Privacy policy

GLOBAL PRIVACY POLICY

Effective Date: November 28, 2023

Last Updated: November 28, 2023

Welcome to the Be Juliet website (www.bejuliet.com) and the Be Juliet mobile application, together with any materials and services available therein, and successor site(s) thereto (individually referred to as the “Site,” or collectively as the “Sites”), which are operated by It's Juliet LLC, a Delaware limited liability company (“Be Juliet” or “we” or “us”). 

This Global Privacy Policy (“Policy”) describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our Sites or other digital properties, communications, or forms that link or refer to the Sites.

The Be Juliet Terms of Service,  (“Terms”), state the terms and conditions governing your use of and access to the Sites and the services we provide through the Sites ("Services") and constitute a legally binding contract between you and Be Juliet. PLEASE REVIEW THE TERMS AND THIS POLICY CAREFULLY. YOUR ACCESS TO AND/OR USE OF THE SITES CONSTITUTES YOUR ACCEPTANCE OF, AND CONSENT TO BE BOUND BY, THE TERMS AND THIS POLICY. IF YOU DO NOT ACCEPT AND CONSENT TO BE BOUND BY THE TERMS AND THIS POLICY, THEN YOU MUST NOT USE OR ACCESS THE SITES. We may change the Terms or this Policy from time to time by notifying you of such changes by any reasonable means, including by posting revised Terms or Policy through the Sites. Any such changes will not apply to any dispute between you and us arising prior to the date on which we posted the revised Terms or Policy incorporating such changes, or otherwise notified you of such changes. The “Last Updated” legend above indicates when the Policy was last changed. 

Links to other websites. The Sites may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.

These Sites are not intended for children. We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to support@bejuliet.com.

Important information and who we are

Controller

It's Juliet LLC, a Delaware limited liability company, is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

Contact details

If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: It's Juliet LLC
Email address: dataprivacy@bejuliet.com
Postal address: 2108 N St #4501, Sacramento, CA 95816
Telephone number: 310-810-0065

You have rights to make complaints to applicable regulatory authorities of various jurisdictions but we would, however, appreciate the chance to deal with your concerns before you approach any such authority so please contact us in the first instance. 

Your duty to inform us of changes

We keep our Policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Contact Information. We collect full name, email address, current and prior postal address, telephone number, and any business contact information.
  • Identifiers. We collect Internet protocol address, signature, username and password, and social media user names.
  • Personal Characteristics or Traits. We collect date of birth, gender, age, nationality, citizenship status, military or veteran status and disability information.
  • Financial Information. We collect tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, card or account security details, and billing address.
  • Commercial Information. We collect records of products or services purchased, obtained, or considered.
  • Internet or Electronic Usage Data. We collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements and browsing time.
  • Audio/Visual Data. We collect audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings.
  • Geolocation Data. We collect geolocation data including the general region or area from which you access our Sites.
  • Inferences. We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your internet usage data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your contact information, identifiers, financial information and commercial information that you provide directly to usfilling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • order or apply for our products or services;
    • create an account on the Sites;
    • subscribe to our service or publications; 
    • request marketing to be sent to you;
    • enter a competition, promotion or survey;
    • visit our locations (contact information or audio/visual data); or
    • give us feedback or contact us. 
  • Automated technologies or interactions. As you interact with our Sites, we will automatically collect identifiers, geolocation data, and internet or electronic usage data. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive internet or electronic usage data about you if you visit other websites employing our cookies. 
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
    • Contact information, identifiers, internet or electronic usage data, financial information and commercial information from third parties including our vendors, clients, and service providers such as analytics providers such as Google, advertising networks such as Google AdSense, and search information providers such as Google.
    • Contact information, identifiers, commercial information and financial information from providers of technical, payment and delivery services, such as Electronic Merchant Systems.
    • Contact information and identifiers from publicly available sources, such as Facebook, Instagram, and Pinterest.
  • Social media platforms. Depending on the information you choose to share and your privacy settings, we may collect contact information, identifiers, audio/visual data, personal characteristics or traits, geolocation data, commercial information, professional or employment information, internet or electronic usage data, and inferences. Based on the way you have set your privacy settings on your social media accounts, most social media platforms, like Facebook and Instagram, analyze data about how you interact with our Sites and combine it with information on other users to provide us information about you. In addition, we may receive information about you if other users interact with us on social media and information about you is visible to us, for example the fact that you are “friends” or other public-facing profile information.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

