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 TWO SCENTS LLC PRIVACY POLICY

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(Last updated May 25, 2020)

  1. Overview
  2. Acceptance And Use
  3. Data Protection Principles
  4. Personal Information We Collect About You (PIPEDA)
  5. Types Of Data We Collect From You
  6. Non-Personal Information
  7. Information Collected Through Technology
  8. Payment Processor
  9. Other Information You May Submit
  10. Automatically-Collected Information
  11. Information We Collect From You Automatically
  12. How We Use Your Data
  13. Remarketing On The Website And Services
  14. Google Adwords
  15. With Whom We Share Your Data
  16. Do Not Track
  17. Interest-Based Advertising Technologies
  18. Data Retention
  19. EEA Data Subjects
  20. Your Privacy Choices
  21. Our COPPA Policy Towards Children
  22. California Online Privacy Protection Act Compliance
  23. Cross Border Transfers
  24. Data Transferred Out Of The EU
  25. Privacy Shield
  26. Legal Bases For Processing (For EEA Users)
  27. Security Measures For Safeguarding Your Information
  28. Third-Party Site And Links
  29. California / Delaware Do Not Track Disclosures
  30. E-Mails Communications
  31. Data Security
  32. GDPR Statement For (EEA Users)
  33. GDPR Data Privacy User Rights
  34. Your Right To Withdraw Consent
  35. Opting Out Of Messages From Us
  36. Opting Out Of Sharing With Third Parties For Marketing
  37. Opting Out Of Interest-Based Advertising
  38. Security And Personal Information
  39. Changes to our Privacy Policy
  40. Terms and Conditions
  41. Contact Us

 

  1. Overview

Welcome to Two Scents LLC website Privacy Statement page

This Privacy Policy and statement is created to explain to you how we (twoscents.com) collect your data, how we process them, how we secure them, how we might share them as regards to our services and how we store them. This Privacy Statements also describe what right you have as regards to your personal data, how you give your consent and how you withdraw your consent. If you are user who resides in the European Union Region, we also explain what right you have as a data subject.

Please endeavor to read through this privacy policy page, to understand your right as a data subject, and the basis of collecting your personal information.

 

  1. Acceptance And Use

This privacy policy covers Two Scents LLC and its subsidiaries, including (collectively, "Two Scents LLC,Twoscents we, us, or our). We provide 100% pure, therapeutic grade essential oils, with no fillers or carrier oils. Every product we sell is free of harsh chemicals and we refuse any product that has been tested on animals. 

By using our website, you signify acceptance to the terms of this Privacy Policy. When you click the accept button on the site, this is considered as your official consent to process your personal information, your consent to the collection, use, and disclosure of your personal information as described further below. We may request you to provide additional disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with other choices about how we process your data. 

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of the Two Scents LLC website and its related services.

 

  1. Data Protection Principles

Personal data means any information that enables us to identify you, directly or indirectly, such as name, e-mail, address, telephone number, any form of identification number, or one or more factors specific to you or your beneficiary's identity.

We are committed to complying with applicable data protection laws and will ensure that personal data is:

  • Used lawfully, fairly and in a transparent way;
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • Relevant to the purposes we have told you about and limited only to those purposes;
  • Accurate and kept up to date;
  • Kept only as long as necessary for the purposes we have told you about;

 

  1. Personal Information We Collect About You (PIPEDA)

According to the Canadian federal personal information protection and electronic documents act, 2000 (PIPEDA), "personal information" means information about an identifiable individual. The information you provide to us is considered personally identifiable information, which may include your name, address, e-mail address, telephone number, and any other information that can identify you. If PII cannot be related to an individual, it is considered anonymous. Whenever possible, Two Scents LLC works with anonymous information. This privacy statement does not apply to anonymous information.

 

  1. Types Of Data We Collect From You
  1. Personal Identifiable Information (PII). We acquire PII from you when you sign up for a customer account and also when you place a purchase. These may include, in specific contexts, your Full name, business name, gender, phone number, home address, and e-mail address.
  2. Financial Information: Bank account information, payment card primary account number (PAN), transaction history, and tax identification.
  3. Sensitive PII: Information about the transactions you make on our Services, such as the names, mobile number, e-mail address, and other information about the directly connected accounts to your account, which are attracted to our service by you.
  4. Correspondence: Survey responses, the information provided to our support team or user research team.

 

  1. Non-Personal Information

Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g., demographic information or web site visitations). Two Scents LLC may collect non-personal information through any of the methods discussed above, as well as automatically through the use of industry-standard technologies described further below.

