Last Updated: August 28, 2020
As explained in further detail below, when you register for and use SuperShe:
SuperShe is located in the United States, and the SuperShe Island is located in Finland. Information collected on our website and application is stored in the United States; therefore, your information may become subject to U.S. law. By using the Services, you consent to the transfer of your data overseas and across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. The laws governing data in your home country may differ from those in the countries to which data is transferred. By accessing and using our website and mobile application, you consent to the transfer of your data in this manner.
INFORMATION WE COLLECT
Any personal information provided to or collected by SuperShe is controlled by SuperShe. SuperShe’s headquarters are located at 14725 N. 20th St., Unit D37; Bellevue, Washington 98007.
Information You Provide To Us
1.1.1.Information That Is Necessary For The Use Of SuperShe’s Services.
We ask for and collect the following personal information about you when you use SuperShe’s Services, which is necessary for the performance of a contract between you and us (e.g., placing an order) and allows us to comply with various legal obligations. Without this information, we may not be able to provide you with all of the requested services.
1.1.2.Information You Choose To Provide To Us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using the SuperShe Services. This additional information will be processed based on your consent or SuperShe’s legitimate interests, as specified below:
SuperShe processes this information based on your consent and based on our legitimate interest in maintaining User Content and facilitating community interaction among SuperShe members. SuperShe has a legitimate interest in ensuring the ongoing management of its business and in maintaining an acceptable and uninterrupted experience for other users of the Services. Based on this legitimate interest, SuperShe will not accommodate requests for erasure of Your Content unless Your Content violates SuperShe’s Terms and Conditions, Community Guidelines, or applicable laws and regulations.
Information We Get From Your Use Of Our Services
When you use SuperShe’s Services, we automatically collect information, including personal information, about the services you use and how you use them, such as information about how you use or interact with our website and mobile application, view or interact with our ads and content, and information about your computer or mobile device. This information may include:
Please also note that most opt-out mechanisms are cookie-based, so you must have cookies enabled in your web browser, and they will only affect the specific computer and browser that is used to submit an opt-out request. If you have multiple computers or change computers, or use multiple browsers, you will need to submit opt-out requests for each such computer or browser. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again. Mobile devices may involve unique advertising choice mechanisms. For more information, please see the Location Information section above.
Information We Collect From Third Parties
SuperShe, or its third-party agents or partners, may collect information that others provide about you when they use the Services, or obtain information from other sources and combine that with information we collect through the Services. We do not control how third parties process your personal data, and any information request regarding the disclosure of your information to us should be directed to such third parties.
To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners, and combine it with information we have about you. For example, we may receive fraud warnings from service providers for fraud prevention and risk assessment efforts. Additionally, we may receive information about you and your activities on and off the Services through partnerships, or about your experiences and interactions from our partner advertising networks.
HOW WE USE INFORMATION WE COLLECT
SuperShe and our third-party agents and partners use, store, and process information, including personal information with your consent, about you to sell advertising on SuperShe, to send you offers and promotions for our products and services or third-party products and services, to provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications, to provide, understand, improve, and develop the Services, create and maintain a secure environment, and to comply with our various legal obligations.
SuperShe relies on advertising to fund the development and distribution of the SuperShe app so that it is available at no cost to you. Accordingly, when you use the SuperShe app, you may see third-party advertising. This advertising is delivered to the SuperShe app by advertising networks that sell advertising to interested third parties. Advertising networks collect a unique device ID or advertising ID (Apple Identifier for Advertisers (“IDFA”) on Apple devices and Google Advertising Identity (“GAID”) on Android devices) that enables the delivery of advertisements that are relevant to you. Your advertising ID is consistent across all apps and thus allows for cross-app tracking and interest-based advertising. Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications. Advertising networks may use your device’s IP address to determine your approximate geographic location to enable them to deliver more relevant advertisements.
We may also provide you with information about new products and special offers. We may tell you about new features or updates. These might be third-party offers or products we think you might find interesting.
For more information about your choices related to these communications, see the “Your Rights” section below.
Provide A Personalized Experience And Improve Our Advertising And Marketing
We use the information we collect to provide a custom user-experience through things such as:
Provide, Improve, And Develop SuperShe’s Services
We use the information we collect to provide, improve, and develop SuperShe’s Services by, for example:
Create And Maintain A Secure Environment
We use the information we collect to ensure SuperShe’s Services are secure by, for example:
HOW WE SHARE INFORMATION WE COLLECT
With Your Consent
We may share your information at your direction or as described at the time of sharing, such as when you authorize a third-party application or website to access your SuperShe account.
