Privacy policy
Woolinos Privacy Policy
Woolinos (“we”, “us”, “our”, or “Jojo Group LLC.”) respects your privacy and is committed to protecting it through our policies and practices as described in this Privacy Policy. This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of Your information when You use our website (woolinos.shop). By using our website or our Services, you agree to the collection, use, and disclosure of your information in accordance with this privacy policy.
This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from woolinos.shop (the “Site”).
PERSONAL INFORMATION WE COLLECT
When you use the Services, we may collect personal or personally identifiable information from you (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data.
We may collect and process the following categories of PII about you:
· Communication Data. Communication data includes any communication that you may send to us through the Services, email, telephone, SMS or other text, livechat, or social media. We process this data to communicate with you by email or other means, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. Woolinos’s lawful ground for collecting and processing this PII is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.
· User Data. User data includes data about how you use the Services and any data that you post to or authorize through the Services, such as your name, address, country, phone number, and email address. This includes data stored in persistent cookies when you login to the Services and analytics data that is collected when you use the Services. We collect and process this data to operate the Services, to authenticate you as a user of the Services, to ensure that timely and relevant content is provided to you, to secure the Services, to ensure that the Services operates in a fast and efficient manner, and to maintain backups of the Services. Woolinos’s lawful ground for processing this user data is its legitimate business interests in administering and offering the Services and to fulfill your orders made through the Services.
· Technical Data. Technical data includes data about your use of the Services, such as your IP address, your login data, your phone number, your mobile device model, your operating system, your geolocation, and your time zone. We may collect this data from your use of the Services and from advertising IDs. Woolinos processes this data to analyze your use of the Services, to route Services traffic, to administer and secure the Services, to provide location-relevant content, and to troubleshoot problems with the Services. Woolinos’s lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy.
· Marketing Data. Marketing data includes data about your preferences in receiving and interacting with Woolinos’s advertisements or content on the Services or on third party websites or applications. We collect this data from your use of the Services and from third party advertising IDs created through advertising programs, such as Google Advertising IDs and Facebook Advertising IDs. Woolinos does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. Woolinos’s lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy by providing advertisements, including re-marketing advertisements, to you.
Woolinos will only use your PII for the purpose for which it was collected. If Woolinos needs to use your PII for an unrelated, new purpose, Woolinos will provide you with notice of this new use and will explain the lawful ground for such processing. Woolinos may process your PII without your knowledge or consent where required or permitted by law.
How do we collect this information?
We collect PII from you through a variety of different means:
· Direct Collection. We may collect PII from you when you purchase products from our Website, register a User Account or for other services, contact us through the Website or other website, via live chat, social media, SMS or other text, telephone, email, or otherwise, respond to a survey, participate in a contest, submit a review or feedback with or without photos, or when you opt-in to receive marketing emails, or mailings from us.
· Third Party Tracking Tools. We use third party tracking tools, such as pixels, web beacons, and cookies, to automatically collect PII from you when you open, view, or click pages or links, emails, or advertisements. We disclose these third-party tracking tools below in this Privacy Notice in our disclosure of PII that we collect from third parties.
· Business Partners and Service Providers. We may, from time to time, obtain PII from our business partners or service providers. When we obtain PII from our business partners and service providers, we ensure that all such business partners and service providers have obtained consent from you to transfer all such PII to us for its intended uses.
· Social Media Networks and Other Platforms. We may obtain PII from you when you interact with our social media accounts or content posted on other third-party platforms, such as Facebook, X, or YouTube. For more information on how your PII may be disclosed by a particular social media network or platform, you are encouraged to review the privacy notices and policies of those platforms.
· Analytics Providers. We may also obtain PII from you through our use of third-party analytics providers, such as Google Analytics or Klaviyo. See below for a complete list of analytics services we partner with. We may create user profiles based on PII obtained through our use of PII from third-party analytics providers to better understand your wants and needs as a customer.
COOKIES AND SIMILAR TECHNOLOGY
Cookies
We may collect information using cookies or similar technologies such as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs). Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies enable us to personalize your experience on our websites and apps, maintain a persistent session, passively collect demographic information about your computer and monitor other activities. Our Services may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage). Web beacons permit us to count users who have visited our pages and allow us to see other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Currently, our web servers do not recognize or respond to “Do Not Track” signals and our Services may continue to collect information in the manner described in this Privacy Policy. If you do not want us to collect this information, do not visit any of our Services.
Third-Party Use of Cookies and Other Tracking Technologies
Please note that some of the cookies on our Services are third-party cookies (e.g. Google advertising cookies) which we do not control. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We use third-party service providers, including Google, which uses cookies and similar technologies to collect and analyze information about your use of our Services. These service providers may also collect information regarding your use of other websites, apps, and online resources. You can learn about Google’s practices at http://www.google.com/policies/privacy/partners/, and opt out by using the Google Analytics Opt-Out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).
