1. Personal Information We Collect.

When we use the term “personal information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with an individual or household. Depending on the applicable law, “personal information” may include “personal data” and similar terms. It does not include information excluded from applicable privacy laws, such as information that is lawfully made public or has been de-identified or aggregated so that it cannot reasonably be linked to an individual or household.

We may collect the following categories of personal information:

(a) Information You Provide to Us.

• Accounts, Loyalty, and Rewards. If you create an account or participate in VENN Circle, a referral program, or another rewards program, we may collect your name, email address, password or other account credentials, birthday if you choose to provide it, preferences, referral information, points and rewards activity, and other account details.
  
  
• Orders and Transactions. When you place an order, we collect information associated with the transaction, including the products purchased, purchase and return history, billing and shipping addresses, phone number, and payment-related information. Our payment processors collect and process payment card information. VENN generally does not directly store complete payment card numbers, but may receive related information, such as billing details, payment status, and a payment token.
  
  
• Communications and Customer Service. We collect the information you provide when you contact us, request information or support, submit a return or warranty request, or otherwise communicate with us, including your contact information and the content of the communication. Where permitted by law and with any notice or consent required by law, we may record telephone calls for training, quality assurance, security, and recordkeeping purposes.
  
  
• Reviews and Interactive Features. We may collect information you submit through product reviews, chat features, social media pages, or other interactive features. Information you post in public areas may be visible to other users and the public. 
  
  
• Surveys, Promotions, and Events. If you participate in a survey, promotion, event, giveaway, or similar activity, we may collect your contact information, responses, entries, and other information you choose to provide.
  
  
• Email Marketing. If you subscribe to or otherwise elect to receive marketing emails from us, we may collect your email address, marketing preferences, and records relating to your subscription or consent, including the date, time, method, and source. We may also collect information about your interactions with our marketing emails, such as whether you open an email or click a link, as well as your unsubscribe and other opt-out requests.
  
  
• SMS / Text Message Marketing. If you opt in to our SMS marketing program, we collect your mobile phone number, your consent to receive text messages, the date, time, and source of your consent, and information about your interactions with our messages, including opt-out requests.
  
  
• Professional and Business Interactions. If you contact us through our professional or business channels, we may collect your name, business contact information, company, title or role, professional credentials or license information that you choose to provide, and information about your inquiry or account.
  
  
• Information About Others. You may provide information about another person, such as a gift recipient or referral contact. Please provide such information only if you are authorized to do so. We use it to complete the requested transaction or communication and for other purposes disclosed at the time of collection.
  

(b) Information We Collect Automatically.  When you use the Services, we and our service providers and advertising partners may automatically collect information about your device and use of the Services, including:

• Device and log information, such as Internet Protocol (IP) address, browser type, operating system, device type, Internet service provider, device and advertising identifiers, and date and time of access;
  
  
• Usage and commercial interaction information, such as referring and exit pages, pages and products viewed, searches, clicks, scrolling activity, cart activity, purchases, advertising interactions, and other information about how you use the Services;
  
  
• Approximate location information inferred from your IP address; and
  
  
• Information collected through cookies, pixels, tags, local storage, software development kits, and similar technologies (collectively, “Technologies”).
  
  
• Cookies and Similar Technologies. Cookies are small text files stored in a browser. Pixels and similar technologies are code that can record interactions with a webpage, email, or advertisement. We use Technologies that are strictly necessary to operate the Services, remember preferences and provide functionality, measure performance and analytics, prevent fraud and improve security, and support advertising and personalization.
  

• Analytics and Advertising. We may use Google Analytics and other analytics and advertising services. These services may collect or receive information from the Services and other websites or apps to measure use, understand audiences, evaluate advertising, and provide or measure targeted advertising. Information collected through these services may be associated with identifiers, accounts, or other information. For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s processing of data generated by your use of the Services by visiting http://tools.google.com/dlpage/gaoptout.

(c) Information from Other Sources.  We may obtain personal information from other sources, including e-commerce, payment, fulfillment, shipping, customer service, loyalty, review, analytics, fraud-prevention, and advertising providers; social media and other platforms; business and referral partners; and publicly available sources. We may combine information from these sources with information we collect directly or automatically.

