Privacy Policy - Sunbliss Superfood®

This privacy policy describes how Sunbliss Superfood, LTD. ( “Sunbliss”, ‘we’, ‘us’) collects, processes, discloses, and protects personal information about you when you access or use our website located at Sunblisssuperfood.com (“Site”), and in relation to any services we provide, including but not limited to the online shop, video purchases, event and course registrations, mailing list and newsletter administration, social media presence, consultant certification processes, and our certified consultants’ portal and other consultant platforms and services (collectively, “Services”), as well as your rights in relation to your personal information. As used in this policy, personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, as well as a combination of pieces of
information that could reasonably allow you or your household to be identified.

Collection of Personal Information

1.1 Types of Personal Information We Collect

In relation to our Site and Services, we may collect personal information of the types described below, depending upon how you interact with us:

For online shop customers:

Identifiers, such as your name, username and account password if you create an account, home and/or mailing address, email address, unique online identifiers, IP address
Additional Customer Records Information, which may include your telephone number, credit card, or financial account information
Commercial information about you, such as records of products or services you purchased, considered, or consumed
Internet or other network activity information, such as online browsing or search history, or information about your interaction with our website, apps, advertisements, or social media, as described in more detail below
Profile information, reflecting your preferences, feedback, opinions, characteristics, behavior, and attitudes, including inferences drawn from the above categories of collected information.

For those visiting our Site, receiving or interacting with our digital marketing (including mailing list/newsletter recipients, those entering contests or giveaways, those receiving services from our subject matter expert contractors)

Identifiers, such as your name, email address, address, unique online identifiers, IP address, your home photos to the extent they identify you or your household in particular
Commercial information about you, such as records of products or services you purchased, considered, or consumed
Internet or other network activity information, if you interact with us online, such as online browsing or search history, or information about your interaction with our website, apps, advertisements, or social media, as described in more detail below

1.2 Sources of Collection

We may collect personal information about you from a variety of sources, including: (a) information we collect directly from you, (b) information we collect automatically, and (c) information we collect from other sources, all as described in more detail below.

Information we collect directly from you. We collect information you provide directly to us, such as when you fill out a form, post a forum comment, register for an event, or otherwise submit, send, or provide your information to us yourself.
Information we collect automatically. When you access or use our Site or interact with our advertising, marketing, social media, or other online features of our Services, we systematically collect standard information using various technologies. When you visit our Site, we collect information related to your access and use of the Site and the device you used to access the Site, such as the type and version of your browser and operating system, hardware model, mobile network information, access times and dates, pages viewed, the referrer page from which you linked to our Site, and your IP address. We (and our service providers and other third parties) may also use technologies like cookies (small data files related to your site visit that are stored on your hard drive or in device memory) and web beacons/pixel tags (embedded electronic images that help deliver cookies and detect or measure events) to automatically collect information about your interaction with our Site, marketing, or social media. For more information on service providers and third parties with whom we share information in this way, see Section 3 on Information Sharing, below. For more information on Cookies and how they are used on the Site, please see the (insert link to our Cookie Policy).
Information we collect from other sources. In connection with some of our Services, a third-party provides us your information or access to your information. For example:
Third-party service providers, platforms and tools: We use or make available to you certain third-party services, platforms and tools to provide certain of our Services, such as communications, collaboration, registration, shopping and payment processing. These third-party providers may collect on our behalf and provide your personal information to us, or may permit us to access it as administrators from their platforms.
Third-party business partnerships: In connection with certain business partnerships, such partners may provide us with the contact information of their users or members, subject to their terms with you. If your information was provided to us by a partner and you no longer wish to receive communications or marketing from us, you may use our available processes to opt-out.

How we use your personal information and the basis on which we use it

For our business and commercial purposes.
In the course of providing our Site and Services, we collect and use your personal information for the following business and commercial purposes:

To provide our Services or complete purchases or transactions you have initiated: For online shop customers, we use information you provide to fulfill and deliver your order.
To process payments for your orders and refunds: For online shop customers, we use your information to process your payment and any refunds.
To authenticate your identity: We may use your collected information to recognize you when you re-visit our Site or validate your identity when you log in to our online shop.
To manage the accounts you hold with us: We may use your collected information to manage your accounts with us, such as associating your orders with your account or assisting you with password resets.
To moderate and administer third-party platform services: We may use your collected information to moderate activity and administer certain communications and collaboration platforms that we make available to you, such as our CRM Platform (MailChimp).
To communicate with you about transactions with us: We may use the contact information you provide to send you status or updates regarding transactions you conduct with us.
To communicate content and marketing messages to you: We may use your email address to deliver our newsletter content when you have signed up to receive it, and your email address, phone number, browser cookies or tags, contest entry, or other contact information to send or show you marketing messages or offers for Sunbliss Services via direct mail, on-site personalization, or targeted advertising on third-party sites, each subject to your consent, opt-out, or unsubscribe options under applicable laws;
To create segments for our marketing messages: We may use information about your past purchases or interactions with us, your email address, and/or information about your interaction with our Site, marketing materials, or social media captured via cookies and tags to categorize you into groups or segments based on your likely preferences or interests for the purposes of directing more relevant marketing to you, subject to your consent where required, or opt-out options under applicable laws.
To provide you relevant information from our third-party and marketing partners: We may use or disclose your email address or other contact information, subject to your consent or opt-out options under applicable laws, to provide you with information or permit marketing to you regarding relevant products or services of our third-party partners.
To resolve your inquiries and requests: We use your contact information and the content of your communication to us to resolve your inquiries, requests, or any complaints or errors in the function of our Site or Services.
To solicit your feedback and opinions: We may use your contact information and information about your past interactions with us and/or our marketing materials to Invite you to take part in our internal customer surveys, questionnaires, evaluations, and other market research activities, to solicit feedback about our marketing, Site, and product/services offerings, or to invite you to provide reviews.
To improve our Site, Services, and marketing: We use information about your use of our Site and Services, your interaction with our marketing and social media, as well as your feedback to analyze, evaluate and make improvements to our product and Services offerings, our Site, including content and functionality, and to assess the effectiveness of our marketing.
To comply with legal obligations: We may use your information as necessary to comply with obligations we have under applicable laws to compile, maintain, and file required records or reports, to cooperate with regulators or law enforcement agencies as to official investigations, or to respond to legal processes.
To exercise or protect our rights: We may use your information to exercise or protect our legal rights, such as prosecuting or defending against intellectual property (copyright, trademark, patent, trade secret, counterfeiting) actions, fraud claims, or violations of our or third parties’ terms and conditions.
To protect Sunbliss, you, or others: We may use your information to protect against harm to rights and safety, including detecting and mitigating internet scams, identity theft or the like, or to communicate with you about warranty information or product safety recalls, or otherwise to combat fraud or counterfeiting.
Non-Personal Information Use: In addition to the above uses for your personal information, we may aggregate and anonymize or de-identify any information collected about you in relation to the Site or Services, so that it is not identifiable to any individual consumer or household, and we may use that non-personal information for any purpose.

Legal basis
In the European Union, we must have a legal basis to process your personal information. We process your personal information for the purposes described above, under the following legal bases:

To fulfill our contractual obligations to you, including using contact information, usernames and passwords, authentication information, payment information, site activity and other related information necessary to provide the Services or goods you requested or ordered, to ensure that items are delivered to the appropriate addresses and invoices are paid correctly, to certify you as a Consultant, and to permit you to access videos you purchased and access and use the features of the Consultant portal and program, as applicable. Failure to provide certain information that is required or necessary for the performance of our contractual obligations to you may prevent or delay our fulfilment of these obligations, and we will inform you of the consequences of failure to provide required information.
To meet our legitimate interests as a business, including our need to operate and offer our products and services, and to understand and analyze how you and other consumers use our products and services, which allows us to improve, develop and provide new or better products and services, available in the proper quantities and locations. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests do not override your fundamental privacy rights and freedoms.
On the basis of your consent – we may obtain your consent, when we are required by law to do so, in order to collect and use certain types of personal information, including in relation to our direct marketing activities, non-essential cookies and other tracking technologies, use of data for targeted advertising, and any sale of data to third parties. If we ask for your consent to process your personal information, you may withdraw your consent at any time by following the processes outlined herein to exercise your privacy rights, or by contacting us using the details at the end of this privacy notice.

Information Sharing

3.1 Disclosure of Information for Business and Commercial Purposes. We may disclose all the categories of collected personal information for business or commercial purposes to the following types of parties:

Service providers. We may share your personal information as necessary with our service providers, business partners, and others who perform services and other business operations for us or on our behalf, provided that such service providers shall be contractually prohibited from retaining, using, or disclosing your personal information for any other purpose. For example, we may engage other companies to provide us with internet service, data analytics, communications platforms, and operating systems and platforms, and to process secure payments, fulfill, ship, and deliver orders, manage event registrations, provide advertising and marketing services, send newsletters, content and marketing emails, and to support email and messaging services.
Third-party partners or targeted marketing providers. We may offer contests or other promotions jointly with disclosed third-party partners, in which case your entry information will also be shared with them, and some jurisdictions require the disclosure of information about contest winners, which will be disclosed to authorities as necessary. We may share information about our site users, purchasers, and Consultants with third parties who provide cross-context behavioral marketing or targeted marketing services to us, subject to your right to opt-in or opt-out, depending upon your jurisdiction. We may also provide your contact information to other third-party partners with whom we may enter into a commercial relationship, so that they may offer their relevant products or services to you, also subject to your right to opt-in or opt-out of this sale/sharing of your personal data, as applicable.
Law enforcement agencies, courts, regulators, and government authorities. We may share your personal information with these parties upon an official request where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect or defend our rights or the rights of any third party.
Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to contractually require that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy policy.

