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Privacy Policy

 

Date revised and posted: November 15, 2023

Cemayla, LLC (dba “FoundRae”) and its affiliates and subsidiaries (collectively "FoundRae" "We" "Us" or "Our") respect your concerns about privacy. This Privacy Policy applies to personal information We collect on this website ("FoundRae Website") and any other website, mobile device application, social media Internet property or related services owned or operated by FoundRae (collectively, the "Sites") and in our retail stores ("Stores").

This Privacy Policy does not apply to personal information collected through any other website.

From time to time, FoundRae may modify this Privacy Policy. In that event, the modified Privacy Policy will appear at this location. In certain circumstances, you may be notified of such changes by email or other means.

1. Purpose

Your privacy is important to Us. This Privacy Policy has been developed as an extension of Our commitment to combine the finest quality products and services with the highest level of integrity in dealing with Our customers. This Privacy Policy describes the types of personal information We collect about you when you visit Our Sites and Our Stores, how We collect it, how We use it, with whom We share it, how long we retain it, and your choices and rights regarding Our use of this personal information. We also describe the measures We have adopted to protect your personal information and how you can contact Us about Our privacy practices.

As a general matter, We collect personal information to deliver the products and services you request, to help improve your shopping experience, and to support our business functions. These purposes include auditing interactions with consumers, detecting security incidents, performing services on behalf of the business, debugging to identify and repair errors that impair existing functionality, internal research for technological development and demonstration, and activities to verify or maintain the quality and safety of FoundRae's website and other business undertakings.

2. What Personal Information Is Collected?

FoundRae may collect the following categories of personal information:

  • Identifiers – including real name, postal address, shipping and billing address, unique personal identifiers, online identifiers, and email address.
  • Information in customer records – including name, signature, address, telephone number, credit card number, and debit card number.
  • Protected classification information – including gender.
  • Commercial purchasing information – including records of products and services purchased.
  • Internet activity – including browsing history, search history, and information regarding a consumer's interaction with the FoundRae website.
  • Inferences – including profiles drawn from the above informational categories to create a profile about you reflecting your interests, preferences, characteristics, attitudes, or other personal characteristics.


We may also keep a record of your product interests and purchases online and in stores. We collect the personal information described in this section only if you choose to share such information with Us. If you choose not to provide the personal information We request, then We may not be able to respond to your or provide you with Our products services, as permitted by law.

3. How do We Collect Personal Information

We collect personal information about you in two key ways: (1) information We directly receive from you and (2) information We receive through cookies and other technologies.

Personal Information You Provide

Personal information We receive from you includes that which you actively share with us, such as your activity on Our website, including when you complete online forms, register or subscribe for accounts or electronic newsletters or features on the Sites, make online purchases, enter sweepstakes or contests, complete surveys, post materials, contribute to a chat room, bulletin board, list serve, blog, wiki or other open forum that We may make available on or through the Sites, submit a comment or question to Us using the "Contact" feature or similar feature on the Sites, or send Us an email or in any other way submit personal information to Us via Our Sites.

Personal Information We Obtain by Automated Means

Personal information We collect through cookies and other technologies (such as web beacons (including pixels and tags), web server logs) helps Us correct or supplement our records, improve the quality of Our services to you, and prevent and detect fraud. We receive personal information, such as information about users who visited Our Sites but did not purchase goods, from various third-party sources.
A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect personal information about your equipment, browsing actions, and usage patterns. The personal information We obtain in this manner may include your device IP Address and other identifiers associated with your device, domain name, location, language preferences, country settings, web browser characteristics, and device characteristics. We may also record the referring website or search engine that brought you to the Sites; the pages you visit on the Sites; the website you visit after the Sites; the ads you view or click on; your product interests and purchases; any search terms you have entered on the Sites or a referral site; and other web usage activity.

To learn more about cookies and the other automated technologies We use, and to learn how to change your cookie preferences, click here. To the extent required by applicable law, We will obtain your consent for using cookies or similar technologies.

4. How Is the Collected Personal Information Used?

We use the collected personal information for the purposes described in this Privacy Policy and, to the extent required by applicable law, rely on a number of legal bases to do so, including where (1) necessary for the performance of a contract with you or to take pre-contractual steps at your request; (2) necessary for Our legitimate business interests or those of third parties as discussed in more detail below; (3) necessary for compliance with a legal obligation to which We are subject, a court order, or to exercise or defend legal claims; or (4) you consent to the processing, which consent you can withdraw at any time by updating your communication preferences at foundrae.com and clicking the "Unsubscribe" feature or by contacting us as indicated in the "How to Contact Us" section below.

