Privacy Policy
Last updated: 1/18/2022
This Site is owned and
made available by Sunless, Inc. and its Affiliates (individually and
collectively, “Sunless”, “Company”, “We”, “Us”, or
“Our”). This Privacy Policy describes the Personal Data collected by Sunless
and its suppliers through the Site and through Your use of the Service and how
that Personal Data is used and disclosed. This Privacy Policy also describes Your
choices regarding the use of Your Personal Data, how You can correct
inaccuracies in Your Personal Data, and how We communicate changes to this
Privacy Policy.
By accessing or using the
Site, by accepting the Site’s EULA (as applicable), by utilizing the Service,
or by entering into any other agreement with Sunless that governs access to or
use of the Site or the Service, You agree on behalf of Yourself and any
organization or company that You represent that You have read and understand
this Privacy Policy. If You do not agree with this Privacy Policy, do not
access or use the Site or Service.
This Privacy Policy is
incorporated into and made a part of Our EULA and any other agreement that
references this Privacy Policy or governs access to or use of the Service.
Table of Contents
Interpretation
and Definitions
Changes to this Privacy Policy
Your Consent
Collecting Your Personal Data
Use and Disclosure of Your Personal
Data
General Principles for the Processing
of Personal Data
Third Party Sites and Services
Choices and Access
Accuracy
Your Rights of Your Personal Data
Retention Period
Security
Do Not Track Policy
Children’s Privacy
Compliance with Local Laws
Your Right to Complain
Contact Us
Interpretation and
Definitions
Interpretation
The words of which the
initial letter is capitalized have meanings defined under the following
conditions. The following definitions shall have the same meaning regardless of
whether they appear in singular or in plural.
Definitions
For the purposes of this
Privacy Policy:
Account
means a unique account created for You to access our Service or parts of our
Service.
Affiliate
means an entity that controls, is controlled by or is under common control with
a party, where "control" means ownership of 50% or more of the
shares, equity interest or other securities entitled to vote for election of
directors or other managing authority.
Application
means the mobile applications provided by the Company downloaded or used by You
on any electronic device, named Mystic Tan, or other related Sunless products.
Device
means any device that can access the Service such as a computer, a cellphone,
or a digital tablet.
Personal
Data
is any information that relates to an identified or identifiable individual.
Service refers to the services provided by
Sunless through the Application or the Website or both.
Site
refers to the Application or the Website.
Usage
Data
refers to data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, the duration of
a page visit).
Website
refers to any website owned by Sunless or its Affiliates.
You
means 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.
Changes to this
Privacy Policy
We reserve the right to
update this Privacy Policy at any time. All updates will be effective
immediately upon posting of the updated Privacy Policy on the Site.
We will let You know via
email and/or a prominent notice on Our Service, prior to the change becoming
effective and update the "Last Updated" date at the top of this
Privacy Policy.
You are advised to review
this Privacy Policy periodically for any changes.
Your Consent
You hereby agree with and
consent to the collection and processing of Your Personal Data as described in
this Privacy Policy. Your Personal Data may be collected, processed and stored
by Sunless or its services providers in the United States and other countries
where our servers reside. Please be
aware that the privacy protections and legal requirements, including the rights
of authorities to access Your Personal Data, in some of these countries may not
be equivalent to those in Your country. You hereby agree with and consent to
the transfer of Your Personal Data to the United States and other countries
where Sunless operates. You have the right, at any time, to withdraw Your
consent to Sunless’ collection and processing of Your Personal Data, or to the
transfer of Your Personal Data to the United States and other countries where Sunless
operates. You may withdraw Your consent by utilizing the contact methods
provided in this Privacy Policy.
Collecting Your
Personal Data
As You interact with Sunless,
there may be opportunities for You to provide Us with Your Personal Data.
Additionally, We may collect certain information about You as further described
below.
You may provide Us with
Personal Data through a number of sources: Sunless Websites, Applications,
product/service related events, surveys, social media platforms, and through
our customer contact centers.