Additionally, we use this Order Information to:
Communicate with you;
Screen our orders for potential risk or fraud; and
When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services such as through email or SMS communication with the information you provide us.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful requests for information we receive, or to otherwise protect our rights.
BEHAVIORAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
COMMON LINKS INCLUDE:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://support.google.com/ads/answer/2662922?hl=en-GB
BING - https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads
PINTEREST - https://help.pinterest.com/en/article/personalization-and-data
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
THIRD PARTIES
We allow third parties to provide analytics services and serve advertisements on our behalf and on behalf of others across the web and in mobile applications. These third parties may use cookies, web beacons, and other technologies to collect information about your use of our website and other websites, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and these third parties to analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests on other websites and online services, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used in this way, please visit www.aboutads.info/choices.
We may also work with third parties to serve ads to you on our behalf or on behalf of other advertisers on third-party platforms (such as Facebook or Google). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us and others to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Advertising
We may use Service providers to show advertisements to You to help support and maintain Our Service.
Google AdSense & DoubleClick Cookie
Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
Their Privacy Policy can be viewed at https://www.facebook.com/privacy/explanation
TikTok
We may use TikTok pixels to publish targeted advertisements to you.
TikTok’s privacy policy can be viewed here: https://www.tiktok.com/legal/page/us/privacy-policy/en.
Email & SMS Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials, and other information that may be of interest to You. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email or SMS message We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails or SMS messages to You.
Their Privacy Policy can be viewed at
https://www.klaviyo.com/privacy
https://www.attentive.com/legal/privacy
Payments
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Shopify Pay
Their Privacy Policy can be viewed at https://www.shopify.com/legal/privacy
Behavioral Remarketing
The Company uses remarketing services to advertise on third party websites to You after You visited our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on Your past visits to our Service.
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
Rebuy and Loyalty Lion
Rebuy and Loyalty Lion are third party Shopify plugins that enable us to create customized user experiences for our users.
For more information regarding Rebuy’s privacy practices, please review their privacy notice at https://www.rebuyengine.com/legal/privacy-notice.
For more information regarding Loyalty Lion’s privacy practices, please review their privacy policy at https://loyaltylion.com/privacy.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI Services and DAA Services. Our Services is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.
DATA RETENTION
We will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for the purposes of satisfying any legal, accounting, or reporting requirements. With respect to location data, technical data, usage and interaction data, and marketing data, we may retain this data for so long as it is relevant to the uses disclosed in this Privacy Notice. We may retain account data, public data, and communications data for so long as you maintain a user account with Woolinos, and we may retain this data for longer periods where there is a need to retain this data to comply with Woolinos’s legal obligations, such as the preservation of electronic evidence or compliance with a preservation order.
Right of Access, Rectification, Correction, Erasure, Transfer, and Withdrawal
Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact Woolinos’s Data Protection Officer as disclosed in this Privacy Notice.
You do not need to pay a fee to access your PII or to exercise your rights. However, Woolinos may charge a reasonable fee if your request is unreasonable or excessive.
To confirm your request, Woolinos may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. Woolinos will attempt to respond to all legitimate requests within thirty (30) days.
Rights of European Citizens
Woolinos adheres to the EU-U.S. Data Privacy Framework (“DPF”) Principles, including the DPF’s Supplemental Principles, and while Woolinos is not compliance certified under the DPF, it follows the Principles in handling all data from EU-citizens. Woolinos is subject to the enforcement powers of the United States Federal Trade Commission (“FTC”) in relation to its handling of user data.
If you are a European citizen, you are entitled to certain rights regarding the protection of your Personally Identifiable Information and Personal Data, which are subject to limitations set forth in the EU GDPR and its applicable case law. These rights are:
- The right to access and correct the information that Woolinos processes about you;
- The right to transfer all or a part of the information collected about you to another data controller, where it is technically feasible;
- The right to the erasure of data concerning you, subject to Woolinos’s rights of retention under the law;
- The right to object to the processing of Personally Identifiable Information and Personal Data where you dispute the accuracy of the data, the processing is not lawful, Woolinos no longer needs the information for the purposes of processing, or you have raised an objection for personal reasons;
- The right to revoke your consent to data processing;
- The right to object to the processing of your Personally Identifiable Information and Personal Data for marketing purposes;
- The right to object to the processing of Personally Identifiable Information and Personal Data for direct marketing or for personal reasons that arise from your particular situation; and
- The right to file a complaint with a data protection authority.
To exercise these rights, you may either opt out of receiving communications from Woolinos by unsubscribing to its e-mails or by sending an e-mail to [email protected]. You do not need to pay a fee to exercise these rights, however, Woolinos reserves the right to charge a reasonable fee if your request is unreasonable or excessive. To confirm your request, we may need to request specific information from you as a security measure to ensure that personal data is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.