 

  1. Information Collected Through Technology

While you visit the Two Scents LLC site and decide not to register for a user account. The Two Scents LLC or its third-party service providers may still collect non-personal information about your use of the website (e.g., Your internet browser, operating system, IP address, connection speed, and the domain name of your internet service provider). The following methods may gather such information:

  • Cookies, including local shared objects, are small pieces of information that are stored by your browser on your device's hard drive, which works by assigning to your computer a unique number that has no meaning outside of the Two Scents LLC site. Cookies do not generally contain any personal information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not taking cookies may make certain features of the Two Scents LLC materials unavailable to you.
  • IP address. You may visit many areas of the Two Scents LLC site anonymously without the need to become a registered user. Even in such cases, Two Scents LLC may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an internet services provider. Each time you access the Two Scents LLC site and each time you request one of Two Scents LLC pages, the server logs your IP address.
  • Beacons. Beacons are small pieces of data embedded in web pages and e-mails. Two Scents LLC may use these technical methods in html e-mails that Two Scents LLC sends to users to determine whether they have opened those e-mails or clicked on links in those e-mails.

 

  1. Payment Processor 

Payments made on the Two Scents LLC website and platform are not collected by us but through our designated payment gateway provider. You will be providing credit or debit card information directly to them who operate a secure server to process payment details, encrypting your credit/debit card information, and authorizing payment. The information which you supply to our payment provider is not within our control and is subject to their privacy policy and terms and conditions. 

Note your payment card details are not shared with Two Scents LLC by the provider

 

  1. Other Information You May Submit

You may submit data to us for limited purposes such as requesting customer support, answering a questionnaire, participating in a study, entering contests or sweepstakes, or signing up to receive communications from us.

 

  1. Automatically-Collected Information

We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, and necessary device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your movements using cookies and similar technologies. By using our services, you agree to our use of these methods as outlined in our cookie policy.

 

  1. Information We Collect From You Automatically

We receive and store certain types of information automatically, such as whenever you interact with or use the Two Scents LLC website. This information helps us address customer support issues, improve the performance of the Two Scents LLC website, providing you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

  • Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name, and version, or personal IP addresses.
  • Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs:

  • How you came to and used the Two Scents LLC website;
  • Device type and unique device identification numbers;
  • The pages and products you viewed
  • The products you eventually purchased on the web shop
  • Device event information (such as crashes, system activity, and hardware settings, browser type, browser language, the date and time of your request and referral URL);
  • How your device interacts with Two Scents LLC website and Services, including pages accessed and links clicked;
  • Broad geographic location (e.g., country or city-level area); and
  • Other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our website via an external link, such as a link appearing on a third party site

 

  1. How We Use Your Data

We may use your data for the following purposes: 

  • Identification and authentication: we use your data to verify and process when you place an order.
  • Communicating with you: we use your data when we communicate with you (e.g., when we respond to customer support or other inquiry).
  • Improving our services: we use your data to understand how you use our services and how we can improve them. In general, we analyze aggregated data rather than specific user data. We may, however, need to analyze a particular case to address a problem (e.g., a bug that affects only a few accounts).
  • Customizing your experience: we use your data to personalize the service to you. May include remembering your preferences for language or volume or displaying site that you might enjoy, based upon your viewing choices.
  • To ensure network and data security: We process your personal information to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks, and to comply with applicable security laws and regulations. The threat landscape on the internet is continuously evolving, which makes it more critical than ever that we have accurate and up-to-date information about your use of Two Scents LLC Services.
  • Marketing and advertising: we use your data to display ads and send you offers. We may also use your data in delivering third-party advertisements to you. These may include "targeted ads" based upon your activities.
  • Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our terms of service.
  • Legal compliance: we use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.
  • Protecting your information: where appropriate, we may anonymize, backup, and delete specific data.
  • For research and development: We process your personal information to understand better the way you use and interact with Two Scents LLC Services. Also, we use such information to customize and improve Two Scents LLC features and the content and layout of our site and applications, and to develop new services. 

We may use algorithms and other automated means to implement any of the above.

 

  1. Remarketing On The Website And Services 

If you have provided your consent by accepting Targeting Cookies on the site, we may use Google AdWords (remarketing and Similar Audience features) and Facebook Ads. You can review the Two Scents LLC cookie policy, which includes details on how to customize your cookie settings.

 

  1. Google Adwords 

Google AdWords enables Google, through the use of cookies, to identify the fact that you have visited the website, to identify aspects of your usage of the site, and combine that with what it knows about your usage of another website in the Google ad network.