The categories of
information that Sunless may collect about You are listed in the table below:
Category |
Examples |
Collected |
Identifiers |
A
real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name, or other
similar identifiers. |
Yes |
Specific
Personal Data Categories |
A
name, signature, Social Security number, physical characteristics or
description, address, or telephone number. Some Personal Data included in
this category may overlap with other categories. |
Yes |
Camera
and Photo Information |
Some
of our services require us to collect images and other information from your
Device’s camera and photos. |
Yes |
Protected
Classification Characteristics |
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 |
Commercial
information |
Records
and history of products or services purchased or considered. |
Yes |
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 |
Internet
or other similar network activity |
Interaction
with our Service or advertisement. |
Yes |
Geolocation
data |
Approximate
physical location. |
Yes |
Sensory
data |
Audio,
electronic, visual, thermal, olfactory, or similar information. |
No |
Professional
or employment-related information |
Current
or past job history or performance evaluations. |
No |
Non-public
education information |
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 |
Inferences
drawn from other Personal Data |
Profile
reflecting a person's preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Yes |
We obtain the categories
of Personal Data listed above (1) directly from You as described herein; (2)
indirectly from You, for example, through information We collect in the course
of providing services and products; (3) directly and indirectly from activity
on this Site; and (4) from third parties that interact with Us in connection
with the services and products We provide.
Personal
Data You Provide
While
using Our Service, We may ask You to provide Us with certain Personal Data that
can be used to contact or identify personally or to provide you services,
including, but not limited to:
·
First and Last Name
·
Phone Number
·
Usage Data
·
Location Information
·
Camera and Photos
You may choose to receive
certain communications from Sunless via Your email address upon interaction
with the Site. From time-to-time Sunless
may include surveys, information requests, or other features on the Service
that ask You to provide Personal Data such as Your name, telephone number,
email address or mailing address. Any information You may provide will be used
by Sunless to allow You to participate in the particular feature being offered.
Sunless may also retain any information You provide in order to send You
information about Sunless’ products and services that may be of interest to You.
Sunless will provide You with the opportunity to opt-out of receiving such
communications. We may use one or more service providers to administer these
messages, but We do not share Your email address with spammers or any other
third parties except as described in this Privacy Policy.
We may combine the Personal
Data You submit directly through the Service with other Personal Data We have
collected from You, whether on- or offline.
We may also combine it with information We receive about You from other
sources, such as other companies, publicly available information sources
(including information from Your publicly available social media profiles), and
other third parties.
Passive Information
Collection and Use
As You navigate around
the Service, certain information can be passively collected (that is, gathered
without You actively providing the information), using various
technologies. We passively collect and
use information in a variety of ways, including:
·
Through Your Browser and Device: When You
access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile
device You use, Your mobile device unique ID, the IP address of Your mobile
device, Your mobile operating system, the type of mobile Internet browser You
use, unique device identifiers and other diagnostic data. We may also collect
information that Your browser sends whenever You visit our Service or when You
access the Service by or through a mobile device. You can enable or disable
access to this information at any time through Your Device settings.
·
Information Collected while Using the
Application: While using Our Application, in order to provide features of Our
Application, We may collect, with Your prior permission: (1) Information
regarding Your location; and (2) Pictures and other information from Your
Device's camera and photo library.
o
We use this information to provide
features of Our Service, to improve and customize Our Service. The information
may be uploaded to the Company's servers and/or a Service Provider's server or
it may be simply stored on Your device.
·
Cookies: Cookies are pieces of information
stored directly on the computer You are using.
Cookies allow Us to collect information such as browser type, time spent
utilizing the Service, pages visited, and language preferences. We, and our service providers, use the
information for security purposes, to facilitate navigation, and display
information more effectively. In
addition, We use cookies to gather statistical information about Service usage
in order to continually improve its design and functionality, understand how
individuals use it, and to assist Us with resolving questions regarding it.
You
can choose to accept or decline cookies.
