This policy was last updated on December 29th 2018
Thank you for visiting www.refreshbotanicals.com, which is part of the Swift Innovations Inc. family of brands and brand sites. We place great value on honesty and clarity and we are committed to building a strong and lasting relationship with our consumers based on trust and mutual benefit.
As part of this commitment, we have created this policy to provide you with information about how we collect, use, share and protect information collected from our sites, mobile applications and social media pages (collectively called the “sites”), when you shop in our website or when you otherwise interact with us. By providing us with your personal information you agree to the terms of this policy.
This policy does not apply to job applicants. If you submit a job application through the sites, your personal information will be governed by a separate policy located on career page.
WHAT IS PERSONAL INFORMATION?
“Personal Information” means any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. through pseudonymized data such as a unique id number). In other words, personal data includes things like email/home addresses/mobile phone, usernames, profile pictures, personal preferences and shopping habits, user generated content, financial information, and welfare information. It could also include unique numerical identifiers like your computer’s ip address or your mobile device’s mac address, as well as cookies.
Personal information does not include anonymous or aggregated information that cannot be tracked back to you personally.
WHAT INFORMATION DOES REFRESH BOTANICALS COLLECT FROM ME?
We may collect information that you provide to us directly, information automatically collected and information from third parties. We may combine information that we collect via one method (e.g., a website, our digital advertising) with information that we have collected via another method (e.g., an offline event). We do this to get a more complete view of our consumers, which, in turn, allows us to serve you better and allow for more customization.
If you submit any personal information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.
* INFORMATION THAT I PROVIDE DIRECTLY
If you register on a site, make purchases through our website, join a loyalty program, enter a contest or promotion, submit a consumer survey, photo, video or product review, sign up to receive emails or other offers or communications, we collect and store the information provided, including personal information.
We may also offer you the opportunity to engage with our content through third party social media platforms. Refresh Botanicals use of social media serves as an extension of its presence on the internet. Social media account(s) are public and are not hosted on Refresh Botanicals servers. Users who choose to interact with Refresh Botanicals via social media should read the terms of service and privacy policies of these platforms. Please remember that any content submitted to one of our social media platforms can be viewed by the public, so you should be cautious about providing certain personal data e.g. financial information or address details. Refresh Botanicals is not responsible for any harm that results due to posting personal data on one of our social media platforms.
When you engage with Refresh Botanicals through social media, you may allow us to have access to certain information associated with your social media account (e.g. name, username, e-mail address, picture). We may use this information to confirm your identity and to personalize your experience.
* Information that is collected automatically
Site Usage Information :
Refresh Botanicals and its third–party service providers may also use a variety of technologies that passively or automatically collect information about how the sites are accessed and used including but not limited to your browser type, device type, operating system, application version, the pages served to you, the time you browse, preceding page views, and your use of features or applications on the sites.
Device Identifiers :
Refresh Botanicals also automatically collects an IP address or other unique identifier information (“device identifier”) for the computer, mobile device, technology or other device (collectively, “device”) you use to access the sites or on third party websites that publish our advertising. A device identifier is a number that is automatically assigned to your device by the device provider when you access a web site or its servers, and our computers identify your device by its device identifier. For mobile devices, a device identifier is a unique string of numbers and letters stored on your mobile device that identifies it. We may use a device identifier to, among other things, administer the sites, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your shopping cart, deliver advertising and gather broad demographic information.
WHERE DOES REFRESH BOTANICALS STORE MY PERSONAL INFORMATION?
Personal information about you may be maintained and processed on our behalf by our affiliates and other third party service providers inside and outside of Canada including but not limited to the United States. Your personal information may be subject to the laws of the countries in which it is stored or used, and those countries may have a different data protection regime than the country in which you reside and under the laws of those other countries, in certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information. By providing us with any personal information, you consent to the transfer of your personal information to other countries, such as the United Sstates, which may have a different privacy regime from your country of residence.
