ITO EN (North America) Inc. (
INFORMATION WE COLLECT
We may collect the following types of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties. All of the information listed in (A)-(C) above, are detailed below, and hereinafter referred to as “Information.”
Information You Provide To Us:
In using our Services, you may provide us with Information, including, without limitation:
- Your legal name;
- Telephone number;
- Email address;
- Shipping and billing address;
- Payment details such as debit or credit card information if you are making a purchase; and/or
- Additional information as otherwise described to you at the point of collection or pursuant to your consent.
Information We Automatically Collect About You:
Our Services may automatically collect certain Information about you. We use this Information to help us design our Services to better suit our users’ needs. This Information may include:
- IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider), or your company;
- Date and time of your visit or use of our Services;
- Domain server from which you are using our Services;
- Type of computer, web browsers, search engine used, operating system, or platform you use;
- Data identifying the web pages you visited prior to and after visiting our website or use of our Services;
- Your movement and activity within the website, which is aggregated with other information;
- Geo-location information through the use of any of our mobile applications;
- Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
- Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.
Cookies & Technologies Used to Collect Information About You.
Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Services use retargeting pixels from Google, Facebook and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.
Mobile Device Identifiers. Certain mobile service providers uniquely identify mobile devices and we, our partners or our third-party service providers with whom we contract may receive such device information if you access the website through a mobile device. Certain features on the Website may require collection of mobile phone numbers and we may associate that phone number to mobile device identification information. Additionally, some mobile service providers operate systems that pinpoint the physical location of devices that use their services. Depending on the provider, we, our partners or our third-party service providers may receive this Information.
Embedded Scripts.An embedded script is programming code designed to collect Information about your use of the website, such as the links you click on. The code is temporarily downloaded to your computer from our web server or a third-party provider, is active only while you are connected to the website and is deactivated or deleted once you leave the website.
Analytics. Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.
Information We May Receive from Third Parties
We may collect additional Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, SnapChat (“Social Media Platforms”), and/or sources providing publicly-available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.
Information we may access about you, with your consent, may include, but is not limited to, your basic Social Media Platform information, your location data, your list of contacts, friends or followers and certain information about your activities on the Social Media Platform. Please keep in mind that when you provide Information to us on a third-party website or platform (for example, via our applications), the Information you provide may be separately collected by the third-party website or the Social Media Platform.
HOW WE USE YOUR INFORMATION
Use and Purpose of Processing Your Information
We use and process your Information for things that may include, but are not limited to, the following:
- Provide you with the Services, related products and information you request;
- To process your profile to open an account;
- To fulfill and manage purchase, orders, payments, returns/exchanges;
- To respond to your inquiries and provide you with requested information and other communications, including by email messages, and including alerts, notification of promotions and/or special sales;
- For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
- To fulfill contracts we have with you;
- To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
- Maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;
- Analyze the use of the Services and Information about visitors to our website to understand an improve our offerings and, in accordance with our sharing policies discussed below, to produce anonymous or aggregated data and statistics that might help third parties develop their own products and service offerings;
- To customize the content you see when you visit the website, including to develop and provide advertising tailored to your interests;
- Comply with our Terms & Conditions;
- Analytics for business purposes and business intelligence;
- Comply with any applicable laws and regulations and respond to lawful requests; and/or
- For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.
Sharing Your Information
We may disclose anonymized aggregated information about our users, that does not identify any individual, without any restriction.
- Third Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, process credit card payments, administer our customer rewards and loyalty program, manage product subscriptions, administrate product surveys and reviews, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your particular Information to identify you individually.
- Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
- Business Transfers. Your Information may be transferred, sold or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You agree to any and all such Conveyances of your Information.
- Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates. If you do not want us to share your Information with our subsidiaries and affiliates, please email us at firstname.lastname@example.org.
- Online Communications and Customer Loyalty/Rewards Programs. We may decide to allow users to voluntarily share comments, participate in surveys or contents, complete a product review, provide testimonials or other information or participate in customer loyalty/rewards programs. If you choose to submit such information to us or enroll in a customer loyalty or rewards program we offer on our Services, the information that you submit may be available generally to the public and will not be returned to you unless we receive such a request. Information that you provide in these areas may be read, collected, and used by others who access them.
LINKS TO OTHER WEBSITES
Our Services may contain links to other websites or social media features which are provided as a convenience, such as Facebook, Instagram, Pinterest, Twitter or YouTube and Vimeo. We are not responsible for the privacy and security practices of those websites or the information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other party’s website or content do not constitute or imply an endorsement or recommendation by us of the linked website or content.
We use commercially reasonable measures to provide our Services. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.
If you believe that your Information has been accessed or acquired by an unauthorized person, you shall promptly Contact Us so that necessary measures can quickly be taken.
We will retain your Information for as long as needed to provide you Services, or as permitted or required by law. If you wish to cancel your account or request that we no longer use your Information to provide you Services, please contact us at email@example.com. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.
HOW WE WILL CONTACT YOU
You agree that we, our affiliates, and/or third-party service providers with whom we collaborate and contract, may communicate with you regarding our Services via electronic messages, including email, text message, or mobile push notification to, for example, send you information relating to our products and Services that we think may be of interest to you, communicate with you about contests, sweepstakes, offers, promotions, sales, specials, upcoming events, and other news about products and services provided by or through us through permissible targeted advertisements offered by us, our parent companies, our subsidiaries, our affiliates, and other business partners. See Your Choices, below, for how you can update the way we contact you.
- Email. By using our Services, you agree that we may contact you by email as set forth herein. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of future marketing email communications or How to Contact Us.