Most Web browsers automatically accept cookies, but You can usually
modify Your browser settings to decline cookies if You prefer. If You would prefer not to accept cookies,
most browsers will allow You to: (i) change Your browser settings to notify You
when You receive a cookie, which lets You choose whether or not to accept it;
(ii) to disable existing cookies; or (iii) to set Your browser to automatically
reject any cookies. If You set Your
browser to reject cookies, part of the Service may not work for You.
Cookies
can be "Persistent" or "Session" Cookies. Persistent
Cookies remain on Your personal computer or mobile device when You go offline,
while Session Cookies are deleted as soon as You close Your Web browser.
·
Pixel tags, Web beacons, clear GIFs, or
other similar technologies: These may be
used in connection with some Service pages to, among other things, track the
actions of Service users and compile statistics about Service usage and
response rates.
We
permit third-party advertising partners to use the foregoing tracking
technologies to collect information about Your browsing activities over time
and across different Sites when You use the Service. For example, We use advertising services
providing by third-party ad partners, such as Google, to market our service to You
on other websites and online services.
Through a process called “retargeting,” each service places a cookie on Your
browser when You visit the Service so that they can identify You and serve You
ads on other sites around the Web based on Your browsing activity. To avoid use of this information for
advertising by these third-party ad partners, You can change Your browser
settings to reject cookies or to notify You when cookies are set and You could
select the Do Not Track option on Your browser, though We have no control over
and cannot confirm whether these third-party ad partners honor the Do Not Track
browser signal. Additionally, many
advertising companies are members of the NAI or DAA and/or provide opt-outs on
those industry pages at networkadvertising.org/choices or
aboutads.info/choices.
We
utilize Google Analytics on the Site. Google Analytics is a website analysis
service provided by Google, Inc. (“Google”). Google utilizes the data collected
to track and examine the use of this Site, to prepare reports on its activities
and share them with other Google services. Google may use the data collected to
contextualize and personalize the ads of its own advertising network. For more
information on Google’s Privacy Policy go to https://www.google.com/intl/en/policies/privacy/.
Users can opt-out of Google Analytics tracking at
https://tools/google.com/dlpage/gaoptout/.
We,
along with third-party vendors such as Google use first-party cookies (such as
the Google Analytics cookies) and third-party cookies (such as the DoubleClick
cookie) or other third-party identifiers together to compile data regarding
user interactions with ad impressions and other ad service functions as they
relate to our Site. Users can set preferences for how Google advertises to You
using the Google Ad Settings page. Alternatively, You can opt out by visiting
the Network Advertising Initiative Opt Out page or by using the Google
Analytics Opt Out Browser add on.
We
may implement applications or "widgets" from third party providers
(e.g., Facebook, Twitter, Instagram, LinkedIn, etc.) that allow interaction,
integration or content sharing with third party services. These widgets or applications may be visible
on a page you visit on our Site or may require log-in through the third party
provider’s service. The third party
providing the widget or integration may offer controls for you to manage your
interactions. Any interaction with a
third party widget or application typically allows the third party to collect
some information about you (whether through cookies, registration information
or otherwise). These third parties may
even track you when you do not interact with the widget. If you have engaged any of these third party
service providers, their respective privacy policies will govern their tracking
and collection of information. You
should review these third party policies to understand these practices.
Use
and Disclosure of Your Personal Data
The Company may use
Personal Data for the following purposes:
To
provide and maintain our Service, including to monitor
the usage of our Service.
To
manage Your Account: to manage Your registration as a user of
the Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered user.
For
the performance of a contract: the development,
compliance and undertaking of the purchase contract for the products, items, or
services You have purchased or of any other contract with Us through the
Service.
To
contact You: To contact You by email, telephone
calls, SMS, or other equivalent forms of electronic communication, such as a
mobile application's push notifications regarding updates or informative communications
related to the functionalities, products, or contracted services, including the
security updates, when necessary or reasonable for their implementation.
Additionally, We may send You information regarding our relationship with You
or regarding the Service, changes to Our terms and conditions, and policies,
and/or other administrative information
To
manage Your requests: To attend and manage Your requests to
Us.