We use the personal information We collect where necessary to perform a contract with you or to take steps at your request prior to entering into a contract, including to (1) provide customer support; (2) transact with you and provide you with Our products and services; (3) process and fulfill your order and keep you informed about the status of your order; and (4) create and manage your account with FoundRae.

In addition, We use the personal information We collect if We have a legitimate interest to do so and where your interests and fundamental rights do not override those interests (which We can explain to you in further detail upon request by contacting Us as indicated in the "How to Contact Us" section below), including to (1) operate, develop, evaluate and improve the Sites and Our business (including developing new products and services; enhancing and improving Our products and services; managing Our communications; analyzing Our products and services and customer base; analyzing the effectiveness of Our marketing efforts; performing data analytics; and performing accounting, auditing and other internal functions); (2) personalize and improve your experience with Our Sites and Our products and services; (3) send you promotional materials and other communications (for example, emails, mailings, newsletters and the like)), although, where required by applicable law, We will send these communications only with your consent; (4) communicate with you about Our products and services; (5) communicate with you and administer your participation in contests, sweepstakes, events, surveys or market research; (6) protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities; (7) reduce credit risk and manage collections; (8) improve security and administer the Sites; and (9) comply with relevant industry standards and policies, including this Privacy Policy and Our Terms of Use.

We also process your personal information to comply with and enforce applicable legal requirements to which We are subject and for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

To the extent required by applicable law, if We plan to use the personal information We obtain for any other purpose, then We will provide an additional notice to you to describe the purposes for which We will use the personal information and Our legal basis for doing so.

5. When Do We Share Personal Information and Usage Information with Others?

We do not disclose personal information We collect about you, except as described in this Privacy Policy.


During the 12-month period prior to the effective date of this Privacy Policy, We may have disclosed each of the categories of personal information described above for a business purpose to the following categories of third parties:

Co-Sponsored Contests, Sweepstakes and Offerings

Some of Our contests, sweepstakes and other offerings that are made available on or through the Sites from time to time may be co-sponsored by another company. In those situations, the personal information We obtain from you in connection with such contest, sweepstakes or offering may be shared with Our co-sponsor and in accordance with terms disclosed in such contest, sweepstakes or offerings. To the extent required by applicable law, We will obtain your consent to do so. In those situations, Our co-sponsors will have the right to use your information for their own purposes, in accordance with their own policies and in particular in accordance with any specific disclosures made to you at the time you participate in such contest, sweepstakes or offering. We are not responsible for the privacy practices of Our co-sponsors.

Service Providers

We use third party partners to provide Our e-commerce solution and to help operate the Sites and deliver Our products and services. We may share your personal information with third party e-commerce solution partners, Our affiliates, service providers and other third parties that provide products or services for or through the Sites or for Our business (such as loyalty program or membership program service providers, site hosting or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, fulfillment companies, wireless device applications, or other similar service providers that use such information on Our behalf). With respect to payment processing, for United States sales, We interface directly with Our payment processor, Shopify, which then shares your information with payment providers for the purpose of processing payments. Similarly, for international sales, We interface directly with Our partner Global-e, which then shares your information with one of its payment processors for the purpose of payment processing. Neither our payment processor nor Global-e uses your information for any purpose other than payment processing. We require our service providers to (1) use personal information only as necessary to perform services on Our behalf and (2) implement appropriate data security and confidentiality obligations, in accordance with applicable law.

Social Media

Like many organizations, we use the tools offered by platforms and social media companies for marketing purposes. This means that, if you are registered with FoundRae and also a registered user with a platform such as Facebook or TikTok, we may match your email so that you can see promotions and content for FoundRae on your feed. You can change your settings on those platforms at any time to opt out of targeted advertising and we don't receive any information about you back from those platforms.