3.2 CCPA Only – Sale of Information. The California Consumer Privacy Act of 2018 (CCPA) requires this disclosure regarding “sale” of personal information, as that term is specifically defined by CCPA. First, as disclosed above, we may disclose your contact information to our third-party marketing and promotional partners, which may be a sale of your information if we receive anything of value in exchange. Second, we may permit certain of our vendors to use tracking technologies to capture information in the categories of internet identifiers, internet activity and commercial information about your engagement with our Site or we may provide lists of certain groups or segments of our customers to our marketing vendors, each for the purposes of effectuating our targeted advertising and marketing to you on third-party sites and services, measuring ad response, analyzing your use of our Site and Services, and customizing our Site and Services, in ways that may be deemed a “sale” of such personal information under the CCPA. To the extent we or our vendors use such technologies on the Site or our Services or use custom marketing lists, or we disclose your personal data to our third-party partners, we offer a mechanism below, detailed in Section 4 of this policy, through which you can opt-out of either or both of these types of sale of personal data.

3.3 Disclosure to Third Parties at Your Direction. To the extent you choose to engage directly with certain third-party services chosen, linked from, or framed on our Site, such as Buy-Now-Pay-Later payment providers or other payment processors, you are either providing your personal information directly to these providers or directing us to provide it to them on your behalf to effectuate your purchase. Personal Information you provide for this purpose is subject to such third parties’ terms and privacy policies, which may be indicated and linked at the point you enter personal information, if done via a frame or pop-up from our Site. To the extent you use PayPal, they act as an independent Controller for the purpose of processing your customer data, which processing is governed by the PayPal Privacy Statement found here: https://www.paypal.com/myaccount/privacy/privacyhub.

3.4 International Data Transfers. Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the Services). As a result, your personal information may be transferred to, stored, or otherwise processed in a country that is not regarded as ensuring an adequate level of protection for personal information in relation to your country of residence.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected when transferred.

Your rights regarding your personal information and How to exercise your rights

Your privacy rights.

You have certain rights regarding your personal information based on applicable local laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA) where applicable, which may include the following rights:

To Access your personal information/data portability – You have the right to request that we send you (or another organization, under certain conditions) a copy of your personal data in our possession, in a readily usable and portable format.

For California residents, in addition to the specific pieces of your personal information, you also have the right to request that we provide you:

The categories of personal information we have collected about you in the preceding 12 months
The categories of sources from which we collected your personal information
The categories of third parties with whom we shared your personal information in the preceding 12 months, including:
If we disclosed your personal information for a business purpose, which categories of your personal information we disclosed for a business purpose to which categories of third parties, and
If we sold your personal information, as “sell” is defined under the CCPA, which categories of your personal information we sold to which categories of third parties
Our business or commercial purpose for collecting or selling your personal information.
To Rectify the information, we hold about you – You have the right to request that we correct any information you believe is inaccurate or complete any information you believe is incomplete.
To Erase or Delete your personal information – You have the right to request that we erase or delete your personal information under certain conditions or subject to certain legal exceptions.
To Restrict our processing of your personal information – You have the right to request that we restrict our processing (collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, making available, alignment or combination, restriction, erasure or destruction) of your personal information, under certain circumstances.
To Object to our processing of your personal information – You have the right to object to our processing of your personal data, under certain circumstances.
To Opt out of certain sharing of your personal information that California law defines as a “sale,” including our selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating your personal information to another business for monetary or other valuable consideration.
To withdraw your Consent for any processing that is based on your Consent.
To Lodge a Complaint with your local data protection authority, as set forth below.
Non-Discrimination – We will not discriminate against you for exercising any of your privacy rights by denying you goods or services, charging you different prices or rates for goods or services, including through granting others or denying you discounts or other benefits or imposing penalties, providing you a different level or quality of goods or services, or suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services if you exercise your rights to access or delete your personal information or opt-out out of its sale.

Exercising your privacy rights.
For all persons except California residents: To exercise your privacy rights, please contact us at:
Sunbliss Superfood, LTD.
10777 Sherman Way, Sun Valley, CA 91352
email: support@sunblisssuperfood.com
toll-free tel: 1-818-962-6253

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

For California Residents:

Opt Out of Sale: To opt out of certain sharing of your personal information that California law defines as a “sale”
For personal information collected via cookies or other web tracking technologies, to opt out (by toggling off the cookie consents labelled “Sale of Personal Data” in our Consent Preference Center), please see below.