HOW DOES REFRESH BOTANICALS USE MY INFORMATION?
Unless otherwise permitted or required by law, Refresh Botanicals shall make reasonable efforts to only collect personal information that is necessary in the following contexts and for the associated purposes:
|Account creation and management||Manage your orders, promotions, surveys or contests you choose to enter; offer you a loyalty program or personalized services based on your beauty characteristics; and allow you to manage your preferences and enrich your profile.|
|Newsletter sign up and commercial communications||Send you marketing communications that may be tailored to your “profile” and keep an up-to-date opt-out list if you have asked not to be contacted.|
|Purchases and order management||Contact you to finalize your order where you have saved your shopping cart or placed products in your cart without completing the checkout process; inform you when a product you wanted to purchase is available; process and follow up on your order including delivering the product to an address you provided; assist you with the payment for your order or the return of a product you previously purchased; measure satisfaction; and manage any dispute relating to a purchase.|
|Consumer care based on inquiries or shared experiences||Respond to your questions and otherwise interact with you or connect you with relevant services|
|Profiling and behavioral advertising||To send or display personalized communications or content tailored to your interests/needs|
|User generated content||To post your review or content to promote our products if you have consented to such publication, or in accordance with the specific terms and conditions accepted by you.|
|Use of apps and devices||To provide you with the products or services requested, including skin/hair advice and notifications; for research and innovation by scientists within Swift Innovations group; and for monitoring and improvement of our apps and devices.|
|Safety and security||Protect you and us against fraud, and to meet legal or regulatory requirements imposed upon Refresh Botanicals from time to time.|
WHY DID I RECEIVE A MARKETING EMAIL AFTER I MADE A PURCHASE ON REFRESH BOTANICALS WEBSITE?
To provide you with a seamless customer experience, we keep records of all your transactions with our brands. We may use information about your purchases to email you about other products and services that we believe may be of interest to you.
HOW DOES REFRESH BOTANICALS SHARE MY PERSONAL INFORMATION?
* With the family of SWIFT INNOVATIONS brands :
When personal information is collected by Refresh Botanicals, we may share that information with our affiliates and other Swift innovations brands.
* With the public when the information is on public forums :
You may disclose personal information when you post content to our websites, or other public forums, such as our brands’ media pages, blogs and online product reviews. Any information that you disclose through these services will become public.
*WITH THIRD PARTIES PROVIDING SERVICES ON BEHALF OF REFRESH BOTANICALS:
We share your personal information with third parties that perform functions on our behalf (or on behalf of our partners) such as service providers that host or operate our sites, provide analytics and site usage information, process transactions and payments, fulfill orders or provide customer service, loyalty program administration, redemption; advertisers; sponsors or other third parties that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance.
* WITH THIRD PARTIES TO WHOM YOU HAVE PROVIDED CONSENT :
* FOR BUSINESS TRANSFERS:
We may share information with other entities and affiliates of the Swift Innovations group, our parent company, on a need-to-know basis to prevent fraud, for research and innovation, to improve our products and services, for internal audit, management, promotional or administrative purposes including defending and bringing legal actions.
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, or assets related to the sites, personal information, usage information, and any other information that we have collected may be disclosed to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
* WHEN LEGAL DISCLOSURE IS REQUIRED:
We may transfer and disclose information, including your personal information, usage information and device identifier, (including IP address), to third parties to comply with a legal obligation or when we believe, upon reasonable grounds, the disclosure is necessary to protect the rights or safety of an identifiable person or group.
* TO PROCESS OR STORE THE INFORMATION IN A FOREIGN JURISDICTION:
Your personal information may be transferred to a foreign jurisdiction to be processed or stored by Refresh Botanicals or Swift Innovations or its service providers, including data hosting providers. Such information may be provided to law enforcement or national security authorities of that jurisdiction upon request, in order to comply with foreign laws.
*WHAT ABOUT LINKS TO OTHER WEBSITES?