Legally Compelled Disclosures

We may disclose personal information and other information to law enforcement authorities and other third parties when We believe it is necessary to identify, contact, or bring legal action against persons or entities to protect FoundRae or Our customers, to enforce laws, intellectual property rights and other rights or when We believe that disclosure is required by the law or legal process. We may disclose user information to government authorities or to other third parties when compelled to do so by government authorities, at Our discretion or as required by law in Our good faith belief, including but not limited to in response to court orders and subpoenas and as otherwise required in connection with a judicial or government proceeding or legal process. This may include in connection with the enforcement of this Privacy Policy or Our Terms of Use. We also may disclose user information when We have reason to believe that someone is causing injury to or interfering with Our rights or property, other users of the Sites, or anyone else who could be harmed by such activities.

Business Transfer

We also reserve the right to transfer personal information We have about you in the event We, Our affiliates, sell or transfer all or a portion of Our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

  1. How Long We Retain Personal Information

    To the extent permitted by applicable law, We retain your personal information We obtain about you for as long as it is needed (1) for the purposes for which We obtained it, in accordance with the terms of this Privacy Policy, which generally means that We will keep your personal information for the duration of Our relationship or as long as you keep your account open with Us; or (2) to take into account applicable statute of limitation periods and comply with mandatory applicable laws. As described in the "Your Rights" section of this Privacy Policy, to the extent provided by the law of your jurisdiction, you may request that We delete your information or restrict the processing of such information by contacting Us as indicated below.

    7. Your Rights

    By law, you have a number of rights when it comes to your personal information. The rights you have depend on the jurisdiction in which you are based.

    You have the right to be provided with clear, transparent and easily understandable information about how We use your information and your rights. This is why We are providing you with the information in this Privacy Policy.

    We offer you certain choices in connection with the personal information We collect about you. At the time you are requested to provide personal information on the Sites, you may have the opportunity to elect to, or not to receive correspondence from Us. Where required by applicable law, We will obtain your consent to send you marketing communication and newsletters about Our products and services, and invite you to participate in events, contests, sweepstakes and surveys. If you wish to opt out/object to/withdraw consent to Our correspondence, you may also do so at any time by updating your communication preferences at foundrae.com and clicking the "Unsubscribe" feature or by contacting Us as indicated in the "How to Contact Us" section. You may also opt out of FoundRae's promotional emails at any time by clicking on the opt-out link within the email you receive. Please note that if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful and it may take up to up to ten business days for your request to become effective and during such time you may receive email notifications from FoundRae. If you opt out of receiving promotional correspondence from Us, We may still contact you in connection with your relationship, activities, transactions and communications with Us.

    To learn more about managing your preferences in relation to the information We collect on an automated basis, using cookies and similar technologies, please see Ad & Cookie Policy.

    To the extent provided by the law of your jurisdiction, you may request access to the personal information We maintain about you or request that We correct, update, amend, or delete your information, or restrict the processing of such information by contacting Us as indicated below. As permitted by the laws in your jurisdiction, you also may review and correct the personal information that has been collected by FoundRae or by resubmitting your information using the "Subscribe" feature located on the FoundRae Website or by contacting Us as indicated below.

    Subject to applicable law, you also have the right to receive, in a structured, commonly used and machine-readable format, the personal information that you have provided to Us about you, with your consent or based on a contract to which you are party. Subject to applicable law, you also have the right to have this information transmitted to another company, where it is technically feasible.

    To exercise these rights, please contact Us as indicated in the "How to Contact Us" section below. If you are a resident of the UK/EEA, you also may lodge a complaint with your national data protection authority if you are not satisfied with Our response.

    We will endeavor to respond to your request as soon as practicable and in compliance with applicable law. Before We are able to respond to your request, however, We may ask you to verify your identity and to provide other details to help Us address your request. For all rights, We usually act on requests and provide information free of charge, but, where allowed under the law, We may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, We may be entitled to refuse to act on the request in some circumstances.

    8. Additional Information for California Residents

    Last Updated: November 15, 2023

    This section applies to solely to California residents, including job applicants who reside in California, except that this section does not apply to FoundRae personnel.

    This section uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 ("CCPA") (as amended by the California Privacy Rights Act of 2020 (the "CPRA")) and its implementing regulations (collectively, the "CCPA/CPRA").

    Notice of Collection and Use of Personal Information

    We may collect (and may have collected during the 12-month period prior to the effective date of this section) the following categories of personal information about you:
  • Identifiers: identifiers such as a real name, postal address, shipping and billing address, unique personal identifier (such as device identifiers; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address.
  • Additional Data Subject to Cal. Civ. Code § 1798.80: credit card number and debit card number.
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as age, gender, gender identity, gender expression.
  • Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history and information regarding your interaction with FoundRae websites, applications or advertisements.
  • Geolocation data
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, and attitudes.