We use these services to advertise to visitors of Google ad network Apps who have previously visited our website or who Google deems to have shared interests with visitors to our website. The Google privacy policy covers Google's collection and use of your personal data. You can set preferences for how Google advertises to you using the Google Ad Preferences page.

 

  1. With Whom We Share Your Data

We share data with third parties as follows: With your consent, we may share your data with third parties where we have obtained your express permission to do so. You may revoke these consents. 

  • Authorized vendors: We may share your data with third-party vendors that help us operate our website, process payments, and comply with your instructions and our contractual obligations. These include payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, e-mail service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM), vendors
  • Advertising: We may share your data with advertising companies to display relevant ads to you. Unless you expressly agree, we will not share or sell your name, e-mail address, or physical address with such persons.
  • Analytics: We may share your data with persons who provide analytics showing how customers are using our services.
  • Affiliates and advisors: We may share your data with our affiliates company and our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. Unless you expressly agree, we will not share your data with our parent or any affiliate for other purposes, such as direct marketing.
  • Certain legal situations: we may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction.

 

  1. Do Not Track 

Do Not Track ("DNT") is a privacy preference that users can set in specific web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

  1. Interest-Based Advertising Technologies 

As noted above, you may limit advertising tracking using advertising identifiers through your device's privacy settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and http://www.aboutads.info/choices/.

 

  1. Data Retention

We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may keep logs of automatically collected information (for internal analytics); your e-mail address, your tax information; communications with you; and your transactional information (for auditing, tax, and commercial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

If we receive legal process about your account, we will retain your data for as long as we in good faith believe it is necessary to comply with the legal process.

 

  1. EEA Data Subjects

Legal Bases for Processing your Information:

For individuals who reside in the European Economic Area, the United Kingdom or Switzerland (collectively "EEA Residents"). At the time their data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation ("GDPR"). We generally only process your data where we are required to, where the processing is necessary to perform any contracts we entered with you (or to take steps at your request before entering into a contract with you). For our legitimate interests to operate our business or to protect the Two Scents LLC site or your property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal bases for processing.

 

  1. Your Privacy Choices 

We enable you to make numerous choices about your data: 

  • You may choose not to provide us with certain information. For example, you may decide not to create an account or not place an order on our website.
  • You may change your account and privacy settings. You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
  • You may opt-out of receiving commercial e-mails from us.
  • You may limit the use of cookies. See our cookie policy for options.
  • You may close your account
  • Users from certain countries may have additional rights.

 

  1. Our COPPA Policy Towards Children 

Two Scents LLC complies with both the Children's Online Privacy Protection Act of 1998 (COPPA) and, concerning EU data subjects, with GDPR. We do not knowingly request to collect personal information required for the Two Scents LLC user account from any person under the age of 18.

Please notify us if you know of any individuals under the age of 18 using our website so we can take action to prevent access to our Services.

 

  1. California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.

As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at any time by sending us a message. Please see our CCPA Page for more info

 

  1. Cross Border Transfers 

To facilitate our global operations, Two Scents LLC may transfer, store, and process your information within our family of companies, partners, and service providers based throughout the world. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with Two Scents LLC, you acknowledge and agree to process your personal information in this way.

If you have a complaint about our privacy practices and our collection, use, or disclosure of personal information, please submit your request via any of Two Scents LLC provided Contact Us mediums.

 

  1. Data Transfer

Two Scents LLC is the publisher of the website and confirms its compliance with the EU-US Privacy Shield Framework. We are committed to subjecting all personal information received from the European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov. Two Scents LLC does its best to process personal information it receives under the standards of Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Before, we share your information with any third party. The Two Scents LLC will enter into a written agreement that the third party provides at least the same level of privacy safeguard as required under those Frameworks, and assures the same level of protection for the personal information as required under applicable data protection laws.

Worldwide data subjects with inquiries or complaints relating to Two Scents LLC Privacy Shield internal policy should first contact Two Scents LLC by filling the CONTACT US form provided in and twoscents.com. If we are unable to resolve your complaint or dispute, you may refer your complaint to our designated independent dispute resolution mechanism, i.e., the International Centre for Dispute Resolution ("ICDR").

 

  1. Privacy Shield

Two Scents LLC adheres to the seven privacy shield principles of notice, choice, and accountability for onward transfer, security, data integrity, access, and recourse, enforcement, and liability as they relate to personal data. Two Scents LLC verifies compliance with the Principles through self-assessment. The privacy policy covering human resources data can be accessed on our intranet site by all employees.