Other SuperShe Services
To facilitate SuperShe App users’ transactions on the SuperShe Website, including but not limited to redemptions and other transactions relating to the Rewards Program, SuperShe will link your App information with its Website. Likewise, to ensure e-commerce activity such as point-earning purchases on the Website are reflected in a user’s SuperShe App, SuperShe may link user information from its Website with the App.
Your Content And Other Public Information
Some of SuperShe’s Services let you publish information, including personal information, that is visible to other SuperShe users. For example:
Interaction Between Members
Some of SuperShe’s Services allow you to communicate with other SuperShe users via private direct message or other means, in which case SuperShe will facilitate such communications with the intended recipient. You should consider who you choose to share information with, because people who can see your activity and/or communications on the Services can choose to share it with others on and off our Services, including people and businesses outside the audience you may have intended. For example, when you send a message to specific members, they can screenshot or re-share that content to others on or off our Services or in-person. Also, when you comment on someone else’s post, react to their content, or post a review on a product, your comments and reactions are visible to anyone who can has access to that portion of the Services.
Compliance With Laws, Responding To Legal Requests, Preventing Harm, And Protection Of SuperShe’s Rights
SuperShe uses a variety of third-party service providers to help us provide the Services. Third-party service providers may be located inside or outside of the European Economic Area (“EEA”). For example, service providers may help us: (i) conduct fraud prevention and risk assessments; (ii) perform product development, maintenance, and debugging; (iii) provide customer service, advertising, payment, and transactional services; (iv) help us track website analytics, such as conversion and traffic metrics; and (v) verify information against public databases.
SuperShe may need to share your information, including personal information, with third-party service providers in order to ensure the adequate performance of our contract with you (e.g., name and billing address to complete a transaction and ship your order).
Advertising and Analytics
SuperShe may share your information with our business partners. For example, this may include a third party that co-sponsors a contest or promotion.
Third Parties for Marketing Purposes
SuperShe may also share your information with third parties for marketing purposes. This may include third parties in whose products or services we believe you may be interested. These third parties may also share your information with others. These third parties may use your information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
Do Not Track and Advertising Across Different Websites
We currently do not change our tracking practices in response to “do-not-track” signals or other similar mechanisms. Third parties that have content or services on our website such as a social feature, an analytics service, or an advertising network partner, may obtain information about your browsing or usage habits. These third parties do not change their tracking practices in response to “do-not-track” signals from your web browser and we do not obligate these parties to honor “do-not-track” signals. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.com.
We may use analytics services, such as Google Analytics, on our website, our social media pages, or our mobile applications to help us evaluate and analyze how visitors use these platforms. For specific details on how Google collects and uses information on our website, social media pages, or mobile applications, please visit: How Google Uses Data.
As described in the sections above, we use customer personal information for the following general purposes:
EU Citizens’ Right to Object - Please note that EU citizens have a right to object to processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing purposes. Please see the “Your Rights” section below for more information.
LEGAL BASIS FOR OUR USE OF INFORMATION WE COLLECT
When processing personal data in the European Union and the European Economic Area, we will use your personal data when we have a lawful basis. Lawful bases may include:
HOW LONG WE KEEP THE INFORMATION WE COLLECT
THIRD-PARTY PARTNERS & LINKS
The Services may contain links to third-party websites or services, such as third-party integrations or third-party branded services. SuperShe does not own or control any of these third-party partners and when you interact with them, you may be providing information directly to the third-party providers, SuperShe, or both. These third-party providers will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.
Some of the safeguards we use to protect your information include firewalls and data encryption; compliance certifications (e.g., annual re-certification of compliance with Payment Card Industry’s Data Security Standards); information access control; and thorough security and breach response policies and procedures.
In the event of any actual or suspected unauthorized use of your SuperShe account, please contact us following the instructions in the “Contact Us” section below.
Use of SuperShe’s Services is not intended for and may not be used by children, especially those under the age of 13. If you are under the age of 13, you may not access or use the Services or provide information to us.
