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VERB PRODUCTS INC. PRIVACY POLICY  

 

Effective Date: October 2023

 

At Verb we are committed to protecting the privacy and security of our customers’ personal information.

This Privacy Policy applies to all personal data we collect and process from individuals who interact with our services.

This Privacy Policy outlines our practices regarding the collection, utilization, and dissemination of your personal data related to our products and services, as well as your rights.

  

Information We Collect and the Methods and Sources of Collection

 

We collect the following categories of personal information:

 

Scenario

Categories and type of information processed

Methods and Sources of Collection

When you access or use the website, contact us, register as a user, order products through the Website, or submit a job application.

Identifiers : real name, address, telephone number, unique personal identifier (including cookies), online identifier, Internet Protocol address,   email address, electronic information such as the content of your message to us.

 

Internet or other electronic network activity information : your consent to our website terms and conditions and to receive our newsletter (via checking a check box), your general location (derived from your Internet Protocol address).

 

Sensitive information : account name and login and password.

 

Characteristics of protected classifications under law: Gender.

1.      Directly from you, the consumer.

2.      From your device, when you access and use our Website .

3.      Your gender is inferred by Google Analytics.

 

When you access or use the website or contact us.

Internet or other electronic network activity information, such as the activities performed on the Website, time and date of access, type of browser used, language use, links clicked and the web pages accessed.

From your device, when you access and use our Website .

When you access or use the website or contact us.

Inferences drawn from any of the above-identified information to create a profile about a consumer reflecting the consumer’s preferences

1.      Directly from you, the consumer.

2.      From your device, when you access and use our Website

 

When you order products through the Website.

Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies of our products.

 

Sensitive information: credit card number and security code.

Directly from you, the consumer.

 

 

 

 

 

When you submit a job application.

Name, contact details, demographic information,   address, qualifications, professional training, skills, hobbies and leisure activities, employment history, experience and education history, information presented in your CV (Curriculum Vitae) or cover letter, employment status, title, family status, background check, criminal record, status in the U.S., and information on your right to work in the U.S., your employment preferences, photos and links to webpages or websites you operate online.

 

Any additional information that you choose to share with us, such as application references, your salary expectations and current and historic salary information.

 

We also collect information about our assessment of your characteristics, skills, abilities, and aptitudes.

Directly from you, the consumer.

 

From recruiters and recruitment or placement agencies, references and past employers, from publicly accessible sources, such as LinkedIn and Facebook (where information is publicly available), from employment background check and criminal record checks providers

 

When you sign a document with us, such as an authorized reseller signing our Authorized Account Agreement, or a sweepstakes/contest winner signing our prize agreement.

Visual information: We collect your signature on the document

Directly from you, the consumer.

 

When you participate in contests or sweepstakes that we run.

Visual information: your contest or sweepstake entry.

 

Identifier and sensitive information: social security number, where required by tax laws to issue a tax form to report the value of the prize you won.

Directly from you, the consumer.

 

 

How We Use the Information We Collect

 

We will use your Personal Information in conducting our business, fulfilling orders, and processing transactions, and managing and providing services to you, which include the following:

 

       Providing, maintaining and improving our business;

       Fulfilling orders and processing transactions;

       Managing and providing services to you;

       Responding to your questions, concerns, and other requests for assistance;

       Customizing your browsing and shopping experience on the Website. We use information about your browsing and shopping activities to bring you a custom shopping experience, by offering products and advertisements tailored to your interests (please see our Cookies section below );

       Keeping you informed of administrative changes to our Website , including changes to our terms and conditions and other policies, and other information regarding the Website;  

       Analyzing Website statistics, such as usage and experiences impacting your browsing experience. We use this information to patch bugs and resolve other issues to present you with the best possible browsing experience. We also use cookies and other technologies to analyze how our customers interact with the Website, which helps us improve its functionality;  

       Conducting market research, which informs our marketing strategy and enables us to present you with a browsing experience tailored to your interests. For example, we create user profiles to enable personalized direct marketing communications;  

       Maintaining basic records, so that we may respond to and honor your requests to delete your data and prohibit future unwanted processing;  

       Preventing fraud, criminal activity, and misuses of our Website . We also use this information to block prohibited resellers from accessing our website and to safeguard the security of this Website, as well as our infrastructural security;  

       Complying with legal obligations and process, and to safeguard our rights, privacy, safety, and property, as well as your rights, privacy, safety, and property, and that of our affiliates and third parties;  

