Privacy Policy

Last updated: June 01, 2022

This Privacy Policy outlines our policies and practices regarding the collection, use, and disclosure of your information when you access or use our Service. It also explains your privacy rights and how the law safeguards your personal data.

We collect and use your personal information to provide, maintain, and enhance our Service. By using the Service, you consent to the collection and use of your information as described in this Privacy Policy.

Interpretation and Definitions

Interpretation

Terms with capitalized initial letters have specific meanings as defined below. These definitions apply consistently whether the terms appear in singular or plural form.

Definitions

For the purposes of this Privacy Policy:

  • Account: A unique account created for you to access our Service or parts of our Service.

  • Business: As defined by the California Consumer Privacy Act (CCPA), this refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of its processing, or on whose behalf such information is collected. This applies to entities that operate in the State of California, either alone or jointly with others.

  • Company: Referred to in this policy as "the Company," "We," "Us," or "Our," the term refers to Enza Limited, 48 Constant Spring Road, Kingston 10, Jamaica

    • For the purposes of the General Data Protection Regulation (GDPR), the Company serves as the Data Controller.

  • Consumer: As defined by the CCPA, a Consumer refers to a natural person who is a California resident. A resident includes:

    1. Individuals present in the USA for reasons other than temporary or transitory purposes.
    2. Individuals domiciled in the USA but temporarily outside the country.

  • Cookies: Small files stored on your computer, mobile device, or other devices by a website. These files contain details about your browsing history and may have other uses.

  • Country: Refers to the jurisdiction applicable to this Privacy Policy.

  • Data Controller: Under the GDPR, this term refers to the Company as the entity that determines the purposes and means of processing Personal Data, either alone or in collaboration with others.

  • Device: Any tool or equipment that can access the Service, such as a computer, smartphone, or tablet.

  • Do Not Track (DNT): A concept promoted by U.S. regulatory authorities, including the Federal Trade Commission (FTC), to provide internet users with a mechanism to control the tracking of their online activities across websites.

  • Personal Data: Any information related to an identifiable individual.

    • Under the GDPR, this includes details such as a name, identification number, location data, online identifier, or other attributes specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of an individual.
    • Under the CCPA, this includes any information that identifies, relates to, describes, or could be associated with you, either directly or indirectly.

  • Sale: Under the CCPA, this term refers to selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer's personal information to another business or third party in exchange for monetary or other valuable consideration.

  • Service: Refers to the Website.

  • Service Provider: Any individual or legal entity that processes data on behalf of the Company. This includes third-party companies or individuals hired by the Company to facilitate the Service, provide the Service, perform related tasks, or assist in analyzing how the Service is used. Under the GDPR, Service Providers are considered Data Processors.

  • Usage Data: Data collected automatically, either generated by using the Service or derived from the Service infrastructure itself (e.g., the duration of a page visit).

  • Website: Refers to soulpick, accessible at soulpick.com

  • You: Refers to the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

    • Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting / Using Personal Data

Types of Data Collected

Personal Data

While using Our Service, we may request certain personally identifiable information that could be used to contact or identify you. This information may include, but is not limited to:

  • Email address
  • Address (including State, Province, ZIP/Postal code, and City)
  • Usage Data

Usage Data

Usage Data is collected automatically while you use the Service. It may include details such as your device's Internet Protocol (IP) address, browser type and version, the pages you visit on our Service, the time and date of your visit, time spent on those pages, unique device identifiers, and other diagnostic data.

When accessing the Service via a mobile device, we may automatically collect certain information, including but not limited to: your mobile device type, unique device ID, IP address, mobile operating system, mobile browser type, unique device identifiers, and other diagnostic data. We may also collect information sent by your browser when you visit our Service or use the Service on a mobile device.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to monitor activity on our Service and store certain information. These technologies include beacons, tags, and scripts to collect and track data for service improvement and analysis. The technologies we use may include:

  • Cookies or Browser Cookies: A small file placed on your device. You can configure your browser to refuse all cookies or notify you when a cookie is being sent. However, if you refuse cookies, you may not be able to use some parts of our Service. If your browser settings do not refuse cookies, we may use them.

  • Flash Cookies: Some features of our Service use locally stored objects (or Flash Cookies) to collect and store information about your preferences or activity. These cookies are managed differently from browser cookies. To learn more about how to delete Flash Cookies, visit Adobe's Flash Player support

  • Web Beacons: Certain areas of our Service and our emails may contain small electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs), allowing us to track visitors to these pages or email opens and gather other statistics, such as the popularity of specific sections and system and server integrity.