For
business transfers: We may use Your information 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 Data held by Us about our Service users is among the assets transferred.
For
other purposes: We may use Your information for other
purposes, such as data analysis, identifying usage trends, determining the
effectiveness of our promotional campaigns and to evaluate and improve our
Service, products, services, marketing, and Your experience.
When
We otherwise have Your consent.
We may share Your Personal
Data for the following business purposes and to the following categories of
third parties:
With
Service Providers: We may share Your Personal Data with
Service Providers to monitor and analyze the use of our Service, to contact You.
For
business transfers: We may share or transfer Your Personal
Data in connection with, or during negotiations of, any merger, sale of Company
assets, financing, or acquisition of all or a portion of Our business to
another company.
With
Affiliates: We may share Your information with Our Affiliates,
in which case We will require those Affiliates to honor this Privacy Policy.
Affiliates include Our parent company and any other subsidiaries, joint venture
partners or other companies that We control or that are under common control
with Us.
With
other users: when You share Person Data or otherwise
interact in the public areas with other users, such information may be viewed
by all users and may be publicly distributed outside.
With
Your consent: We may disclose Your Personal Data for
any other purpose with Your consent.
In addition, We use and
disclose Personal Data collected through the Service as We believe to be
necessary or appropriate: (a) as permitted by applicable law, including laws
outside Your country of residence; (b) to comply with any legal process; (c) to
respond to requests from public and government authorities, including public
and government authorities outside Your country of residence; (d) to enforce
our EULA (if applicable); (e) to protect Our operations or those of any of Our Affiliates;
(f) to protect our rights, privacy, safety, or property, and/or that of our Affiliates,
You, or others; and (g) to allow Us to pursue available remedies or limit the
damages that We may sustain. We may also use and disclose Personal Data
collected through the Service in other ways, with Your prior consent.
In addition, We may use
and disclose information that is not in personally identifiable form (such as
anonymized, masked, or de-identified information) for any purpose. If We
combine information that is not in personally identifiable form with
information that is (such as combining Your name with Your geographical
location), We will treat the combined information as Personal Data as long as
it is combined.
In the preceding twelve
(12) months, We have not sold any Personal Data.
In the event that Sunless
begins selling Personal Data, this Privacy Policy will be updated to reflect
that sale and You will be notified of such update. Additionally, You will be
provided the ability to opt-out of the sale of Your Personal Data collected by Sunless
by clicking a DO NOT SELL MY PERSONAL INFORMATION link.
In
the last 12 months, We have disclosed and shared these categories of Personal
Data about consumers for a business purpose, and as further described above in
this Privacy Policy:
·
Personal identification information such
as real name, postal address, online identifier, IP address, email address, and
account number.
·
Internet or other electronic network
activity, including but not limited to, browsing history, search history, and
information regarding Your interaction with the Site.
·
Payment information such as credit card
number, debit card number, bank account number, or other financial information.
·
Geolocation information.
Sunless
and our affiliates may send you regular promotional communications about our
products, services, events and promotions. Such promotional materials may use
the “Sunless” brand and may be sent to you via different channels, such as:
email, phone, SMS text messages, postal mailings, and third party social
networks.
In
order to provide you with the best personalized experience, sometimes these
communications may be tailored to your preferences (for example, as you
indicate these to us, as we may have inferred from your Site visits, or based
on the links you click in our emails).
When required by applicable law, we will obtain your consent before
starting these activities. In addition,
you may withdraw your consent (opt-out) at any time.
In
particular, you can opt-out from receiving marketing-related emails by
following the unsubscribe instructions provided in each email. You can also contact us using the contact
details provided below to opt-out from receiving marketing-related
communications.
Please
note that even if you opt-out from receiving marketing communications, you
might still receive administrative communications from us, such as technical
updates of our products, order confirmations, notifications about your account
activities, and other important notices.