For job applicants residing in California, only:

  • Employment Information: professional or employment-related information, such as resume information, occupation details, education details, certifications and professional associations, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information.


We may use (and may have used during the 12-month period prior to the effective date of this section) the categories of personal information listed above for the purposes described in our Privacy Policy and for the following business purposes:

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
  • Providing advertising and marketing services to you, except for cross-context behavioral advertising;
  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
  • Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us;
  • Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Undertaking internal research for technological development and demonstration; and Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Us.


For job applicants residing in California, only:

  • Managing career opportunities with us (including recruiting; processing job applications; performing background checks and conducting due diligence; determining suitability for employment; determining physical and/or mental fitness for work; accommodating a disability or illness; reviewing and evaluating applications; determining salary and other forms of compensation; providing references; reimbursing expenses; making travel arrangements; securing immigration statuses; reviewing hiring decisions; providing access to facilities; and contacting you regarding your job application and informing you about benefits or other information relating to your potential employment with us).


Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in our Privacy Policy and this section, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

Sources of Personal Information

During the 12-month period prior to the effective date of this section, We may have obtained personal information about you from the following categories of sources:

  • Directly from you, such as when you make a purchase with us
  • From your devices, such as when you visit our Sites
  • Our affiliates and subsidiaries
  • Vendors and service providers who provide services on our behalf
  • Data analytics providers
  • Our business and joint marketing partners
  • Online advertising services and advertising networks
  • Sweepstakes and contests, affinity groups, or other marketing campaigns
  • Social networks
  • Financial institutions


For job applicants residing in California, only:

  • Your family or friends
  • Recruiting and talent agencies
  • Job references (such as your employers and teachers)
  • Publicly available sources (such as public databases)
  • Data brokers (such as credit bureaus, credit reporting service providers, and background check services)


Sale or Sharing of Personal Information

We do not sell or share personal information for monetary consideration. We may share your personal information by allowing certain third parties (such as online advertising services, advertising networks and social networks) to collect your personal information via automated technologies on our Sites for cross-context behavioral advertising purposes. This kind of sharing may be considered a "sale" under the CCPA/CPRA when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information.

We may sell or share (and may have sold or shared during the 12-month period prior to the effective date of this section) the following categories of personal information about you to online advertising services:

  • Identifiers
  • Commercial Information
  • Online Activity
  • Inferences


We do not have actual knowledge that We sell or share the personal information of minors under 16 years of age.

Disclosure of Personal Information

During the 12-month period prior to the effective date of this section, We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Categories of Personal Information

Categories of Third Parties

Identifiers

• Our affiliates and subsidiaries
• Vendors who provide services on our behalf
• Professional services organizations, such as auditors and law firms
• Data analytics providers
• Operating systems and platforms
• Our business and joint marketing partners
• Online advertising services and advertising networks
• Social networks
• Co-sponsors of contests, sweepstakes or other promotions
• Financial institutions

Additional Data Subject to Cal. Civ. Code § 1798.80

• Our affiliates and subsidiaries
• Vendors who provide services on our behalf
• Financial institutions

Protected Classifications

• Our affiliates and subsidiaries
• Vendors who provide services on our behalf
• Data analytics providers
• Our business and joint marketing partners
• Online advertising services and advertising networks

Commercial Information

• Vendors who provide services on our behalf
• Data analytics providers
• Our business and joint marketing partners
• Online advertising services and advertising networks

Online Activity

• Vendors who provide services on our behalf
• Data analytics providers
• Our business and joint marketing partners
• Online advertising services and advertising networks

Geolocation Data

• Vendors who provide services on our behalf
• Data analytics providers
• Our business and joint marketing partners
• Online advertising services and advertising networks

Inferences

• Vendors who provide services on our behalf
• Data analytics providers
• Online advertising services and advertising networks


For job applicants residing in California, only:

Employment Information

• Your family or friends
• Recruiting and talent agencies
• Job references (such as your employers and teachers)
• Publicly available sources (such as public databases)
• Data brokers (such as credit bureaus, credit reporting, service providers, and background check services)


In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this section, We may have disclosed personal information about you to government entities (e.g., in response to law enforcement requests) and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

California Consumer Privacy Rights

If you are a California resident, you have the right to:

Access: You have the right to request, twice in a 12-month period, that We disclose to you the personal information We have collected, used, disclosed and sold or shared about you within the previous twelve months, including personal information We have disclosed to another company for a business purpose.