Cookie Types

Cookies can be persistent or session cookies. Persistent cookies remain on your device after you go offline, while session cookies are deleted when you close your browser. We use both types of cookies for the following purposes:

  • Necessary / Essential Cookies
    • Type: Session Cookies
    • Administered by: Us
    • Purpose: These cookies are necessary for providing you with services available through the Website and enabling certain features, such as user authentication and fraud prevention. Without these cookies, some services would not be available.
  • Cookies Policy / Notice Acceptance Cookies
    • Type: Persistent Cookies
    • Administered by: Us
    • Purpose: These cookies track whether users have accepted our cookie policy.
  • Functionality Cookies
    • Type: Persistent Cookies
    • Administered by: Us
    • Purpose: These cookies help us remember your preferences, such as login details or language choice, providing a more personalized experience and avoiding the need to re-enter preferences.
  • Tracking and Performance Cookies
    • Type: Persistent Cookies
    • Administered by: Third Parties
    • Purpose: These cookies track website traffic and user behavior. The information gathered may indirectly identify you based on your device’s pseudonymous identifier. We may also use these cookies to test new features or pages on the Website.

For more details on the cookies we use and your choices regarding cookies, please refer to our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service: This includes monitoring how our Service is used.
  • To manage Your Account: We manage your registration as a user of the Service. The personal information you provide enables access to various features of the Service available to registered users.
  • For contract performance: To develop, enforce, and fulfill the terms of the purchase contract for products, services, or any other agreements you make with us through the Service.
  • To contact You: We may contact you via email, phone calls, SMS, or other forms of electronic communication (such as push notifications from mobile apps) about updates or relevant information regarding the Service, products, or services, including security updates, when necessary or reasonable.
  • To provide You with updates and offers: We may send you news, special offers, and information about other goods, services, or events similar to those you've already purchased or inquired about unless you choose not to receive such updates.
  • To manage Your requests: We handle and respond to any requests you make to us.
  • To deliver targeted advertising: Your information may be used to create tailored content and advertisements (and to work with third-party vendors) based on your interests or location and to assess the effectiveness of such ads.
  • For business transfers: Your personal information may be used in connection with mergers, acquisitions, restructurings, bankruptcies, or other asset transfers, where your data could be transferred as part of the transaction.
  • For additional purposes: Your information may also be used for data analysis, identifying trends in usage, assessing the effectiveness of our marketing campaigns, and improving our services, products, and overall user experience.

We may share your personal information in the following scenarios:

  • With Service Providers: We may share your personal data with service providers who help us monitor and analyze how our Service is used, provide targeted advertising, and contact you.
  • For business transfers: We may share or transfer your personal information in connection with mergers, sales of company assets, financing, or acquisitions.
  • With Affiliates: We may share your information with affiliates, such as our parent company or subsidiaries, and require them to comply with this Privacy Policy.
  • With business partners: Your information may be shared with our business partners to offer specific products, services, or promotions.
  • With other users: When you share information or interact in public areas of the Service, that information may be visible to other users and potentially shared outside of the Service.
  • With Your consent: We may disclose your personal information for any purpose if you give us your explicit consent.

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We will keep and use your Personal Data as required to comply with legal obligations (e.g., if required by applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis. This data is typically stored for a shorter duration, unless it is used to enhance security or improve the functionality of our Service, or we are legally obligated to retain it for a longer period.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and other locations where the involved parties are situated. This means that your data may be transferred to — and stored on — systems located outside of your state, province, country, or other legal jurisdiction, where data protection laws may differ from those in your jurisdiction. By consenting to this Privacy Policy and submitting your information, you agree to this transfer. The Company will take reasonable steps to ensure your data is treated securely and in accordance with this Privacy Policy. We will not transfer your Personal Data to any organization or country unless adequate safeguards are in place to ensure the security of your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

In the event that the Company undergoes a merger, acquisition, or asset sale, your Personal Data may be transferred. We will notify you prior to such a transfer, at which point your data will be subject to a different Privacy Policy.

Law Enforcement

In certain circumstances, the Company may be required to disclose your Personal Data if mandated by law or in response to valid requests from public authorities (e.g., a court or government agency).

Other Legal Requirements

The Company may disclose your Personal Data in good faith if it believes such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the Company’s rights or property
  • Investigate or prevent potential wrongdoing related to the Service
  • Protect the personal safety of Service Users or the public
  • Protect against legal liability

Security of Your Personal Data

The security of your Personal Data is a priority for us, but please be aware that no transmission method over the internet, or method of electronic storage, is 100% secure. While we strive to use commercially reasonable means to protect your Personal Data, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers we work with may have access to your Personal Data. These third-party vendors collect, store, use, process, and transfer information about your activity on our Service according to their own privacy policies.