       Administering special offers, including contests, promotions, surveys, and other interactive Website experiences;  

       Enabling us to publish your reviews and other content;

       Applications for employment and employment-related purposes; Conducting a proper recruitment process, assessing how suitable you are for the position, deciding whether to hire you and, where relevant, preparing to enter into an employment agreement with you; Considering you for future openings at Verb other than the specific position to which you initially apply;

       Communicating with you, including through email. We may use the email address which you provide for order processing to send you information and updates about your orders, as well as occasional news, updates, marketing, and promotional information about our company and related products and services.   If at any time you would like to unsubscribe from receiving future emails, please refer to the detailed unsubscribe instructions at the bottom of each email;

       Communicating with you, including through SMS/text messaging. If you opt in by checking the acknowledgment box, thereby affixing your signature and giving us your express consent, we may use the telephone number which you provide to send you marketing and promotional messages using an automated system for the selection or dialing or phone numbers.   Signing up for SMS/text messages is not a condition of purchasing any property, goods, or services.   If at any time you would like to stop receiving future SMS/text messages, text “STOP” to the initial SMS message received or contact us at privacy@verbproducts.com.

       Notifying you about special offers and products or services available from us, our affiliates or our partners that may be of interest to you.

 

We do not use or disclose sensitive personal information for purposes other than those permitted in the privacy laws.

 

How Long We Keep Your Personal Information

We will keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law ( e.g. for tax, legal, accounting or other purposes), whichever is longer.  

 

To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we use your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer need to retain your Personal Information, it will be deleted or be anonymized so that you can no longer be identified from it.

 

How We Protect And Store Your Information

We are committed to making sure your privacy is protected when you use our Website and when we collect information from you. We take the security of your information seriously, and implement a variety of security measures to maintain safety of all Personal Information you provide. We also make sure that third parties we use to process your Personal   Information also use appropriate security measures to protect your data.

 

When we collect sensitive information like your credit card information, social security number (where required by tax laws), financials, etc., that information is encrypted and securely transmitted. For example, we use a secure server for transmitting sensitive information. All supplied sensitive/credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. You can verify that this sensitive information is being transmitted securely by looking for “https” at the beginning of the address of the webpage.

 

After a transaction is completed, your sensitive information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.  

 

The safety and security of your information also depends on you. We urge you to be careful about entering information on public computers or on public networks.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to or stored on our Website .

Notice of the Right to Opt-Out Using the Opt-Out Preference Signal

You have a right to opt-out of sharing your personal information for behavioral targeted ads. You can exercise this right by using the opt-out preference signal as explained here.

We process the opt-out preference signal if it is sent by your browser in accordance with the "global privacy control". For more information on how to install and implement the global privacy control, please visit globalprivacycontrol.org/#download.

If you turn on this global privacy control in your browser, we will receive the signal, process it in a frictionless manner, and treat it as a request to opt-out of the use of your personal information for behavioral-targeted ads. The opt-out request is specific to the browser in which you have it turned on. It is effective as an opt-out request only while you use that browser to surf the web.

Disclosures to Others

 

We will not disclose your information to third parties for their own uses, except in the events listed below or when you provide us your explicit and informed consent.

 

We share your Personal Information with our affiliated companies and with trusted third parties who help us run our Website , manage our business, and serve you. This includes hosting and cloud service providers, payment processors, order management and fulfillment services, e-commerce platforms, review platforms, email and customer support services, SMS/text messaging services, and web analytics, marketing, and digital advertising services.

 

These companies are obligated not to use your information for their purposes, to keep this information confidential and use appropriate security measures to protect your information.

 

We do not sell your personal information and have not done so in the past 12 months.

 

Categories of personal information

Categories of third parties to whom we disclose your information and the specific business or commercial purpose for the disclosure

Identifiers

 

 

·        With outside legal counsels and authorities, for the purpose of responding to, handling, and mitigating suspected violations of law in connection with our business.

·        With third parties to which a law or binding order requires us to disclose your information. Our purpose in doing so complying with our obligations under the law or the binding order.

·        With the target entity of our merger, acquisition or reorganization, and legal counsels, and advisors, for the purpose of facilitating the structural change in the operation of our business within a different framework, or through another legal structure or entity (such as due to a merger or acquisition).

