INFORMATION WE COLLECT
To operate our Website and provide you with access to certain products and services, we may collect the following types of information which are described in more detail below: (A) information you provide to us, (B) information we automatically collect, and (C) information we 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 Website, you may provide your personal Information to us during your direct interactions, such as when you purchase products, access various content or features, contact us directly, or sign up for our newsletter. You may provide us with Information, including, without limitation:
- Your legal name;
- Telephone number;
- Email address;
- Shipping and billing address; and/or
- Payment details such as debit or credit card information if you are making a purchase.
Information We Automatically Collect:
We also collect information about you from your visit to our Website including:
- IP address;
- Your geographic location;
- Date and time of your visit;
- Domain server;
- Type of computer, web browsers, search engine used, operating system, or platform or web browser you use;
- Data identifying the web pages you visited prior to and after visiting our Website; and/or
- Your movement and activity within the Website, which is aggregated with other information.
We use a few different technologies to collect this Information:
Cookies. The Website may place small files, called “cookies” onto your computer. Cookies are data files that websites write onto computer hard drives for record keeping purposes when you visit them. The cookie file then identifies you as a unique user. Cookies make your use of these Website more pleasing and efficient by “personalizing” your Website experience and gathering Website statistical data, such as which parts of the Website you have previously visited, what material you downloaded, your Internet provider’s domain name and country, and the addresses of websites you visited immediately before and after our Website. They enable us to tailor the Information you receive and to assist our Partners or our third-party service providers with whom we contract identify you as our customer or Website user. Most web browsers automatically accept cookies, unless you have configured yours not to accept them. You can program your browser not to accept cookies, but if you do, you may not be able to use certain portions of the Website and the Website will not be able to customize certain features according to your preferences.
Web Beacons. Small graphic images or web programming code called web beacons (also known as “pixel tags” or “clear GIFs”) may be included on the pages of the Website and in email messages we send you. Web beacons or other similar technologies may be used for several purposes, such as to count visitors to the Website, monitor how you navigate the Website or to count how many particular links posted on the Website were actually viewed.
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.
You can opt-out of having your activity on the Website made available to Google Analytics by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) for your web browser.
Opting Out and Do Not Track: We, or third party companies with whom we collaborate or hire to perform services on our behalf, may use your Information to text, email, or contact or share with you with information that we believe may be useful to you, such as information about products or services provided by or through us through permissible targeted advertisements or related to our Website. You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1
- 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.
Information We Receive from Third Parties
We may collect additional Information about you from third party websites, or sources providing publicly available information, to help maintain and support your account, for advertising purposes on social network platforms, and to track or monitor your behavior on social media platforms. This information enables us to measure the effectiveness of various marketing advertisement for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users.
HOW WE USE YOUR INFORMATION
Use and Purpose of Processing Your Information
We use and process your Information above for things that may include, but are not limited to, the following:
- Process your profile to open an account;
- Fulfill and manage purchases, orders, payments, returns/exchanges;
- Provide any requested services;
- To respond to your inquiries;
- Communicate with you regarding our products and services, provided that you have not already opted-out of receiving such communications;
- Improve our Website and resolve any technical problems;
- Provide targeted advertisements to you;
- Analyze the use of the Website and Information about visitors to our Website to understand and improve our service 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;
- Customize the content you see when you visit the Website, including to develop and provide advertising tailored to your interests;
- Comply with our Terms and Conditions of Use (which is available on our Website);
- 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 or pursuant to your consent.
Lawful Basis For Processing Your Information
How Long We Keep Your Information
We generally keep Information for so long as it may be relevant to the purposes listed above, consistent with any applicable laws and agreements. To dispose of Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for an additional time.
Sharing Your Information
- Third Party Service Providers. In some cases we may employ third party service providers to perform certain services on our behalf, including, without limitation: (i) processing your order if you place an order or make a purchase; (ii) providing customer service; (iii) shipping, sending postal mail, newsletters and e-mails; (iv) analyzing, updating and correcting information we receive on the Website; (v) performing business analysis, data processing and/or quality control; (vi) providing marketing assistance, search results and links (including, without limitation, paid listings and links); (vii) processing credit card and debit card payments; (viii) hosting our databases; and (ix) providing you with information you requested. Consequently, we may share your Information with these third party service providers if they need it to perform services on our behalf. However, such third-party service providers are not authorized by us to use your Information for any other purpose.
- Disclosure of Customer 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 in investigations of fraud, intellectual property infringement or any other activity that is illegal or may expose us or you to legal liability; (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’s users; (v) to enforce or apply the Website’s Terms and Conditions of Use; and (iv) to verify the identity of the Website’s users.
- 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 consent to any and all such Conveyances of your Information.
- Online Communications: We may decide to allow users to voluntarily share comments, participate in surveys or contests, complete a product review, provide testimonials, or other information. If you choose to submit such information to us, 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 THIRD PARTY WEBSITES
Our Website may contain links to other websites or social media features which are provided as a convenience, such as Facebook, Instagram, Pinterest, Twitter or YouTube. 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.
OUR RIGHT TO CONTACT YOU
We may contact Website visitors who provide us information by way of email or telephone (including text messages) and you consent to us contacting you in these matters concerning our Website, this privacy statement, or related services or information we believe may be of interest to you. If you do not want to receive such communications, we provide customers with the opportunity to opt-out of receiving communications from us. If you no longer wish to receive specific communications or services, you have the following options:
- You can click the unsubscribe link in the email and follow the instructions providing for unsubscribing to future email correspondence.
- You can send an e-mail request to: email@example.com
- You may also at any time edit your itoen.com registration so that you no longer receive such e-mails.
- Call us toll-free at: 1-888-832-7832.
We use industry-standard procedures and safeguards to help protect the confidentiality of your Information. However, you should assume that no data transmitted over the Internet 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. We do not guarantee that your information will not be misused or disclosed to third parties. We will not have any liability for misuse or disclosure of your Information.
If you believe that your information has been stolen or accessed by an unauthorized person, you are required to notify us so that necessary measures can be taken immediately.
CONSENT TO TRANSFER
The Website is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Website, or providing us with any information, you consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. Portions of our site may be supported by a network of computers or cloud-based servers in other jurisdictions. We do not represent that our Website is appropriate or available in any particular jurisdiction.
ACCESSING YOUR INFORMATION
Upon your written request, subject to certain exceptions, we will inform you of the existence, use and disclosure of your Information and will give you access to that Information. Access requests should be sent by contacting us in the following ways:
- E-mail: firstname.lastname@example.org
- If you have an ITO EN account you may also update your account information under “My Account.”
- Call us toll-free at: 1-888-832-7832.
The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.
NOTICE TO CALIFORNIA RESIDENTS
Under California’s “Shine the Light” Law, you have the right to request what Personal Information you have shared with third parties, for the purpose of direct marketing, within the previous calendar year. Additionally, as a California resident, you have the right to opt-out of having your Personal Information shared with third parties who may use that information to market directly to you. We will not share your information after we have received your notification that you are opting out. If you wish to opt-out of having your Personal Information shared or request what Personal Information has been shared with third parties, you have the following options:
- You can send an email to: email@example.com
- You can call us toll-free at: 1-888-832-7832.
For all requests, please put the statement "Your California Privacy Rights" in the subject matter of your request.
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).