 

  1. Legal Bases For Processing (For EEA Users)

If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws.  The legal bases depend on the services you use and how you use them. These means we collect and use your information only where:

  • We need it to provide you the services, including to operate the process your orders, provide customer support and personalized features and to protect the safety and security of the services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.  Where we are using your information because a third party (e.g. your employer) or we have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services

 

  1. Security Measures For Safeguarding Your Information

Two Scents LLC takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of personal information. These include, but are not limited to, internal reviews of (a) Two Scents LLC data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Two Scents LLC stores personal information.

 

  1. Third-Party Site And Links

The Two Scents LLC contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Two Scents LLC may use third parties to provide components of the Two Scents LLC contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of Two Scents LLC. Two Scents LLC: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such site, and (c) does not make any warranties or representations about the materials, products or services offered on such website or the security of any information you provide to them

 

  1. California / Delaware Do Not Track Disclosures 

Various third parties have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party web sites or online services (e.g., browser do not track signals).  Currently, Two Scents LLC do not monitor or take any action concerning these signals or other mechanisms.

 

  1. E-mails Communications

By creating an account, you consent to receive commercial e-mails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt-out or opt-in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process, and you will continue to receive transactional e-mails from us (e.g., e-mails confirming transactions or providing information about your account).

 

  1. Data Security

We are committed to maintaining the security of your data. And have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we regularly upgrade our security as better methods become available.

Our data centers and those of our partners utilize new physical security measures to prevent unauthorized access to the facility. Also, all personal data protected in a location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access. 

Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry-standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.

 

  1. GDPR Statement For (EEA Users) 

These apply only to natural persons residing in the European economic area (for this section only, "you" or "you're" shall be limited accordingly). It is Two Scents LLC policy to comply with the EU'S general data protection regulation (GDPR). Following the GDPR, we may transfer your personal information from your home country to the United States (or other countries) based upon the following legal frameworks:

  • Legitimate business interests: We could not provide our services or comply with our obligations to you without transferring your personal information to the United States
  • Consent: we may transfer your personal information when we receive your express, revocable consent.
  • You have the right to opt-out of non-essential cookies (see our cookie policy) access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data, and withdraw consents.

We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfill our obligations in response to direct requests. We will endeavor to process applications within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they impose an unreasonable cost on us.

If you have a request, complaint, or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

 

  1. GDPR Data Privacy User Rights

If you are an EU resident and Two Scents LLC is processing, or transmitting your data, then you - as an "EU data subject" – benefit from the following rights and privileges under the General Data Protection Regulation (GDPR):

  • Right of Access
  • Right to rectification.
  •  Right to erase your data:
  • Right to Data Portability
  • Right to Restrict the Processing of your data
  • Right to Object

 

  1. Your Right To Withdraw Consent 

You have the right to withdraw your consent without detriment at any time by contacting us Sales@twoscents.com. You can also change your marketing preferences. If we do not satisfactorily resolve your request or concern, you may contact our data protection officer; his e-mail is Sales@twoscents.com

 

  1. Opting Out Of Messages From Us

To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message sent to you (found at the bottom of the e-mail) or send an unsubscribe request to us at Sales@twoscents.com. We will process your request within a reasonable time after receipt.

 

  1. Opting Out Of Sharing With Third Parties For Marketing

If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an e-mail to Sales@twoscents.com. Please note that if you will opt-out in this manner, certain aspects of the website and platform may no longer be available to you. We will process your request within a reasonable time after receipt.

 

  1. Opting Out Of Interest-Based Advertising 

The online advertising industry provides a service through which you may opt-out of receiving targeted ads from individual data partners and other advertising partners that participate in self-regulatory programs. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance ("EDAA").

 

  1. Security And Personal Information

The site uses the best methods to store and secure all Personal Information on servers with restricted access and electronic security technologies. Not to withstand the preceding, the website cannot guarantee that such precautions would render the site and its servers immune to security breaches.

 

  1. Changes To our Privacy Policy 

Two Scents LLC continually strives to implement new technologies and processes to protect you better, your privacy, and your use of the Two Scents LLC service. As a result, changes to this privacy policy may be made by Two Scents LLC from time to time. In no event will these changes result in the degradation of any of the security measures designed to protect you from unauthorized disclosure.

 

  1. Terms and Conditions 

To learn more about our terms and conditions, please visit our Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of our website

 

  1. Contact Us

If you have any questions about this privacy policy, please contact us at Sales@twoscents.com