- Text Messages. When using our Services, you will be presented with opportunity to receive shipping and delivery notification via text message. By providing your phone number, you agree to receive shipping and delivery notifications by text message. If you no longer want to receive text messages, please contact us at firstname.lastname@example.org.
- Location Choices. You can change the privacy settings of your device at any time to turn off the sharing of location information with our Services. If you choose to turn off location services, this could affect certain features or services of our Services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
Opting Out of Direct Marketing. To exercise choices regarding the marketing information you receive, you may also review the following links:
- You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at https://www.aboutads.info/appchoices.
- You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
- You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.
- Some users engage a Do Not Track (DNT) setting to indicate a preference regarding tracking by advertisers and other parties. We do not respond to DNT signals.
ACCESSING, CORRECTING, OR DELETING YOUR INFORMATION
Upon request as set forth below and subject to certain exceptions and limitations and applicable laws, we will inform you of the existence, use and disclosure of your Information and will provide you access to that Information. To the extent other state laws provide users with additional data subject rights, those rights may be honored by us following proper authentication and verification.
We encourage you to review, update, and correct Information that we maintain about you, and you may request that we delete Information about you that is inaccurate, incomplete, or irrelevant. We may not accommodate a request to change Information if we believe the change would violate applicable law in our control.
To access, correct, or delete your Information, contact us at:
NOTICE TO CALIFORNIA RESIDENTS
Data Subject Requests:
If you would like to submit a Data Subject Request, you can complete one online at https://itoen.com/pages/data-request. You can also call us, toll-free, at 1-888-832-7832. If you complete our online form, it must be completed accurately and completely before we can respond. If you choose to submit a Data Subject Request, you must provide us with enough Information to identify you and enough specificity on the requested data. We will only use the Information we receive for verification. We will not be able to disclose Information if it cannot verify that the person making the Data Subject Request is the person about whom we collected Information, or someone authorized to act on such person’s behalf.
If you are a California resident, you may submit a Data Subject Request to receive information about our data collection practices as it relates to your data. By submitting this request, you are declaring that you are a California resident availing yourself of the rights afforded to you under the California Consumer Privacy Act (CCPA).
You may request information on the categories of personal Information (as defined by California law) we have collected about you; the categories of data collection sources; any business or commercial purpose for collecting or selling personal Information; the categories of third parties with whom we share personal Information, if any; and the specific pieces of personal Information we have collected about you. If you would like to also receive information about our data disclosure for business purposes, then please include that in the Data Subject Request. We will clarify whether the Information was collected and disclosed or simply collected and kept internally.
The “Sale” of Personal Information under the California Consumer Protection Act
The California Consumer Protection Act gives California residents the right to stop the “sale” of their personal information through a mechanism called “Do Not Sell My Personal Information” button or hyperlink.
While there are many positive impacts of this requirement, California’s definition of “sale” also captures the transfer of data between corporate affiliates (that is, companies that share common ownership) and other transfers that ordinarily may not be thought of as a “sale” in the traditional sense of the word. Because the CCPA has defined some of these transfers as “sales,” we are unable to offer all of our services to our users that ask us not to “sell” their Personal Data.
California residents may utilize the “Do Not Sell My Personal Information” hyperlink located on our Services to facilitate their opt-out of the sale of certain personal Information. However, if you opt to request that we do not “sell” your personal Information you may not be able to use any service we offer that requires our continued use of your email address. Accordingly, users who direct us to stop “selling” their personal Information may be asked to delete their account with ITO En and their associated personal Information. Users who make this request will still be able to access all of the services we offer on our website and through our Services that are available to non-account holders and may always use a new email address to register a new account with our Services.
Please note that we will attempt to verify your identity via the email address and/or telephone number associated with your request prior to fulfilling it. If you authorize another person to make this request on your behalf, in addition to verifying your identity we will also require proof that the person is authorized to act on your behalf.
You may request that we delete your personal Information. Your deletion request should be submitted through a Data Subject Request. Subject to certain exceptions set out below we will, on receipt of a verifiable Data Subject Request, delete your personal Information from our records and direct any service providers to do the same.
Please note that we may not delete your personal Information if it is necessary to:
- complete the transaction for which the personal Information was collected;
- provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
- debug and repair internal information technology as necessary;
- undertake internal research for technological development and demonstration;
- exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act;
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the Information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- comply with an existing legal obligation; or
- otherwise use your personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Information.
We may not, and will not, treat you differently because you of your Data Subject Request activity. As a result of your Data Subject Request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal Information.
In addition, if you are a California resident under the age of 18 and are a registered user, you may request us to remove content or Information posted on our websites or stored on our servers by (a) submitting a request in writing to insert email, and (b) clearly identifying the content or Information you wish to have removed and providing sufficient information to allow us to locate the content or Information to be removed. However, please note that we are not required to erase or otherwise eliminate content or Information if (i) other state or federal laws require us or a third party to maintain the content or Information; (ii) the content or Information was posted, stored, or republished by another user; (iii) the content or Information is anonymized so that the minor cannot be individually identified; (iv) the minor does not follow the instructions posted in this Policy on how to request removal of such content or Information; and (v) the minor has received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or Information.
Accessibility of Privacy Notice
Please feel free to call us at 1-888-832-7832, or email us at email@example.com and we will work with you to provide the information, item, or transaction you seek through an alternate communication method or that is accessible for you consistent with applicable law (for example, through telephone support).
CONSENT TO TRANSFER
The website is intended only for users over the age of eighteen (18). If we become aware that a user is under 13 (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such information. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of thirteen (13).
HOW TO CONTACT US