See the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Transactional purposes

We use contact information, identifiers, financial information, and commercial information to: (i) provide you or our clients with products and services that we offer; (ii) communicate with you; (v) provide you with customer assistance; and (vi) provide supporting business activities such as billing and collections, procurement, and tax related activities.

Performance of a contract with you

Analytical purposes

We use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Marketing and promotional purposes

We use contact information, identifiers, financial information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new clients or candidates, client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.

Performance of a contract with you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Maintenance and improvement of our Sites and systems

We use identifiers, geolocation data, internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems.

Performance of a contract with you

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

Necessary to comply with a legal obligation

Develop and improve our products and services, including notifying you about changes to our Terms or Policy; asking you to leave a review or take a survey and enabling you to partake in a prize draw, competition or complete a survey

We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data and inferences to help us develop new products and services and to improve and analyze our existing products and service offerings.

Performance of a contract with you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Necessary to comply with a legal obligation

Security and fraud prevention

We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data and inferences to: (i) protect our Sites, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, our carriers and others from fraud, theft and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

Necessary to comply with a legal obligation

Legal

We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

Necessary to comply with a legal obligation

Other purposes

We may use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data and inferences for other reasons we may describe to you.

Necessary for our legitimate interests







 

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy center where you can view and make certain decisions about your personal data use. 

By submitting a telephone number to us you agree that a representative of Be Juliet, or a third party on behalf of Be Juliet, may contact you at the number you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message. Your consent is not an obligation to receive any of our products.

Promotional offers from us 

We may use your contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Sites and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies, analytics and other tracking technology

Our Sites use cookies to distinguish you from other users of our Sites. This helps us to provide you with a good experience when you browse our Sites and also allows us to improve our Sites.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Sites. They include, for example, cookies that enable you to log into secure areas of our Sites, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our Sites when they are using it. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognize you when you return to our Sites. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visits to our sites, the pages you have visited and the links you have followed. We will use this information to make our Sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

Our online store is powered by Shopify Inc. which places its cookies on the platform for our store. To learn more about those cookies, we refer you to https://www.shopify.com/legal/cookies. 

Please note that certain of our third party contractors may also use cookies, over which we have no control. These  parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

To deactivate the use of third-party advertising cookies, you may visit the consumer page to manage the use of these types of cookies at dataprivacy@bejuliet.com.

Do Not Track Signals

Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Global Privacy Control

Our website does respond to Global Privacy Control. 

Third-party Analytics and Advertising

We allow others to provide analytics services and serve advertisements on our behalf across the Internet and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Sites and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked and conversion information. We use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity. Please click here to change your preferences regarding analytics and advertising cookies.

Google Analytics

We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • Internal Third Parties as set out in the [Glossary]. 
  • External Third Parties as set out in the [Glossary].

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Please be aware that information we obtain about you will be processed in the United States and across Canada by our service providers or us. By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States, Canada or other jurisdictions may be different from the laws in your country of residence. The United States or Canada may not afford the same level of protection as laws in your own country.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

Data retention

How long will you keep my personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data to: 

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at dataprivacy@bejuliet.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers based in the USA or Canada who support the operation of our services, Site, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, order fulfillment, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, such as payment processors, the vendor or service provider may directly collect the information from you on our behalf.
  • Marketing, analytics or advertising partners (including social media platforms and networks), based in the USA or Canada, for commercial purposes such as sending you marketing emails.
  • Professional advisors including lawyers, bankers, tax consultants, auditors and insurers based in the USA or Canada who provide consultancy, banking, legal, insurance and accounting services where necessary in the course of the professional services that they provide us.
  • Regulatory and government entities based in the United States or Canada including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
  • Potential investors, purchasers, merger partners, and their advisors, who may be based in the United States, Canada or various other countries, in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
  • Third parties to whom you direct us or consent to our sharing of information for reasons we may describe to you.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

California Privacy Rights/Notice to California Residents

Shine The Light. If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at dataprivacy@bejuliet.com and include “CA Shine the Light” in the subject line of your email.