General Principles
for the Processing of Personal Data
Personal Data will be
collected, stored, processed, and transmitted in accordance with Sunless’
established policies and applicable federal, state, local and foreign laws, rules,
and regulations.
The principles of Sunless
with respect to the processing of Personal Data are as follows: (1) Personal Data will be processed fairly
and lawfully, (2) Personal Data will be collected for specified, explicit, and
legitimate purposes and not further processed for incompatible purposes, (3) Personal
Data collected by Sunless will be adequate, relevant, and limited to what is
necessary in relation to the purposes for which they are collected and
processed, (4) Personal Data collected by Sunless will be accurate and, where
necessary, kept up to date to the best of our ability, (5) Personal Data
collected by Sunless will be retained as identifiable data for no longer than
necessary to serve the purposes for which the Personal Data was collected, and
(6) Personal Data will be processed in a manner that ensures appropriate
security of the Personal Data, including protection against unauthorized or
unlawful processing and against accidental loss, destruction or damage, using
appropriate technical or organizational measures.
Third Party Sites
and Services
This Privacy Policy does
not address, and We are not responsible for, the privacy, information, or other
practices of any third parties, including any third party operating any site or
Web property (including, without limitation, any application) that is available
through the Service or to which the Service contains a link. The availability of, or inclusion of a link
to, any such site or property on this Site does not imply endorsement of it by Us
or by Our Affiliates.
Third parties may offer
products and services on the Sites and collect information about You by
requesting certain information necessary to provide a particular product or
service (including, for example, insurance coverage for Your Sunless products
or reports of insurance claims). Sunless may also obtain certain information
about its users from third party customer research groups (e.g., demographic
information) which Sunless uses to learn more about its customers. Sunless does
not control the policies and practices of third parties in relation to the use
and disclosure of any information about users collected by third parties on the
Site or in market research programs conducted by such third parties and any use
or disclosure of such information by third parties is not governed by this Privacy
Policy.
Choices and Access
We give You choices
regarding our use and disclosure of Your Personal Data. Sunless provides You
with the opportunity to receive information by email, regular mail, or
telephone calls from Sunless, or third parties which may be of interest to You,
including information relating to new products and services offered on the Site
by Sunless, or other third parties. If You
do not want to receive any information by email, regular mail, or telephone
calls, You may opt-out of further communications provided by Sunless at any
time by: (i) sending Sunless an email at appsupport@sunlessinc.com; or (ii)
writing to Sunless at Sunless, Inc., 8909 S Freeway Drive, Macedonia, OH 44056.
Please note that Sunless can only comply with requests relating to email,
regular mail or telephone communications provided by Sunless. If You no longer
wish to receive further information by email, regular mail, or telephone from
any third party, You will need to contact such third party directly to opt-out
of further communications being provided to You. We will seek to comply with Your request(s)
as soon as reasonably practicable.
If applicable, and You
would like to review, correct, update, or delete the Personal Data that You
have provided via this Site, please contact Us.
We will try to comply with Your request as soon as reasonably
practicable.
Accuracy
It is Your responsibility
to provide Sunless with accurate Personal Data.
Except as otherwise set forth in this Privacy Policy, Sunless shall only
use Personal Data in ways that are compatible with the purposes for which it
was collected or subsequently authorized by You. To the extent necessary for these purposes, Sunless
shall take reasonable steps to ensure that Personal Data is accurate, complete,
current, and relevant to its intended use.
Your Rights Over Your
Information
European Data Subjects
This privacy notice
section for European residents supplements the information contained in Our
Privacy Policy and it applies solely to all visitors, users, and others who
reside in the European Economic Area and Switzerland (“Europe”). In Europe, “Personal
Data” is defined very broadly and includes any information about a natural
person, who can be identified, directly or indirectly, from data that We hold
about them or from data that is combined with other information. Europe data
protection law requires Us to have a legal basis before processing any Personal
Data about You. The legal basis for Us
processing Your Personal Data for the above purposes may be because: (i) You
have provided Your consent; (ii) it is necessary to for the performance of a
contract with You; (iii) the processing is necessary for our compliance with a
legal obligation; or (iv) the processing is in our legitimate interests. To the
extent provided by applicable law, You may withdraw any consent You previously
provided to us, or object at any time on legitimate grounds, to the processing
of Your Personal Data. In some circumstances, withdrawing Your consent to Sunless
use or disclosure of Your Personal Data will mean that You cannot take
advantage of certain Sunless products or services.