2. How We Use Your Information.

We may use personal information for the following business and commercial purposes:

• Provide, operate, maintain, and improve the Services;

• Create and manage accounts, loyalty benefits, referrals, rewards, and preferences;

• Process and fulfill orders, payments, shipping, returns, exchanges, refunds, and related transactions;

• Respond to inquiries, provide customer service and technical support, and communicate about accounts, orders, products, policies, and the Services;

• Send transactional communications and, where permitted by law or with consent, marketing communications by email, text message, or other channels, including promotions, product launches, back-in-stock notifications, and cart reminders;

• Personalize the Services, product recommendations, content, and offers;

• Conduct analytics, research, testing, and product and service development;

• Market and advertise our products and Services, create and measure advertising audiences and campaigns, and provide targeted or personalized advertising;

• Protect the Services, accounts, transactions, and users; detect, investigate, and prevent fraud, abuse, security incidents, and other unlawful activity; and verify identity;

• Comply with legal, regulatory, tax, accounting, and contractual obligations; establish and defend legal claims; and enforce our agreements and policies;

• Evaluate or complete a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or other business transaction;

• Create and use de-identified or aggregated information, which we may use and disclose for any lawful purpose; and

• Carry out any other purpose disclosed to you at the time of collection or with your consent.

3. How We Disclose Your Information.

We may disclose personal information to the following categories of recipients:

• Service Providers and Contractors. We may disclose personal information to companies that perform services on our behalf, including e-commerce and website hosting, payment processing, order fulfillment and shipping, customer service, account management, email and SMS delivery, loyalty and referral programs, reviews, analytics, advertising support, fraud prevention, security, data storage, and professional services.
  
  
• Analytics and Advertising Partners. We may disclose identifiers (excluding mobile information and SMS opt-in data and consent), commercial information, Internet or other electronic network activity, approximate location, and inferences to analytics and advertising partners for campaign measurement, audience creation or matching, and targeted advertising. Under certain U.S. state privacy laws, these disclosures may be considered a “sale,” “sharing,” or processing for “targeted advertising,” even when no money is exchanged.
  
  
• Business and Promotional Partners. We may disclose personal information to business partners when necessary to provide a product, service, promotion, event, or benefit you request, or when we jointly offer a product or service.
  
  
• Other Users and the Public. Information you submit in a public review, social media post, or other public feature may be disclosed to other users and the public.
  
  
• Affiliates. We may disclose personal information to our corporate affiliates for the purposes described in this Privacy Policy, subject to applicable law.
  
  
• Professional Advisers and Authorities. We may disclose personal information to lawyers, accountants, auditors, insurers, and other professional advisers, and to courts, regulators, law enforcement, or other authorities when we believe disclosure is required or appropriate to comply with law or legal process, protect rights, property, or safety, collect amounts owed, prevent loss, investigate suspected wrongdoing, or establish or defend legal claims.
  
  
• Business Transfers. Personal information may be disclosed or transferred in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of assets, or transition of services.
  
  
• At Your Direction or with Your Consent. We may disclose personal information to other recipients when you direct us to do so, when we provide notice at the time of collection, or with your consent.

4. Mobile Information and SMS Consent. 

We do not sell or disclose mobile information, including text messaging originator opt-in data and consent, to third parties or affiliates for their own marketing or promotional purposes. We may disclose mobile information to service providers that support our messaging program, such as messaging platforms and telecommunications carriers, solely to provide those services, and as required by law. Text messaging originator opt-in data and consent will not be shared with third parties for their own marketing or promotional purposes.

5. International Data Transfers. 

VENN is based in the United States. Personal information may be transferred to, processed, and stored in the United States and other countries where we or our service providers operate. Those countries may have data protection laws that differ from the laws where you live. Where applicable law requires a transfer mechanism, we may rely on recognized safeguards, such as adequacy decisions, contractual protections, or the European Commission’s Standard Contractual Clauses and the United Kingdom’s applicable transfer addendum or agreement.

6. Your Choices.

(a) Email Communications. You may opt out of marketing emails by using the unsubscribe link in the email. You may continue to receive transactional or non-promotional communications regarding orders, accounts, security, policy changes, and other requested Services.

(b) SMS / Text Message Marketing and Communications. If you opt in to our SMS marketing program, we use your mobile phone number and consent to send recurring automated marketing text messages, such as promotions, product launches, back-in-stock notifications, and cart reminders. Consent to receive marketing text messages is not a condition of any purchase. We collect SMS consent through checkout and sign-up forms. Message and data rates may apply, and message frequency varies.