To opt-out of the use of your email address or other non-cookie information for targeted marketing purposes, or the disclosure of your contact information to our third-party partners for their marketing purposes, please complete this webform: INSERT HYPERLINK to the CCPA Request From (CREATE A NEW HIDDEN PAGE) or Contact Us as provided below. (In addition, although our email newsletters and direct email marketing are not considered a “sale” of information under CCPA, please note that you may use the “Manage Preferences” or “Unsubscribe” function in the footer of any such email to limit or stop receiving them.)

Right to Know/Access or Delete: To exercise your CCPA privacy rights to request access or deletion of your personal information, please complete this webform: insert hyperlink to the INSERT HYPERLINK to the CCPA Request From (CREATE A WEBPAGE / NEW HIDDEN PAGE) or Contact Us as provided below.

Please note that requests under CCPA to know, access, or delete your data must be verifiable, and that in order for us to verify your identity, we will need to match certain information you provide in your request with data that we maintain and have determined to be reliable for the purposes of identity verification. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. If we are unable to verify your identity with reasonable certainty, we may deny your request as permitted by law. If your request is to know or access specific pieces of personal information, you will be required to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. You may not make a request to know or access your information under the CCPA more than twice within a 12-month period.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We may require any agent making a request on your behalf to provide written permission from you to submit a request on your behalf and to verify their identity and authorization to do business in California, as applicable, or demonstrate that he or she has power of attorney in connection with your request to know, access or delete.

Additional Disclosures

5.1 Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. We do not share your information with third parties for their direct marketing purposes.

5.2 Do Not Track Signals
We do not currently respond to web browser “do not track” signals, because a uniform technological standard has not been developed.

5.3 Disclosure regarding the collection and sale of children’s personal information
This Site and our Services are intended for adults over 16 years of age, and we do not knowingly collect or sell personal information of minors under 16 years of age without affirmative authorization or without affirmative, verifiable consent from a parent for those under age 13.

5.4 CCPA Notice of Financial Incentives
On our Site and/or our social media channels, we may provide an opportunity to sign up to receive our newsletter and/or other interest-based content by providing us your name, email address, or other personal contact information. There is no obligation to opt-in, and you may unsubscribe at any time by following the instructions in the mailing. From time to time, we may offer a financial incentive to those who sign up for or remain on our mailing list, complete a market research survey, make a purchase, or do not complete a purchase that was begun, such as a discount coupon or an opportunity to win a prize or giveaway in a random drawing. The details of each incentive program will be contained in the program terms.

We offer these programs, among other things, to enhance our relationship with you, to provide you with content that may be of interest to you, and/or so you can enjoy more of our products/services at a lower price. The CCPA requires certain disclosures related to financial incentive offerings, including in relation to the value of your consumer data to our business. Although we do not calculate the value of consumer data to our business in our accounting statements, we make this good faith estimate for California residents to use in making an informed decision whether or not to take advantage of any financial incentive or price or service difference we may offer that relates to the collection, retention or sale of your personal information.

To the extent we create overall value for our business from our financial incentive marketing programs that could be directly or reasonably related to the value of customer data, that value would vary from program to program and among individuals, but our method for calculating this value to our business would include: for each program, and in the aggregate, whether and by what amount the sales generated by the program(s) exceed the cost to us of offering them, which would include costs associated with (1) any financial incentives that are paid to consumers; (2) the cost of the marketing and distribution of the offer; (3) our marketing team’s efforts to enhance the resulting consumer data through campaign optimization and consumer engagement at sufficient scale; (4) leveraging our past investments in understanding consumers as our existing and future customers; (5) collecting and maintaining data as intellectual property; and (6) all other costs reasonably related to the programs.

Retention

We will only keep your personal information for so long as we have a legal basis on which to do so, including during such time as we have a relationship with you that requires the information, and thereafter, only as necessary to maintain our products and services records, or as required to comply with law, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.

Information Security and Storage

We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

Changes to the Privacy Policy

We may modify or update this privacy policy from time to time and will update this privacy policy if we change our privacy practices. We will notify you of the changes, either directly (e.g., if you have an account with us) or by posting an updated version with a new effective date on our Site. Where changes to this privacy policy fundamentally impact on the nature of the processing or make a material change in the purposes for which we collect or use your personal information, or otherwise have a substantial impact on you, we will notify you and provide you the option to consent or remove your data from our control before such change, or will only apply the change to data collected thereafter.

Contact Us

Sunbliss Superfood, LTD. is the controller responsible for the personal information we collect and process.

If you have questions or concerns regarding the way in which your personal information has been used or wish to discuss your privacy rights, please contact us as provided below:

Sunbliss Superfood, LTD.
10777 Sherman Way, Sun Valley, CA 91352

email: Support@sunblisssuperfood.com
toll-free tel: 1-818-962-6253