We may transfer Your
Personal Data outside Europe to the United States or any country that Sunless
or its service providers may have operations. Such countries do not have the
same data protection laws as Europe. Any transfer of Your Personal Data will be
subject to a European Commission approved contract (as permitted under the
General Data Protection Regulation) that is designed to help safeguard Your
privacy rights and give You remedies in the unlikely event of a misuse of Your
Personal Data.
Your Rights under the
GDPR
Under the General Data
Protection Regulation, You have a number of important rights free of charge. In
summary, those include rights to:
·
Fair processing of information and
transparency over how We use Your Personal Data;
·
Access to Your Personal Data and to
certain other supplementary information that this Privacy Policy is already
designed to address;
·
Require Us to correct any mistakes in Your
Personal Data that We hold.
·
Require the erasure of Personal Data
concerning You in certain situations;
·
Receive the Personal Data concerning You
which You have provided to Us, in a structured, commonly used, and
machine-readable format and have the right to transmit that data to a third
party in certain situations;
·
Object at any time to processing of Your
Personal Data for direct marketing;
·
Object to decisions being taken by
automated means which produce legal effects concerning You or similarly
significantly affect You;
·
Object in certain other situations to our
continued processing of Your Personal Data; and
·
Otherwise restrict Our processing of Your Personal
Data in certain circumstances
For
further information on each of those rights, including the circumstances in
which they apply, see the Guidance from the UK Information Commissioner’s
Office (ICO) on individual’s rights under the General Data Protection
Regulation (or other relevant guidance).
California Data
Subjects
This privacy notice
section for California residents supplements the information contained in Our
Privacy Policy and it applies solely to all visitors, users, and others who
reside in the State of California.
The California Consumer
Privacy Acts provides California residents with specific rights regarding their
Personal Data. If You are a resident of California, You have the following
rights:
The right to notice. You
have the right to be notified which categories of Personal Data are being
collected and the purposes for which the Personal Data is being used.
The right to request.
Under CCPA, You have the right to request that We disclose information to You
about Our collection, use, sale, disclosure for business purposes and share of Personal
Data. Once We receive and confirm Your request, We will disclose to You:
·
The categories of Personal Data We
collected about You
·
The categories of sources for the Personal
Data We collected about You
·
Our business or commercial purpose for
collecting or selling that Personal Data
·
The categories of third parties with whom We
share that Personal Data
·
The specific pieces of Personal Data We
collected about You
·
If We sold Your Personal Data or disclosed
Your Personal Data for a business purpose, We will disclose to You:
o
The categories of Personal Data categories
sold
o
The categories of Personal Data categories
disclosed
The right to say no to
the sale of Personal Data (opt-out). You have the right to
direct Us to not sell Your Personal Data. To submit an opt-out request please
contact Us.
The right to delete
Personal Data. You have the right to request the deletion
of Your Personal Data, subject to certain exceptions. Once We receive and
confirm Your request, We will delete (and direct Our Service Providers to
delete) Your Personal Data from our records, unless an exception applies.
The right not to be
discriminated against. You have the right not to be discriminated
against for exercising any of Your consumer's rights
Under California Civil
Code Section 1798 (California's Shine the Light law), California residents with
an established business relationship with Us can request information once a
year about sharing their Personal Data with third parties for the third
parties' direct marketing purposes.
If You'd like to request
more information under the California Shine the Light law, and if You are a
California resident, You can contact Us using the contact information provided
below.
California Business and
Professions Code section 22581 allow California residents under the age of 18
who are registered users of online sites, services, or applications to request
and obtain removal of content or information they have publicly posted.