You may opt out at any time by replying STOP to any text message you receive from us. You may also revoke consent through any other reasonable method that clearly communicates your request, including by contacting us at care@vennskincare.com. We will process an opt-out request promptly and no later than 10 business days after receipt. For help, reply HELP or contact us at care@vennskincare.com. We may send one non-marketing text message confirming your opt-out. For full details, see our SMS / Text Messaging Terms at https://vennskincare.com/pages/terms-of-use#sms.

(c) Account and Rewards Preferences. You may update certain account information and preferences through your account. You may withdraw from a loyalty, referral, or rewards program as described in the applicable program terms or by contacting us. Withdrawal may affect unused points, rewards, or benefits, subject to applicable law and the program terms.

(d) Cookies, Targeted Advertising, and Privacy Choices. You may be able to manage non-essential Technologies through the cookie or privacy preference tool made available on the Site. You may also adjust browser or device settings to block or delete cookies, although doing so may affect the availability or operation of certain features.

To opt out of disclosures that may be considered a sale or sharing of personal information, or processing for targeted advertising, use the “Your Privacy Choices” link in the Site footer. Where required by law, we also process recognized opt-out preference signals, such as the Global Privacy Control (“GPC”). A preference signal generally applies to the browser or device from which it is sent; if you are logged in and we can reasonably associate the signal with your account, we may apply the request to the account as required by law.

(e) Do Not Track. Some browsers offer a “Do Not Track” (“DNT”) setting. Because there is not a uniform industry standard for DNT, we do not respond to DNT signals. This statement does not affect our obligation to process legally recognized opt-out preference signals, such as GPC, where required by applicable law.

7. U.S. State Privacy Rights.

Depending on where you live and subject to applicable law and exceptions, you may have the right to:

• Confirm whether we process your personal information and access or obtain a copy of it;
  
  
• Correct inaccuracies in your personal information;
  
  
• Delete personal information;
  
  
• Obtain personal information in a portable and, where technically feasible, readily usable format;
  
  
• Obtain information about categories of recipients or, where required by law, specific third parties to which personal information was disclosed;
  
  
• Opt out of the sale of personal information, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects;
  
  
• Limit certain uses and disclosures of sensitive personal information or withdraw consent to processing, where applicable;
  
  
• Appeal a decision we make regarding a privacy rights request; and
  
  
• Receive equal service and not be discriminated against for exercising privacy rights.
  

To submit an access, correction, deletion, portability, or similar request, use the privacy request form linked on the Site, call us at (888) 418-4302, or email care@vennskincare.com. To opt out of sale, sharing, or targeted advertising, use the “Your Privacy Choices” link or an applicable opt-out preference signal. Please describe the right you wish to exercise and provide the information reasonably necessary for us to locate relevant records and verify your identity. We will use personal information provided in connection with a request only to verify and fulfill the request, maintain required records, and prevent fraud.

You may use an authorized agent where permitted by law. We may request proof that the agent is authorized and may require you to verify your identity or confirm the request. If we deny a request and applicable law provides a right to appeal, you may appeal by replying to our decision or emailing care@vennskincare.com with “Privacy Appeal” in the subject line. We will respond within the period required by applicable law and provide information about further recourse where required.

8. Data Retention. 

We retain each category of personal information only for as long as reasonably necessary and proportionate for the purposes for which it was collected or processed, unless a longer period is required or permitted by law. In determining retention periods, we consider the duration of our relationship with you; the time needed to provide the Services and administer accounts, orders, returns, warranties, loyalty benefits, and marketing preferences; applicable tax, accounting, recordkeeping, product, and legal requirements; the need to prevent fraud and maintain security; applicable statutes of limitation and dispute periods; and whether information has been de-identified. We retain records of consent and opt-out requests for a period reasonably necessary to demonstrate compliance and honor your choices. Additional category-specific criteria for California residents are provided below.

9. Security of Your Information. 

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. No security measure or transmission over the Internet is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of account credentials and for notifying us promptly of suspected unauthorized access. If we are required to notify you of a security incident, we may do so electronically, by mail, through the Services, or by another method permitted by law.