Analytics

We may use third-party Service Providers to monitor and analyze how our Service is used.

  • Google Analytics
    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to monitor and analyze the use of our Service. This data is shared with other Google services and may be used by Google to personalize ads on its advertising network.
  • You can opt out of having your activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics from sharing information about your visits with Google.
  • For more information about Google’s privacy practices, please visit the Google Privacy & Terms page.

Email Marketing

We may use your Personal Data to send you newsletters, marketing, promotional materials, or other information that may be of interest to you. You can opt-out of receiving these communications by following the unsubscribe link provided in any email we send or by contacting us directly.

We may use Email Marketing Service Providers to manage and send emails to you, such as:

  • Amazon
  • You can view Amazon’s Privacy Policy here.

Behavioral Remarketing

The Company uses remarketing services to advertise to you after you’ve accessed or visited our Service. We and our third-party vendors use cookies and other non-cookie technologies to recognize your device and understand how you use our Service. This helps us improve our Service based on your interests and show you relevant advertisements.

These third-party vendors collect, store, use, process, and transfer information about your activity on our Service in accordance with their privacy policies. This allows us to:

  • Measure and analyze traffic and browsing activity on our Service.
  • Display advertisements for our products and/or services on third-party websites or apps.
  • Measure and evaluate the performance of our advertising campaigns.

Some of these third-party vendors may use non-cookie technologies that might not be impacted by browser settings blocking cookies. If this is the case, your browser may not allow you to block these technologies.

You can use the following third-party tools to opt-out of the collection and use of information for interest-based advertising:

You may also opt-out of all personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). For more information, refer to your mobile device’s help system.

We may share information such as hashed email addresses (if available) or other online identifiers collected on our Service with third-party vendors. This enables our vendors to recognize and deliver ads to you across devices and browsers. For details on the technologies used by these third-party vendors and their cross-device capabilities, please refer to the privacy policy of each vendor listed below.

The third-party vendors we use include:

  • Google Ads (AdWords)
    Google Ads remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize your Google Display Network ads by visiting the Google Ads Settings page. Additionally, Google recommends installing the Google Analytics Opt-out Browser Add-on to prevent data collection and use by Google Analytics. For more information on Google’s privacy practices, please visit the Google Privacy & Terms page.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process your Personal Data under the following legal grounds:

  • Consent: You have given us your consent to process your Personal Data for one or more specific purposes.
  • Performance of a contract: Processing your Personal Data is necessary for fulfilling a contract with you or for pre-contractual obligations.
  • Legal obligations: Processing is required to comply with legal obligations to which we are subject.
  • Vital interests: Processing is necessary to protect your vital interests or those of another individual.
  • Public interests: Processing is related to carrying out a task that is in the public interest or in the exercise of official authority vested in the company.
  • Legitimate interests: Processing is necessary for legitimate interests pursued by the company, provided these interests are not overridden by your rights and freedoms.

If you're unsure about the specific legal basis for any processing of your Personal Data, please feel free to contact us. We’ll clarify whether the provision of your Personal Data is a statutory or contractual requirement or a requirement to enter into a contract.

Your Rights under the GDPR

We are committed to respecting your privacy rights under the GDPR and ensuring that you can exercise them. If you're within the EU, you have the following rights:

  • Access to your Personal Data: You have the right to request access to the Personal Data we hold about you. You can also update or delete your data through your account settings. If you are unable to do this yourself, please contact us for assistance. You also have the right to request a copy of the Personal Data we hold about you.
  • Correction of Personal Data: You have the right to have any inaccurate or incomplete information we hold about you corrected.
  • Object to processing: You have the right to object to the processing of your Personal Data, particularly if we are relying on legitimate interests as the legal basis for processing. You can also object to processing for direct marketing purposes.
  • Erasure of Personal Data: You have the right to request the deletion of your Personal Data when there’s no valid reason for us to continue processing it.
  • Transfer of Personal Data: You can request that we transfer your Personal Data to you or a third party in a structured, commonly used, machine-readable format. This applies to automated data provided by you based on consent or where used to fulfill a contract.
  • Withdraw your consent: You have the right to withdraw consent for the processing of your Personal Data at any time. Please note that withdrawing consent may affect your ability to access some services or features.