SuperShe does not knowingly collect personal information from individuals under the age of 13 or allow them to register accounts. If it comes to our attention that we have collected personal data from a minor, we may delete this information without notice. If you have reason to believe this has occurred, please contact firstname.lastname@example.org or our Customer Service department.
If you are between 13 and 16 years old, by registering for an Account with your email and/or phone number you represent that you have obtained your parent or legal guardian’s express consent to register with and use the Services. You and your parent or guardian also consent to our use, and our third party partners’ use, of your data for advertising purposes.
By accessing or using the Services, you represent that you have legal capacity to enter into this Agreement and to fulfill your obligations set out in this Agreement. If you are not of an age old enough to enter into contracts in your jurisdiction, you need to review this Agreement with your parent or guardian before using the Services; if your parent or guardian do not agree with the Agreement as applied to you, then you are not authorized to access or use the Services.
SuperShe acknowledges your right to access your personal data. Whenever you use our Services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we must keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort (e.g., developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical. For requests not falling in the aforementioned categories, where we can provide information access and correction, we will do so for free.
We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
You have the right to request information about the personal data we hold on you. If your data is incorrect, incomplete, or irrelevant you can ask to have the information corrected or removed. To access or update your personal information, email email@example.com with your current contact information and the personal information you would like to access. We will provide you the personal information requested if reasonably available, or will describe the types of personal information we typically collect.
If you are a parent or guardian of a child between the ages of 13 and 16 and wish to review, modify, or delete your child’s information, please contact us at firstname.lastname@example.org. We may contact you to verify your identity before acting on your request.
California Residents – Do Not Sell my Personal Information
California Consumer Privacy Act
If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.
1. You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
2. You can ask us to delete your personal information.
3. You can ask that we stop selling your personal information.
More information on each of these requests is below.
1. What personal information do you collect about me?
If you make this request, we will return to you (to the extent required by law):
You can ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to personal information we collected about you in the previous 12 months.
2. Delete My Personal Information:
You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account, and limit your use of in-store functions that require your personal information.
3. Stop Selling My Personal Information:
We do not share your personal information for money. We do share personal information with certain third parties, which may be considered a “sale” under California law even if we don’t receive money in exchange for the information. For purposes of California law, we may share with these parties all categories of personal information, except for background and criminal information, biometric information, and government identifiers. We do not knowingly sell the personal information of minors under 16 years of age. If you are a California resident, you have a right to opt-out of the sale of your personal information. To do so, please contact us at email@example.com.
Below is a chart showing the types of personal identifiers that we may have sold in the previous 12 months.
Categories of Third Parties to Whom the Personal Information May Be Sold
Categories of Personal Information Sold
Advertising companies (like ad servers, advertising agencies, technology vendors, providers of sponsored content, and others)
Characteristics of protected classifications under California or federal law
We will not discriminate against you for exercising your rights. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Please know, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain services which require usage of your personal information to function.
To exercise the California privacy rights described above, please contact us at firstname.lastname@example.org with “Request My Personal Information” in the subject of your email.
To opt-out of the sale of your personal information, please contact us at email@example.com with “Do Not Sell My Personal Information” in the subject of your email.
Verifying Your Identity for Requests to Access or Delete Personal Information
We take the privacy of your personal information seriously and want to ensure that we provide only you or your authorized agent with your personal information. The CCPA also requires that we verify the identity of each person who makes a request to know what personal information we have about you or to delete the personal information we have about you.
What Personal Information Do I Provide to Verify My Identity?
To verify your identity, we ask you to provide your:
*required field if you registered with this information
How Do You Verify My Identity?
We may verify your identity in a few different ways. When you make your request, you will be asked to answer a few questions about yourself to help us validate your identity. If you have an online account, we may ask you to log into your account and complete a one-time passcode validation.
In some instances, we may ask you to provide other documentation to verify your identity. If this happens, we will reach out to you directly with this request.
What If You Can’t Verify My Identity?
If we can’t verify your identity, we will not be able to process your request to know what personal information we have about you or to delete the personal information we have about you. If we are unable to verify your identity with a high degree of certainty, we will only be able to provide a report with category-level information and we may not be able to delete some of your information.
How to Submit a Request Using an Authorized Agent
An authorized agent is a person or business who has authorization to request to know what personal information we have about you, to delete the personal information we have about you, or to opt out of the sale of personal information on behalf of a California resident. Authorized agents use the same links described above to submit requests.
