Apeel’s Website Privacy Notice

Thank you for choosing to be part of our community at Apeel Technology, Inc., doing business as Apeel Sciences (“Apeel Sciences”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacy@apeelsciences.com.

When you visit our website https://www.apeelsciences.com,and use its services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as https://www.apeelsciences.com), or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services“).

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Effective Date/Last Updated Date: August 31, 2020


 1.  WHAT INFORMATION DO WE COLLECT?
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use.

Context

Type of Data

Primary Purpose for Collection and Use of Data

Cookies and first party tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Policy for more information.

We have a legitimate interest in making our website operate efficiently.

Cookies and Third Party Tracking

We participate in behavior-based advertising, this means that a third party usestechnology (e.g., a cookie) tocollect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Policy for more information.

Where required by law, we base the use of third party cookies upon consent.

Demographic Information

We collect personal information, such as your age or location.

We have a legitimate interest in understanding our users and providing tailored services.

Location Information

When you use our Services we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells our products.

We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.

Email Interconnectivity

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

We have a legitimate interest in understanding how you interact with our communications to you.

Feedback/Support

If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.

We have a legitimate interest in receiving, and acting upon, your feedback or issues.

Mailing List

When you sign up for one of our mailing lists we collect your email address or postal address.

We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores.

We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

Partner Promotion

We collect information that you provide as part of a co-branded promotion with another company.

We have a legitimate interest in fulfilling our promotions.

Surveys

When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.

Sweepstakes or contests

When you participate in a sweepstakes or contest we collect information about you which includes contact information to notify you if you are selected.

We have a legitimate interest in operating the sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.

Website interactions

We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.

We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

Web logs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

All personal information that you provide to us must be true, complete, and accurate, and you should notify us of any changes to such personal information.  

2.  HOW DO WE USE YOUR INFORMATION?
In addition to the purposes and uses described above, we use information in the following ways:
● To identify you when you visit our websites.
● To provide products and services.
● To improve our services and product offerings.
●  To conduct analytics.
●  To respond to inquiries related to support, employment opportunities, or other requests.
●  To send marketing and promotional materials including information relating to our products, services, or promotions, or those of our business partners.
●  For internal administrative purposes, as well as to manage our relationships.

Although the items above describe our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

3. INFORMATION SHARING
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
(a) Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
(b) Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
(c) Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
(d) Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
(e) Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them.Their use of your information is not governed by this privacy policy.
(f) Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

4.  OUR USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES?
We use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

5. DO WE USE GOOGLE MAPS?
Yes. We use Google Maps to provide more accurate services. You may find the Google Maps Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By using Google Maps through the Services, you agree to be bound by Google’s Terms of Service. By using Google Maps through the Services, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location information like ZIP code).

For a full list of what we use information for, please see the previous section titled “HOW DO WE USE YOUR INFORMATION?” and “INFORMATION SHARING” You agree to allow us to obtain or cache your location. You may revoke your consent at any time. Google Maps stores and accesses cookies and other information on your devices.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
As a multi-national company we transmit information between and among our affiliates, and our primary servers are located in the United States. As a result your information may be processed in a country where privacy laws maybe less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

7. HOW LONG DO WE KEEP YOUR INFORMATION?
We typically keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required by law (such as tax, accounting or other legal requirements).

8. HOW DO WE KEEP YOUR INFORMATION SAFE?
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

9. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least18. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under the age of 18, please contact us at privacy@apeelsciences.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?
You can make the following choices regarding your personal information:
(a) Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note thatCalifornia residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
(b) Changes To Your Personal Information. We rely on you to update and correct your personal information provided to us. If our website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
(c) Deletion Of Your Personal Information. You may request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
(d) Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
(e) Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
(f) Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you with certain services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Please address written requests and questions about your rights to privacy@apeelsciences.com or via postal mail us at the address provided below.

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for certain information to confirm your identity. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

(i)        A signed and notarized document indicating that you have authorization to act on the consumer’s behalf.
(ii)        If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.

11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

12. CALIFORNIA RESIDENTS
California law indicates that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information(if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contact Information" section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

13. UPDATES TO THIS POLICY
We may update this privacy policy from time to time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

14. CONTACT INFORMATION
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

Email: privacy@apeelsciences.com
Post: Apeel Sciences, ATTN: Privacy, 71 S Los Carneros, Goleta, CA 93117, United States

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

California Information Sharing Disclosure

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information(as that term is defined under California law). The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself.

Categories of Personal Information That We Collect

Categories of Third Parties to Whom WeDisclose Personal Information for Business Purpose

Identifiers – such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name or other similar identifiers.

● Service Providers
● Product and service fulfillment companies
● Internet service providers
● Advertising Networks
● Social Networks
● Payment Processors and financial institutions
● Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
● Data analytics providers

Network activity data– internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

● Service Providers
● Product and service fulfillment companies
● Internet service providers
● Advertising Networks
● Social Networks
● Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
● Data analytics providers

Geolocation data – such as precise physical location.

● Service Providers
● Internet service providers
● Advertising Networks
● Social Networks
● Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
● Data analytics providers

Inferences –drawn from any of the information listed above to create a profile

● Service Providers
● Advertising Networks
● Social Networks
● Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
● Data analytics providers