For further information regarding your privacy rights as a citizen of the EU, please visit the U.S. Department of Commerce’s Services at https://www.commerce.gov/ and the DPF overview webpage at https://www.dataprivacyframework.gov/s/program-overview.
You can find a list of DPF certified organizations here: https://www.dataprivacyframework.gov/s/
As a citizen of the EU, you may, under certain conditions, invoke binding arbitration against Woolinos, and Woolinos may be held liable in cases of onward data transfers to third parties as described more fully in DPF overview page linked above. Woolinos may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
California Privacy Rights
The following rules apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, B, D, F, and G) as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Notice:
Table T.1
|
Category |
Examples |
Collected |
|
A. Identifiers |
Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
YES |
|
B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)) |
Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. |
YES |
|
C. Characteristics of protected classifications under State or federal law |
Religious affiliation, ethnicity, etc. |
NO |
|
D. Commercial |
Records of products or services purchased. |
YES |
|
E. Biometric Data |
Fingerprints or footprints. |
NO |
|
F. Internet or other similar network activity |
Browsing history, search history, information on a consumer’s interaction with a Services, application, or advertisement. |
YES |
|
G. Geolocation data |
Physical location or movements. |
YES |
|
H. Audio, electronic, visual, thermal, olfactory, or similar information |
N/A |
NO |
|
I. Professional or employment-related information |
N/A |
NO |
|
J. Educational information |
N/A |
NO |
We obtain the categories of PII marked “YES” in the above table directly from California residents when they complete forms through our Services or provide it to us as a part of a transaction or inquiry concerning our Services. We also obtain these categories of PII indirectly from California residents while observing their actions on our Services and from third parties or service providers that they have authorized to receive and share PII.
California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you.
California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information.” By selecting this link or icon, you “Opt Out,” which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.
To submit a request for a list of the categories of personal information collected from you or to request that Woolinos delete your personal information, please email us at [email protected] or send a letter to us at the following address:
JoJo Group, LLC
Attn: Privacy Compliance Officer
19885 Detroit Rd. #130
Rocky River, OH 44116
To verify your request, we may request certain information from you to confirm that you are a Woolinos user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to Woolinos to disclose or delete your personal information. To do so, you must provide Woolinos with proof that the individual or business has been appointed as your agent, such as by providing a signed power of attorney form and provide accurate responses to any information requested by Woolinos that may be necessary to confirm that you are a Woolinos user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by Woolinos for their exercise of these rights conferred under California law.
Colorado Residents
Woolinos does not conduct business in Colorado, control or process the personal data of 100,000 or more consumers during a calendar year, or derive revenue or receive a discount on the price of goods or services from the sale of personal data.
Connecticut Residents
During the preceding calendar year, Woolinos did not control or process the personal data of at least 100,000 consumers or derive more than 25% of our gross revenue from the sale of personal data.
Montana Residents
Woolinos does not control or process the personal data of 50,000 or more Montana residents during a calendar year or derive over 25% of its revenues from the sale of personal data and control or processing of personal data of 25,000 or more Montana residents. Therefore, the Montana Consumer Data Privacy Act does not apply to our collection or use of PII.
Nevada Residents
If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may send us an email to [email protected] with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.
Tennessee Residents
Woolinos does not exceed $12.5 million in annual revenue, control or process the personal information of 175,000 or more Tennessee consumers, or control or process the data of 25,000 consumers while deriving more than 50% of its gross revenue from the sale of personal information.
Texas Residents
Woolinos is considered a small business as defined by the Small Business Administration and, therefore, is exempt from the Texas Data Privacy and Security Act. However, we generally collect and process PII only to the extent that it is adequate, relevant, and reasonably necessary for the purposes disclosed in this Privacy Policy. The categories of PII collected by Woolinos are disclosed within this Privacy Policy, in particular in Table T.1 above, and Texas residents may request, free of charge, information of the PII collected from them twice annually.
Utah Residents
Woolinos does not have annual revenues of $12500,000 or more and control or process the PII of 100,000 or more consumers. Therefore, the Utah Consumer Privacy Act does not apply to our collection and use of PII.
Virginia Residents
Woolinos does not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of its gross revenue from the sale of personal data. For these reasons, the Virginia Consumer Data Protection Act (VCDPA) does not apply to Woolinos’s collection and use of PII.
Third Party Links
Woolinos’s Services may include links to third-party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. Woolinos does not control these third-party links and you are advised to review their respective privacy policies.
CHILDREN UNDER THE AGE OF 13
We comply with the requirements of COPPA (Childrens’ Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age, and our products and services are marketed to individuals 13 years of age or older. If you believe that we have collected PII from someone under the age of 13, you are directed to notify us immediately at [email protected].
CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at [email protected] or by mail using the details provided below:
19885 Detroit Rd. #130, Rocky River, OH 44116, United States