Electronic information

Sensitive information: account name and login and password

Commercial information

Internet or other electronic network activity information

Professional or employment-related information

Education information

Inferences drawn from any of the above-identified information to create a profile about a consumer reflecting the consumer’s preferences

 

 

The chart below explains about the personal information we share for online behaviorally targeted ads in the preceding 12 months. We do not have actual knowledge that we share the personal information of consumers under 16 years of age for online behaviorally targeted ads.

 

Categories of personal information

Categories of third parties to whom we share your information for online behavioral-targeted ads

The specific business or commercial purpose for sharing your information for online behavioral-targeted ads

Identifiers

 

 

 

 

 

 

Advertising networks

·        To distinguish the device you use to access the Internet from other devices based on information it automatically sends, such as IP address or browser type.

·        To show you ads based on the content you’re viewing, the app you’re using, your approximate location, and your device type.

·        To measure the performance and effectiveness of ads and other content that you see or interact with.

·        To receive and send technical information that enables your device to present and interact with ads and content.

·        To show you personalized ads and other content based on a profile about your visits to our website.

Internet or other electronic network activity information

Inferences

 

 

SMS/Text Messaging

 

If you choose to receive text messages from us by ticking the box and submitting, we'll send messages to the phone number you give us.

By doing this, you're stating that you're at least 16 and you own the phone number. We might ask you to confirm again that you want our text messages. You don't have to sign up for texts to buy anything from us.

If you need help, reply "HELP" to our first text message or email us at privacy@verbproducts.com. If you want to stop getting texts, reply "STOP" to our first text or email us. We'll send one more text to say we've stopped sending them.

You can sign up again on our website whenever you want. The number of messages we send varies. You might have to pay to receive them.

If you sign up for our text messaging program, cookies may be used to personalize your experience (e.g. send you personalized text messages such as shopping cart reminders).

 

 

Data Subject Rights

 

·        Protection against discrimination . You have the right not to be discriminated against because you exercised your rights under this section of the Privacy Policy, and we will not discriminate against you for doing so.

·        Right to know : You have the right to know what personal information is collected about you and how it is used. This includes the following information:

o    The categories of personal information collected.

o    The purposes for which the personal information is collected.

o    The third parties with whom the personal information is shared.

o    The choices you have about how your personal information is used.

·        Right to access : You have the right to access your personal information. This means that you can request a copy of the personal information that a business has collected about you.

·        Right to delete : Subject to certain exceptions set out below, you have the right to request the deletion of the personal information that we have collected from you.  

Please note that we will not delete your personal information if it is necessary to:

o    Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.

o    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

o    Debug to identify and repair errors that impair existing intended functionality.

o    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.

o    Comply with the Electronic Communications Privacy laws.

o    Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.

o    Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.

or

o    Comply with an existing legal obligation.

We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the law applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.

·        Right to opt out of targeted advertising : You have the right to opt out of targeted advertising. This means that you can request that a business not use your personal information to target you with advertising.

·        Right to know more : You have the right to know more about how your personal information is used, including how it is shared with third parties. This includes the following information:

o    The specific purposes for which your personal information is used

o    The specific third parties with whom your personal information is shared

o    The specific choices you have about how your personal information is used

·        Request that your personal information be corrected or updated : You have the right to request that your personal information be corrected or updated if it is inaccurate or incomplete.

In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.

We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.

We may deny your request to correct in the following cases:

o    We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.

o    We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

o    Conflict with federal or state law.

o    Other exception to the applicable Privacy Rights Act.

o    Inadequacy in the required documentation.

o    Compliance proves impossible or involves disproportionate effort.

We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information.

·        Limit the use of your sensitive personal information : You have the right to limit the use of your sensitive personal information. This means that you can request that a business not use your sensitive personal information for certain purposes, such as marketing.

·        Right to opt out of the sale of your personal information to third parties for their own marketing purposes : You have the right to opt out of the sale of your personal information to third parties for their own marketing purposes.

·        Right to restrict the use of your sensitive personal information : You have the right to restrict the use of your sensitive personal information. This means that you can request that a business not use your sensitive personal information for certain purposes, such as marketing.

·        Right to port your personal information to another business : You have the right to port your personal information to another business. This means that you can request that a business provide you with a copy of your personal information in a format that you can easily transfer to another business.

·        Right to restrict the use of your sensitive personal information : You have the right to restrict the use of your sensitive personal information. This means that you can request that a business not use your sensitive personal information for certain purposes, such as marketing.