Exercising Your GDPR Rights

You can exercise your rights to access, correct, delete, or oppose the processing of your data by contacting us HERE. Please note that we may ask you to verify your identity before responding to such requests. We will make every effort to respond to your request as promptly as possible.

You also have the right to lodge a complaint with a Data Protection Authority if you believe that our collection or use of your Personal Data violates applicable laws. If you are in the European Economic Area (EEA), you may contact your local data protection authority.

CCPA Privacy

This section applies to California residents and supplements our Privacy Policy, addressing privacy rights under the California Consumer Privacy Act (CCPA).

Categories of Personal Information Collected

We may collect the following categories of personal information from California residents:

  • Category A: Identifiers
    Examples: Real name, postal address, unique personal identifier, online identifier, email address, account name, IP address, driver’s license number, or similar identifiers.
    Collected: Yes
  • Category B: Personal information as defined by the California Customer Records statute
    Examples: Name, signature, Social Security number, physical description, address, phone number, passport number, driver’s license number, insurance policy number, financial information, medical information, or health insurance details.
    Collected: Yes
  • Category C: Protected classifications
    Examples: Age, race, gender, marital status, medical condition, disability, sexual orientation, veteran status, genetic information.
    Collected: No
  • Category D: Commercial information
    Examples: Purchase history or history of services.
    Collected: No
  • Category E: Biometric information
    Examples: Fingerprints, voiceprints, retina scans, gait, sleep, or exercise data.
    Collected: No
  • Category F: Internet or network activity
    Examples: Interactions with our Service or advertisements.
    Collected: Yes
  • Category G: Geolocation data
    Examples: Approximate physical location.
    Collected: No
  • Category H: Sensory data
    Examples: Audio, video, or other sensory information.
    Collected: No
  • Category I: Professional or employment-related information
    Examples: Employment history or job performance.
    Collected: No
  • Category J: Non-public education information
    Examples: Educational records, grades, transcripts.
    Collected: No
  • Category K: Inferences drawn from other personal information
    Examples: Profile based on preferences, characteristics, behavior, etc.
    Collected: No

Exclusions from Personal Information

Under the CCPA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated data
  • Information excluded from CCPA, including health data (covered by HIPAA), financial data (covered by GLBA), and driver's license information.

This provides transparency about the types of personal information we may collect or have collected, and how we handle it under applicable laws.

Sources of Personal Information

Categories of Personal Information We Obtain

We may obtain personal information from the following categories of sources:

  • Directly from You: This includes information you provide by completing forms on our Service, expressing preferences, or interacting with our Service.
  • Indirectly from You: Information we collect by observing your activity on our Service, such as interactions and usage patterns.
  • Automatically from You: We may collect information via cookies or other tracking technologies as you navigate through our Service.
  • From Service Providers: Third-party vendors may provide us with information, such as data analytics or targeted advertising services.

Use of Personal Information for Business or Commercial Purposes

We may use or disclose personal information for “business purposes” or “commercial purposes” as defined under the CCPA. These purposes include:

  • Operating our Service and providing it to you.
  • Providing customer support, addressing inquiries, and improving our Service.
  • Fulfilling the reason you provided the information (e.g., responding to a service inquiry).
  • Responding to law enforcement requests or complying with legal obligations.
  • Conducting internal administrative or auditing activities.
  • Detecting security incidents and protecting against fraudulent activities.

The examples above are for illustrative purposes and are not exhaustive. For more details, refer to the “Use of Your Personal Data” section. If we decide to collect new categories of personal information or change how we use the data, we will update our Privacy Policy accordingly.

Disclosure of Personal Information for Business or Commercial Purposes

In the past twelve months, we may have used or disclosed the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers (e.g., name, email address, etc.)
  • Category B: Personal information categories from the California Customer Records statute (e.g., contact information, financial data)
  • Category F: Internet or other similar network activity (e.g., usage data, interactions)

When we disclose personal information for these purposes, we enter into contracts with third parties requiring them to maintain confidentiality and only use the information for the specified business purposes.

Sale of Personal Information

The CCPA defines “sale” as transferring personal information to third parties for valuable consideration, which does not necessarily have to be monetary. We may have sold personal information in the past twelve months, including:

  • Category A: Identifiers
  • Category B: Personal information categories from the California Customer Records statute
  • Category F: Internet or other network activity

Please note that this does not mean all personal information in these categories has been sold, but reflects our belief that some of this data may have been shared for value in return.