To request removal of
such data, and if You are a California resident, You can contact Us using the
contact information provided below, and include the email address associated
with Your account.
Be aware that Your
request does not guarantee complete or comprehensive removal of content or
information posted online and that the law may not permit or require removal in
certain circumstances.
Exercising Your
Rights
In order to exercise any
of Your rights as described herein, You may submit a verifiable consume request
to Us by either contacting Us via the contact methods provided below or by
visiting the Site.
Your request to Us must:
·
Provide sufficient information that allows
Us to reasonably verify You are the person about whom We collected Personal
Data or an authorized representative.
·
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 the required information if We cannot:
·
Verify Your identity or authority to make
the request.
·
And confirm that the Personal Data relates
to You.
Sunless will not
discriminate in any way against any users of the Site that exercise their
rights as provided by law.
Retention Period
We retain Your Personal
Data for the period necessary to fulfill the purposes outlined in this Privacy Policy
unless a longer retention period is required or allowed by law or to otherwise
fulfill a legal obligation.
Security
Sunless has implemented
security measures designed to protect Personal Data provided by You against
unauthorized access and use. Sunless also uses commercially reasonable efforts
to establish secure connections with Your Web browser. Please be aware, however,
that no data transmission over the Internet is 100% secure and any information
disclosed online can potentially be collected and use by parties other than the
intended recipient. If You have reason to believe that Your interaction with Us
is no longer secure, please immediately notify Us of the problem by contacting Us
as described in this Privacy Policy.
"Do
Not Track" Policy
Our
Service does not respond to Do Not Track signals.
However,
some third-party websites do keep track of Your browsing activities. If You are
visiting such websites, You can set Your preferences in Your Web browser to
inform websites that You do not want to be tracked. You can enable or disable Do
Not Track Requests by visiting the preferences or settings page of Your Web browser.
Children's
Privacy
Our Service does not
address anyone under the age of 13. We do not knowingly collect personally
identifiable information from anyone under the age of 13. If You are a parent
or guardian and You are aware that Your child has provided Us with Personal
Data, please contact Us. If We become aware that We have collected Personal
Data from anyone under the age of 13 without verification of parental consent, We
take steps to remove that information from Our servers.
If We need to rely on consent
as a legal basis for processing Your information and Your country requires
consent from a parent, We may require Your parent's consent before We collect
and use that information.
Compliance with
Local Laws
This Privacy Policy is
meant to guide Sunless with respect to Personal Data collected from or about You
at this Site. While this Privacy Policy
applies to Personal Data generally, the local laws, rules and regulations of
jurisdictions that are applicable to Sunless (“Local Laws”) may require
standards which are stricter than this Privacy Policy and, in such event, Sunless
will comply with applicable Local Laws.
Specific privacy policies may be adopted to address the specific privacy
requirements of particular jurisdictions. All the information You provide may
be transferred or accessed by entities around the world as described in this Privacy
Policy. Your Personal Data may be stored and processed in any country where We
have facilities or service providers, and by using our Site or by providing
consent to Us (where required by law), You specifically acknowledge and consent
to the transfer of information to countries outside of Your country of
residence, including to the United States, which may provide for different data
protection rules, and a lower standard of required protection, than in Your
country. Irrespective of which country Your Personal Data is transferred, We would
only share Your Personal Data under a ‘need to know’ basis. In these circumstances We will, as required
by applicable law, ensure that Your privacy rights are adequately protected by
organizational, technical, contractual and/or other lawful means.
Your Right to
Complain
If You have a complaint
as to our use of Your information, You may file a complaint with us, the
California Attorney General, the applicable Supervisory Authority, any other
governmental agency, and/or a judicial body.
A complaint may be
submitted directly to Sunless through the contact methods presented below.
Contact Us
If You have any questions
about this Privacy Policy, You can contact us:
·
By email: AppSupport@sunlessinc.com
·
By phone: 440-836-0199
·
By mail: Sunless, Inc., 8909 S Freeway
Drive, Macedonia, OH 44056