California Consumer Privacy Act ("CCPA").

Categories, Sources, and Uses of Personal Information We Collect. For details about precise data points we will collect, the categories of sources of such collection, and the business and commercial purposes for collecting personal information, please see the sections above titled "The data we collect about you," "How is your personal data collected?" and "How we use your personal data." 

Use or Disclosure of Sensitive Personal Information. We do not collect, use or disclose Sensitive Personal Information or Special Categories of Personal Data for purposes to which the right to limit use and disclosure applies under the CCPA.

Sale or Sharing of Personal Information. We will "share" (as that term is defined in the CCPA) identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences to marketing/analytics/advertising partners. However, we will not knowingly collect or share the personal information of minors under the age of 16. We will not "sell' (as that term is defined in the CCPA) personal information.

Disclosure for a Business Purpose. For a description of the categories of recipients and business purposes for which we share personal information, please see the sections above titled "The data we collect about you," "How is your personal data collected?" and "How we use your personal data."

Your Rights Under the CCPA. Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:

  • You have the right to request that we tell you (i) the categories of personal information we have collected, sold, or shared about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed, sold or shared personal information.
  • You have the right to request that we provide you with a copy of your personal information.
  • You have the right to request that we delete personal information that we have collected from you. We may not delete all of your personal information if one of the exceptions to the CCPA applies.
  • You have the right to opt-out of the sale or sharing of your personal information.
  • You have the right to direct us to limit the use or disclosure of your Sensitive Personal Information to only the purposes specified in the CCPA.
  • You have the right to correct inaccurate personal information that we hold about you.
  • You have the right to opt out of automated decision-making, including profiling.
  • You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.

Exercising Your Rights. To exercise any of your CCPA rights, please use our webform or call us  at 1-310-810-0065. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request.

If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.

In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at dataprivacy@bejuliet.com.

If you choose to use the Global Privacy Control (“GPC”) browser signal, you will only be opted out of online sales or sharing of personal information, and will need to turn it on for each browser you use. Disabling all cookies will also only opt you out of online selling or sharing relating to cookies. To submit a request to opt out of sales and sharing which would not otherwise be controlled by GPC or cookies, please use our webform or call us at the contact information above.

Notice of Financial Incentive. We do not offer a financial incentive for the collection, retention, sale, or sharing of personal information.

Metrics. We are not subject to the requirement to compile and report metrics regarding our responses to consumer requests during the prior calendar year.

Other Consumer Rights Information. Under California Civil Code Section 1789.3, we are required to provide California residents with the following information:

  • Unless otherwise expressly stated, the Sites are provided without charge.
  • To file a complaint regarding the Sites or to receive further information regarding use of the Sites, please contact us via email at privacy@bejuliet.com. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.

Removal of Content. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@bejuliet.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Canada Privacy Rights

Your Rights. If you are a resident of Canada, subject to certain exceptions and limitations, you have the following rights:

  • You have the right to request that we inform you of the existence, use, and disclosure of your personal information and provide you with a copy of that personal information within the timeframes provided for by law.
  • If the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified.
  • You have the right to contact us to request information about our data processing activities, namely what personal information was collected from you and how we process it. You may ask us to clarify the categories of third parties that have access to your personal information and the applicable retention period for that information.
  • You have the right to withdraw your consent to our collection, use, and disclosure of personal information at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising Your Rights. To exercise any of your rights, please use our webform or call us at 1-310-810-0065. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request.