·        Right to sue businesses that violate the relevant regulation : You may have the right to sue businesses that violate the relevant regulation. This right varies depending on the specific regulation.

 

For purposes of exercising your rights above, please note the following regarding how we collected and used your personal information during the 12 month period preceding the effective date of this Privacy Policy:

 

        We collect the categories of personal information as indicated in this Privacy Policy in the section titled “Information We Collect and the Methods and Sources of Collection”.  

        We disclose the personal information for a business purpose as recited in this Privacy Policy in the section titled “Disclosures to Others”.

        We share personal information for online behaviorally targeted ads as recited in this Privacy Policy in the section titled “Disclosures to Others”.

        We use the above categories of personal information as indicated in the above section of this privacy policy entitled “How We Use the Information We Collect”.

 

Exercising your rights and methods for submitting requests

If you wish to contact us to submit a request please contact us by email at privacy@verbproducts.com.

 

You may have an authorized agent contact us to submit a request; however, to do so, we require that You (1) provide the authorized agent with signed permission to do so and (2) verify Your own identity. If the authorized agent is not an individual having power of attorney, We also require (3) that You directly confirm that You provided the authorized agent permission to submit the request.  

 

We may need to verify your identity to enable us to process your request. The verification process will include your receipt of an email with a secured link asking you provide us with two or three points of data about you that we have on file. Such personal information may include your name, your mailing address, date of birth, purchased items, and corresponding   purchase totals. Disclosure and/or deletion will not be completed if a consumer request cannot be verified.  

 

Notice of Financial Incentive

We offer our customers membership to Verb Friends With Perks (“Loyalty Program”), a loyalty program that provides certain perks such as exclusive gifts with purchase, early access to purchase new products, and free shipping on all orders. For a full list of benefits, please visit the Verb Products website https://www.verbproducts.com/pages/friends-with-perks.  

 

In order to provide you with the perks described above, we use personal information about you including your name, phone number, email address, birthdate, purchase history, etc. to identify you as a member of the program and provide you with relevant messaging, experiences, and deals.

 

You may opt-in to the Verb Friends With Perks Rewards Program by creating an account on the Verb Friends With Perks landing page ( https://www.verbproducts.com/pages/friends-with-perks ) .

 

You have a right to withdraw from the Verb Friends With Perks at any time. To do so, please email   Verb Products Customer Service at INFO@VERBPRODUCTS.COM.

 

These financial incentives are reasonably related to the value of the data you provide. Our Loyalty Program is considered a Financial Incentive Program pursuant to privacy laws. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program. This value is based on the expense related to offering those products, services, and benefits to Program participants.  

 

California Minors Who Are Registered Users

 

If you are under the age of 18, reside in California and are a registered user of the Website, you have the right to request that we remove content or information you posted on the Website.   Please send an email to privacy@verbproducts.com with “California Minors Content Removal” in the subject line of your message.   Please note that our removal of content or information you posted may not ensure complete or comprehensive removal of the content or information.  

 

Protecting Children’s Privacy

 

We are a general audience site. Our Website , products, and services are all directed to people who are at least 16 years of age or older. We do not knowingly collect, use or disclose any information from anyone under 16 years of age. Similarly, we do not have actual knowledge that we share the personal information of consumers under 16 years of age for online behaviorally-targeted ads, or that we sell the personal information of consumers under 16 years of age.

 

We understand and are committed to respecting the sensitive nature of children’s privacy online. If we discover that we have inadvertently collected information from anyone under 16 years of age, any information regarding that user will be promptly deleted. If you believe we might have any information from or about anyone under 16 years of age, please contact us by using the information below.

 

Changes to Our Privacy Policy

 

We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Website home page. If we make material changes to how we treat the information collected from our users, we will also post a notice on our Website home page. The date the Privacy Policy was last revised is identified at the top of the page.

 

We will also make an effort to proactively notify you of any material changes by sending an email to you, if we have your email address on file.

 

Contact Us

 

If you have any questions or concerns regarding this Privacy Policy or data processing, if you would like to change or access the Personal Information we have collected from you, or if you would like to make a complaint, you may contact us using the information below. You may also be able to refer a complaint to your local data protection regulator if you are not satisfied with the way we handled your complaint.

 

Email: privacy@verbproducts.com    

Mailing Address: Legal Department; 5742 Ferrier Street, Montreal, QC. Canada H4P 1M7