Information. These notices may supplement or clarify our privacy practices with respect to that Personal Information and may provide you with additional choices about how we use that Personal Information.

Personal Information Collected from Third Parties

We may collect your Personal Information from third party business partners such as social media sites, ad networks and analytics providers.

We may also collect your Personal Information from others that refer you to our websites or our services.

Personal Information Automatically Obtained from Your Interactions with Our Website

When you use our website, our servers automatically record information that your browser sends whenever you visit a website. This information may include your IP address, browser type or the domain from which you are visiting, the webpages you visit, the search terms you use and any advertisements you interact with.

Like many websites, our website also use “cookie” technology to collect additional website usage data and to improve our websites 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 our websites and is deleted from your computer when you disconnect from or leave the websites. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our websites. We may use both session and persistent cookies to better understand how you interact with our websites, to monitor aggregate usage by our uses and web traffic routing on our websites, and to improve our websites and our 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 website. 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 websites, the pages or other content you view or otherwise interact with on our websites and the dates and times that you visit, access or use our websites. We may also use these technologies to collect 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.

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.

We may display third-party content on the websites, 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 websites. 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 Wander Beauty. Please consult such third party’s data collection, use and disclosure policies for more information.

Our website 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 websites. We encourage you to read the privacy policies or statements of the other websites you visit.

2. How We Use Personal Information

We may use or disclose the Personal Information we collect about you as described in our Privacy Policy. We may also use or disclose your Personal Information for one or more business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your Personal Information to facilitate new product orders or process refunds. If you submit a review of our products or your experience with Wander Beauty, we may post that submission on our websites, without identifying you by your full name or address.
• To provide, support, personalize and develop our websites, products and services.
• To create, maintain, customize and secure your account with us.
• To process your requests, purchases, transactions and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience on our websites and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third party sites and via email or text message (with your consent, where required by law).
• To help maintain the safety, security and integrity of our websites, products and services, databases and other technology assets and our business.
• For testing, research, analysis and product development, including to develop and improve our websites, products and services.
• To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Wander Beauty’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Wander Beauty about users of our websites, our customers and other individuals is among the assets transferred.

Wander Beauty will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice.

4. How We Share Personal Information

Wander Beauty may disclose your Personal Information to third parties as described in our Privacy Policy and for certain other business purposes. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

• Service Providers. We engage certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
• Law Enforcement Agencies. We cooperate 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 claims, for legal process (including subpoenas), to protect the property and rights of Wander Beauty or a third party, to protect Wander Beauty 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 our websites and services and any equipment used to make the websites and services available, or to comply with the law.
• Third Parties Involved in Business Transfers. Wander Beauty may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets or similar transaction, or in the event of insolvency or bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Supplemental Privacy Policy or our Privacy Policy.
• Other Third Parties. We may share Personal Information with our headquarters and affiliates, and business partners to whom it is reasonably necessary or desirable for us to disclose your Personal Information for the purposes described in our Privacy Policy and this Supplemental Privacy Policy. We may also make certain non-Personal Information available to third parties for various purposes, including our business or marketing purposes or to assist third parties in understanding our customers’ and visitors’ interest, habits and usage patterns for certain programs, content, services, advertisements, promotions and functionality available through our websites.

5. Disclosures of Personal Information for a Business Purpose

In the past 12 months, Wander Beauty has disclosed the following categories of Personal Information for a business purpose:

• Category A: Identifiers.
• Category B: Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)).
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category I: Professional or employment-related information

6. Sales of Personal Information

In the past 12 months, Wander Beauty has not “sold” Personal Information for money.

Wander Beauty may have “sold” (as that term is defined in the CCPA) Personal Information in the following categories from consumers within the last twelve (12) months. Please note that the CCPA uses an expanded definition of the term, in which “sell” means:

“Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a consumer’s personal information with a third party, whether for valuable consideration or for no consideration, for the third party’s commercial purposes.”

When we disclose that we may have “sold” Personal Information, it means that we may have received some kind of benefit to our company in return for sharing Personal Information, but have not received any money in exchange.

7. Your CCPA Privacy Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information as described below.

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 over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information, which may include:

• 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.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) 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. After we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records within the time period required by the CCPA, unless an exception applies.

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 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 Exercise Your Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by:

• Emailing us at privacy@wanderbeauty.info

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 consumer 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. The verifiable consumer request 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.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request to exercise your access, data portability and/or deletion rights 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.

Response Timing and Format

We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.

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 email.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. For data portability requests, we will select a commercially reasonable format to provide your Personal Information that is commonly usable and should allow you to transmit the information from one entity to another entity without hindrance, but we do not guarantee that all formats are usable in all media.

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.

Personal Information Sales Opt-Out and Opt-In Rights

At this time, Wander Beauty does not “sell” any Personal Information for money.

The CCPA does grant consumers rights with respect to the “sale” of their Personal Information. If you are 16 years of age or older, you have the right to direct companies not to “sell” your Personal Information at any time. If you are between 13 and 16 years of age, your Personal Information can only be sold by companies that you provide affirmatively authorize to “sell” your Personal Information. If you are less than 13 years of age, your Personal Information can only be sold by companies that your parent or legal guardian affirmatively authorizes to “sell” your Personal Information. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

The CCPA requires businesses to provide a web page where consumers can opt out of the ”sale” of their Personal Information. The link to our Do Not Sell web form is located HERE.

Non-Discrimination

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.

Other California Privacy Rights

California Civil Code Section 1798.83 permits visitors to our site who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to us at privacy@wanderbeauty.info.

8. Security

We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of Personal Information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure given the reality of communication via technology systems. Therefore, although we believe the measures implemented by us are commercially reasonable and reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications sent to us over those systems will always remain private or secure. We are not responsible for the circumvention of any privacy settings or security features.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, please promptly email us at privacy@wanderbeauty.info so that necessary measures can quickly be taken.

9. Third Party Links

Our websites or services may contain links to other websites or services that are not owned or controlled by us, including links to social media platforms, or may redirect you off our website away from our services to other websites for information or other services. This Supplemental Privacy Policy only applies to information collected by our websites and services. We are not responsible for the privacy and security practices of those other websites or social media platforms or the information they may collect (which may include IP address). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other website’s or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content.

10. Changes to this Supplemental Privacy Policy

Wander Beauty reserves the right to amend this Supplemental Privacy Policy at our discretion at any time. When we make changes to this Supplemental Privacy Policy, we will post the Supplemental Privacy Policy on our websites and update the Supplemental Privacy Policy’s last updated date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.

We welcome your questions, comments and concerns about privacy. Please email us at privacy@wanderbeauty.info with your feedback pertaining to privacy. You also may write to us at:

Wander Beauty, Inc.
35 W 36th St, Suite 3W
New York, NY 10018