If you are submitting a request on behalf of another person, we require a valid power of attorney and a signed attestation form.
How Do I Send You My Documentation?
Please email us at firstname.lastname@example.org. Please note, you will have 10 business days to provide all required documentation.
Your California Privacy Rights - Shine the Light
The following rights apply to California residents.
Please contact us at email@example.com with any questions or comments about this Policy or about how we handle your personal information.
The Privacy Office’s address is:
Attn: Privacy Officer
14725 N. 20th D37
Bellevue WA 98007
Customers Located In The EEA
Customers located in the EEA may exercise any of the rights described in this section by sending an e-mail to firstname.lastname@example.org. Please note that we may ask you to verify your identity before taking further action on your request.
Managing Your Information
You may access and update some of your information, including personal information, through your SuperShe account settings. You are responsible for keeping your personal information up-to-date.
Correcting Inaccurate Or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your SuperShe account).
Data Access And Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly-used, and machine-readable format, and/or request us to transmit this information to another service provider (where technically feasible). To make such a request, please contact us at email@example.com.
Data Retention And Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. Because we keep the content on SuperShe relevant, fresh, and new, we may delete Your Content at any time without prior notice with you, unless applicable law or agreements require otherwise. This includes your messages and other types of Your Content in private portions of the Services, such as private messages.
If you no longer want us to use your information to provide the Services to you, and subject to SuperShe’s legitimate interest exceptions, you can request that we erase your personal information and close your SuperShe account. To make such a request, please contact us at firstname.lastname@example.org. Please note that if you request the erasure of your personal information:
Withdrawing Consent And Restriction Of Processing
Where you have provided your consent to the processing of your personal information by SuperShe, you may withdraw your consent at any time by changing your account settings, cookie settings, or by sending a communication to email@example.com specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular, where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise, or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 10.6 and pending the verification whether the legitimate grounds of SuperShe override your own.
Objection To Processing
In some jurisdictions, applicable law may entitle you to require SuperShe not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, SuperShe will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defense of legal claim(s).
Where your personal information is processed for direct marketing purposes, you may, at any time, ask SuperShe to cease processing your data for these direct marketing purposes by updating your cookie settings or e-mailing firstname.lastname@example.org.
You have the right to lodge complaints about the data processing activities carried out by SuperShe before the competent data protection authorities in your country. Additionally, you may reach out to SuperShe’s Data Protection Officer at:
Attn: Privacy Officer
14725 N. 20th D37
Bellevue WA 98007
To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.
11.1.What is a cookie?
11.2.What cookies do we use?
The Services use both first-party cookies (which are set by the websites and/or mobile app being visited) and third-party cookies (which are set by a server located outside the domain of our websites and/or mobile app).
11.3.Functional or essential cookies
11.4.Experience or preference cookies
These cookies collect information about your choices and preferences (e.g., username and language selection) and are used to enable certain additional functionality on our websites, such as storing your preferences. This functionality improves user experience and allows us to customize your site experience accordingly.
11.5.Social media and advertising cookies
Social media cookies collect information about social media usage and allow you to connect to your social networks to share content from our website or mobile app.
We may also use advertising cookies to market SuperShe products or services to you on third party websites. For example, if you visit our website, you may then see an advertisement for SuperShe products or services on certain third-party websites you visit in the future.
Analytics cookies collect information about your use of the Services, and enable us to improve the Services. For example, analytics cookies show us which are the most frequently visited pages on our website or mobile app, help us record any difficulties you have (e.g., mobile app crashes), and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on the Services, rather than the usage of a single person. We use the information to analyze traffic on the Services to help create a better user experience. Analytics cookies may be classified as either functional, experience/preference, or social media/advertising cookies.
11.7.How do I manage cookies?
If you'd like to remove or disable cookies via your browser, you certainly can. You'll want to refer to your browser’s configuration documentation (usually the Help portion of your browser’s toolbar) to do this since the steps for doing so are usually browser-specific.
Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions/settings panel for more information.
One important note is that if you limit cookie settings, this might adversely impact your ability to use our Services effectively. Enabling cookies ensures a smoother experience when you use our Services.
Attn: Privacy Officer
14725 N. 20th D37
Bellevue WA 98007
Or you may also e-mail us at email@example.com.