10. Third Party Websites and Services. 

The Services may link to websites, applications, platforms, and services that we do not control. This Privacy Policy does not apply to those third-party services. We encourage you to review their privacy notices before providing personal information. We are not responsible for the privacy, security, content, or practices of third-party services.

11. Children's and Teenagers' Information.

The Services are intended for adults and are not directed to individuals under 18. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information in violation of applicable law, please contact us so that we can take appropriate action. We do not knowingly sell or share the personal information of consumers under 16, or process personal information of minors for targeted advertising or other purposes requiring consent, without the consent required by applicable law.

12. Supplemental Notice for California Residents.

This section applies to personal information subject to the California Consumer Privacy Act, as amended (the “CCPA”). It describes the categories of personal information we collected in the preceding 12 months, the categories of recipients to which we disclosed personal information for business purposes, the categories that we sold or shared as those terms are defined by the CCPA, and our retention criteria. The categories of sources and the business and commercial purposes applicable to these categories are described in Sections 1 and 2 above.

We do not sell personal information in exchange for money. As described above, we may disclose online identifiers, non-SMS contact identifiers used for audience matching, commercial information, Internet or other electronic network activity, approximate location, and inferences to advertising partners in ways that may constitute “selling” or “sharing” under the CCPA. Mobile information and SMS opt-in data and consent are excluded from these disclosures. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

California Privacy Rights and Requests

California residents may have rights to know, access, correct, and delete personal information; obtain information about collection, disclosure, sale, and sharing; opt out of sale or sharing; limit certain uses and disclosures of sensitive personal information; and receive non-discriminatory treatment. The request methods, verification procedures, authorized-agent process, and appeal information in Section 6 apply. You may opt out of sale or sharing through the “Your Privacy Choices” link or GPC. We use and disclose sensitive personal information only for purposes permitted without a right to limit, such as providing requested goods and Services, processing payments, authenticating accounts, maintaining security, preventing fraud, and complying with law, and not to infer characteristics about you.

Notice of Financial Incentives

We may offer VENN Circle, welcome offers, referral rewards, birthday benefits, discounts, points, gifts, or other programs that may be considered financial incentives or price or service differences under California law. Participation is voluntary. Depending on the program, we may collect identifiers, California Customer Records information, commercial information, Internet or other electronic network activity, and inferences, including name, email address, birthday if voluntarily provided, purchase history, rewards and referral activity, and engagement with the Services. The material terms and value of each benefit are described in the applicable offer or program terms.

Our good-faith estimate is that the value of the personal information associated with a program is reasonably related to the value of the benefits provided to participants. We calculate this estimate by considering the value of the discount, points, rewards, gifts, or other benefits; the costs of administering the program; and the incremental revenue and engagement reasonably attributable to the program. The value varies by participant based on purchases, activity, and benefits used, and the practical estimate of value is generally the value of the benefits made available to that participant. You may opt in by enrolling or otherwise accepting the applicable offer. You may withdraw at any time through your account or by contacting us, but withdrawal may result in the loss of unused points, rewards, or benefits, subject to applicable law and the program terms.

De-Identified Information

If we maintain information as de-identified under the CCPA, we will maintain and use it in de-identified form and will not attempt to reidentify it except as permitted by law.

13. Supplemental Notice for Nevada Residents.  

Nevada residents may have the right to opt out of the sale of certain covered information to a person who will license or sell that information. We do not currently sell covered information as “sale” is defined in Nevada Revised Statutes Chapter 603A. You may submit a Nevada opt-out request by contacting us as described below.

14. International Privacy Rights and Supervisory Authorities.

If applicable data protection laws of the European Economic Area, Switzerland, the United Kingdom, or another jurisdiction apply to our processing of your personal information, you may have additional rights, including rights to object to or restrict processing, withdraw consent, and lodge a complaint with a competent data protection authority. You may contact us to exercise rights or request information about applicable transfer safeguards.

15. Changes to Our Privacy Policy.

We may update this Privacy Policy from time to time. The “Last Updated” date identifies when it was last revised. If changes are material, we will provide notice as required by applicable law. The updated Privacy Policy becomes effective when posted or on the date otherwise specified in the notice.

16. Contact Us.

If you have questions about our privacy practices, this Privacy Policy, or a privacy request, please contact us at:

Venn Skincare, Inc.
750 N San Vicente Blvd
Ste 800 West
Los Angeles, CA 90069 USA

care@vennskincare.com

(888) 418-4302