Correction: You have the right to request that We correct the personal information We maintain about you, if that information is inaccurate.

Deletion: You have the right to request that We delete certain personal information We have collected from you. With respect to deletion requests, note that, if you choose to delete your personal information, then you may not be able to use certain website or in-store functions that require personal information to operate. Opt-Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes. With respect to opt-out of sale requests, note that We do not sell your personal information for monetary consideration. However, as described above, under some circumstances a transfer of personal information to a third party without monetary consideration may be considered a "sale" under California law.

Shine the Light Request: You also may have the right to request that We provide you with (a) a list of certain categories of personal information We have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. We share personal information with third parties for the direct marketing of their products only if We have your affirmative consent (opt in).

We will not discriminate against you choosing to exercise any of your rights under California law.

How to Submit a Request

To submit a (a) Shine the Light request or (b) a request to access, correct or delete your personal information, you may (1) send Us an email at legal@foundrae.com, (2) call Us at 1-844-731-0808, or (3) write to Us at Cemayla LLC, 52 Lispenard Street, New York, New York 10013 Attn: Chief Executive Officer. To opt-out of the sale or sharing of your personal information, (1) follow the instructions provided this link, (2) send Us an email at clientcare@foundrae.com, (3) call Us at 1-844-731-0808, or (4) write to Us at Cemayla LLC, 52 Lispenard Street, New York, New York 10013 Attn: Chief Executive Officer. To submit a request as an authorized agent on behalf of a consumer, please email, call, or write to use as described above, and provide proof of authorization to act on behalf of a California resident.

As indicated above, to help protect your privacy and maintain security, We will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, We may verify your identity by requiring you to sign in to your account. If you do not have an account with Us and you request access to or deletion of your personal information, We may require you to provide any of the following information: postal address, email address, phone number, and proof of most recent purchase. In addition, if you do not have an account and you ask Us to provide you with specific pieces of personal information, We may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

9. Data Transfers

The personal information that We collect from you or that obtain from third parties, including Global-e, will be processed by FoundRae in the United States. We also may share this information with Our affiliates, including those located in the United States. In addition, Our service providers may be located in countries other than the country in which you originally provided your personal information, including in France where, along with the United States, Global-e hosts some user personal information. Some of these countries may not have the same data protection laws as the country in which you provided the personal information. When We transfer your personal information to other countries, We will protect that information as described in this Privacy Policy. We will also comply with the applicable data transfer laws of other countries.

10. Security

We maintain appropriate security measures (including administrative, technical and physical safeguards) designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Third-Party Features

Our Sites may provide links to other online services for your convenience and information, and may include third-party features such as apps, tools, widgets and plug-ins (e.g., Facebook or Twitter). These online services and third-party features may operate independently from Us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which We strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Us, FoundRae is not responsible for these third parties' information practices.

Please be aware that if you disclose personal information on social media sites, website message boards or chat areas, that information may be collected and used by third parties without Our knowledge and may result in unsolicited communications from third parties. Such activities are beyond Our control and subject to those third parties' privacy statements.

12. Children's Privacy

FoundRae is concerned about the safety of children when they use the Internet. We encourage parents and guardians to spend time with their children online and to be familiar with the sites their children visit. Our Sites are designed for a general audience and are not directed at children. Accordingly, We do not knowingly collect personal information from children under the age of 16 (or other age where parental consent may be required) without prior verifiable parental or guardian consent when legally required. If We become aware that We have inadvertently received personal information from a child under the age of 16 (or other age where parental consent may be required) without the legally required prior verifiable parental or guardian consent, We will delete such information from Our records.

13. Changes to your information

It is important that the personal information We hold about you is accurate and current. Please keep Us informed if your personal information changes during your relationship with Us.

14. How to Contact Us

Cemayla LLC, 52 Lispenard Street, New York, New York 10013 is the data controller and is responsible for the processing of your information as described in this Privacy Policy.

Questions or comments may be directed to: Tel: +1-844-731-0808, or email: clientare@foundrae.com.