Sharing of Personal Information

We may share your personal information with the following categories of third parties:

  • Service Providers: Companies that help us provide our Service.
  • Affiliates: Other entities within our corporate group.
  • Business Partners: Companies with whom we collaborate to provide products or services.
  • Third-party Vendors: With your consent or as authorized by you, we may share personal information with other vendors involved in delivering products or services to you.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from children under 16. However, third-party websites linked through our Service may collect such information. We encourage parents and guardians to monitor children’s internet usage. If we receive affirmative consent (opt-in) from consumers between 13 and 16 years old, or from parents of children under 13, we may allow the sale of personal information. Consumers can opt-out of the sale of their personal information at any time by contacting us.

If we suspect a child under 13 has provided personal information, we will take steps to delete it. Please contact us if you believe this has occurred.

Your Rights Under the CCPA

If you are a California resident, you have the following rights under the CCPA:

  • The Right to Notice: You are entitled to know which categories of personal information are being collected and the purposes for which it is used.
  • The Right to Request: You can request information about our collection, use, sale, and disclosure of your personal information. Upon request, we will disclose:
    • Categories of personal information we’ve collected about you.
    • Sources from which the personal information was obtained.
    • The purpose for collecting or selling your information.
    • Categories of third parties with whom we share your information.
    • Specific pieces of personal information we’ve collected about you.

    If we sold or disclosed your information for business purposes, we will provide details on:

    • Categories of personal information sold.
    • Categories of personal information disclosed.
  • The Right to Opt-Out of the Sale of Personal Data: You can direct us not to sell your personal information. To do this, please contact us.
  • The Right to Delete Personal Data: You may request that we delete your personal information, subject to certain exceptions. We may deny your request if we need the information for specific purposes such as:
    • Completing a transaction.
    • Detecting or preventing fraudulent activities.
    • Legal obligations.
  • The Right Not to Be Discriminated Against: You have the right to not face discrimination for exercising your rights, such as denial of goods or services or offering different prices or levels of service.

For more information or to exercise your rights, please contact us.

Exercising Your CCPA Data Protection Rights

To exercise your rights under the California Consumer Privacy Act (CCPA) as a California resident, please follow the instructions below:

  1. Contact Us:
    • Via our Website: Visit https://soulpick.com/support.
    • Verifiable Request: Only you or an authorized representative registered with the California Secretary of State can submit a verifiable request.
  2. Request Requirements:
    • Provide enough information to allow us to verify your identity or confirm that the personal information relates to you.
    • Describe your request clearly enough for us to properly understand, evaluate, and respond to it.

    3. We cannot respond if we cannot verify your identity or confirm that the personal information pertains to you.

  3. Disclosure Timeframe:
    • We will respond within 45 days of receiving your verifiable request.
    • If more time is needed, we will extend this period once by an additional 45 days with prior notice.
  4. Data Portability:
    • We will provide your personal data in a format that is easily usable and allows you to transfer it to another entity.

Do Not Sell My Personal Information

You have the right to opt out of the sale of your personal information:

  • To Opt-Out: Submit a verifiable consumer request by contacting us.
  • Interest-Based Advertising: To opt-out of personalized ads served by third-party service providers, follow these platforms:

If you change browsers or delete cookies, you will need to opt out again.

Mobile Devices

For mobile device users, you can limit interest-based ads by:

  • Android: "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization."
  • iOS: "Limit Ad Tracking."

You can also turn off location tracking through your device's preferences.

"Do Not Track" Policy (CalOPPA)

Our Service does not respond to "Do Not Track" (DNT) signals. However, you can enable DNT preferences in your browser settings if you'd like to prevent tracking by other websites.

Children's Privacy

  • We do not knowingly collect personal information from children under 13.
  • If you are a parent or guardian and aware that your child has provided personal data, please contact us. We will take steps to remove it.

If your country requires parental consent, we may ask for it before processing the information.

California Privacy Rights (Shine the Light Law)

Under California Civil Code Section 1798, California residents can request information about the sharing of personal data with third parties for direct marketing purposes once a year. To make a request, please contact us.

California Privacy Rights for Minor Users

Under California Business and Professions Code Section 22581, minors under 18 can request removal of content they have posted publicly on our service. To request removal, contact us with the associated email address.

Please note that this removal may not be complete in all cases, as there are exceptions based on the law.

Links to Other Websites

Our Service may contain links to third-party websites. We are not responsible for their content, privacy policies, or practices. We encourage you to review the privacy policies of those websites.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Any changes will be posted on this page with an updated date. You will be notified via email or a prominent notice on our Service before any changes take effect.

Contact Us

If you have any questions about this Privacy Policy, please contact us by visiting our support page a https://soulpick.com/support