WHAT ARE MY RIGHTS AND CHOICES REGARDING MY PERSONAL INFORMATION?
You can opt out from receiving promotional communications
Swift Innovations and its brands want to communicate with you only if you want to hear from us so we will only send you promotional communications if you’ve requested them. If at a later date you prefer not to receive promotional information, such as information about special offers and sales events, from one or more of our brands, you can let us know by contacting our customer service as described in the section entitled, “Contact us“, or you can follow the “unsubscribe” link provided in promotional emails or text messages sent to you.
If you unsubscribe from promotional communications from a brand, you may continue to receive transactional and account-related messages from the brand and promotional communications from the other brands you have not unsubscribed to.
- You have the right to be informed
- You have the right to obtain clear, transparent and easily understandable information about how we use your personal information and your rights (subject to applicable legal restrictions). This is why we are providing you with the information in this policy.
- You can ask that your Personal Information be changed or deleted
- You have the right to have your personal data rectified if it successfully proven to be incorrect or outdated and/or completed if it is incomplete.
HOW LONG DOES REFRESH BOTANICALS STORE MY PERSONAL INFORMATION FOR?
Refresh Botanicals retains personal information only as long as it is deemed necessary, to fulfill the purposes identified or as required by law. Keep in mind that the retention period for personal information may extend beyond your relationship with us. We use the following criteria to determine retention periods:
- where you purchase products and services or participate in a promotional offer, we keep your personal information for the duration of our contractual relationship with you;
- where you contact us for an enquiry, we keep your personal data for the duration needed to process your enquiry;
- where you create an account, we keep your personal information until you require us to delete it or after a period of inactivity;
- where you have consented to direct marketing, we keep your personal data until you unsubscribe or require us to delete your information; and
- where cookies are placed on your computer, we keep them for as long as necessary to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session id cookies).
Personal information no longer necessary or relevant for the identified purposes or no longer required to be retained by law, shall be securely destroyed, erased or made anonymous.
DOES REFRESH BOTANICALS PROTECT CHILDREN’S PRIVACY?
Refresh Botanicals takes seriously its obligations under the US CHILDREN’S ONLINE PRIVACY PROTECTION ACT and QUEBEC’S CONSUMER PROTECTION ACT. The sites are not directed to children under 13. We do not knowingly collect, use or disclose personally identifiable information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her personal information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
We strongly recommend that minors 13 years of age or older ask their parents for permission before sending any information about themselves to anyone over the internet and we encourage parents to teach their children about safe internet use practices.
IS MY PERSONAL INFORMATION SECURE?
Refresh Botanicals maintains reasonable safeguards to protect personal information against loss, theft, unauthorized use, disclosure, copying or destruction and when transferring information for processing and requires third parties providing services on our behalf to do the same.
No method of transmitting or storing data is 100% secure. As a result, although we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us through or in connection with Refresh Botanicals website. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem in order for Refresh Botanicals to resolve the issue in a timely manner.
IS MY PERSONAL INFORMATION PROCESSED ONLY IN CANADA?
The sites are governed by and operated in, and in accordance with the laws of Canada, and are intended for the enjoyment of residents of Canada. Country or region specific web sites may be available for Refresh Botanicals or Swift Innovations brands and products around the world. Refresh Botanicals makes no representation that the sites are governed by or operated in accordance with the laws of any other nation. By using the sites, or providing us with any information, you (a) acknowledge that the sites are subject to the laws of Canada, (b) consent to the collection, processing, maintenance and transfer of such information in and to Canada and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.
WILL THIS POLICY BE UPDATED AND IF SO, HOW WILL I KNOW?
We may change information on the sites and/or this policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised policy on the sites. Refresh Botanicals will use your personal information in a manner consistent with the policy in effect at the time you submitted the information, unless you consent to the new or revised policy. We encourage you to periodically review this page for the latest information on our privacy practices. You can tell if the policy has changed by checking the revision date that appears at the top of this policy.