Pepper Body Inc.
Privacy Notice

Last modified: July 5, 2023

Pepper Body Inc., d/b/a “Pepper” (the “Company”, “Pepper”, or “we”) respects your privacy and is committed to protecting it through our compliance with the practices described in this Privacy Notice.

This Privacy Notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal information we may collect from you or that you may provide when you visit our website (https://www.wearpepper.com/), or communications or forms that link or refer to this Privacy Notice (collectively, our “Website”), including purchasing products or services through our Website. You can access this Website in many ways, including from a computer or mobile phone, and this Privacy Notice will apply regardless of the means of access. This Privacy Notice applies to the personal information collected through our Website, regardless of the country where you are located. This Privacy Notice is governed by our Terms of Use.

This Privacy Notice also governs the use of personal information we obtain from you from any third party site or application where we post content or invite your feedback or participation, including, but not limited to, Twitter, Facebook, Instagram, YouTube, Pinterest, TikTok, YouTube and Google+ (collectively, “Third Party Sites”). Pepper cannot control the privacy policies or practices of Third Party Sites or of companies Pepper does not own or control, and cannot control the actions of people Pepper does not employ or manage. You should always check the privacy policies of Third Party Sites and your privacy settings. Please see “Social Commerce and Third Party Sites” below for additional information.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES FOR PROCESSING AND STORING YOUR INFORMATION. BY ENGAGING WITH OUR WEBSITE, YOU ACCEPT AND CONSENT TO THE PRACTICES SET FORTH IN THIS NOTICE. IF YOU DO NOT AGREE TO THIS NOTICE, DO NOT ACCESS OUR WEBSITE, ENGAGE US FOR OUR SERVICES, AND/OR PURCHASE OUR PRODUCTS.   

This Privacy Notice may change from time to time (see “Changes to Our Privacy Notice”). Your continued engagement with our Website after any such revisions indicates that you accept and consent to them.

Information We May Collect About You

We collect and use different types of information from and about you including:

• Contact information and personal identifiers, such as your name, address, email address, telephone number, date of birth, and social media handle.
• Device identifiers, such as information about your device like your IP address, or other online identifiers.
• Demographic information, such as your age, sex, and gender (some of which may be protected by applicable law).
• Approximate location of your device based on IP address.
• Physical characteristics that you share through completing our Start Fit Quiz.   
• Commercial information, such as the products you have purchased, returned or considered, and your product preferences.
• Payment information, such as your method of payment, items in your card, and purchase history (including items purchased and date of purchase).
• Identity verification information, in order to verify you when you call customer support or make other requests.
• Online or network activity information, such as information regarding your interaction with our Website,, digital properties, and advertisements, information about your browsing and search history on our Website, and log file information, which includes, but may not be limited to, your browser type, webpages you visit, and other electronic network activity.
• User Contributions (as defined below), such as your communications with us and any other content you provide (including photographs, videos, reviews, articles, survey responses, and comments).
• Additional contact information, personal identifiers, demographic information, and any other information you may provide if you submit a job application and/or inquire about employment opportunities at Pepper. This may include employment history, resume, educational transcripts, reference contact information, compensation information you voluntarily provide, background check information (subject to applicable laws and regulations), and sensitive personal information that you provide voluntarily or which we request on a non-mandatory basis in order to comply with applicable law.
• Personal information collected from Third Party Sites. 
• Inferences drawn from or created based on any of the information identified above.

If we combine or connect non-personal, technical, or demographic data with personal information so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

Note regarding credit card information. Except as set forth above, we do not collect, receive, or use your credit card information, though a credit card is required to purchase some products. We utilize vendors to process your credit card information to complete your purchases for products and your choices regarding use of credit card information are described in the “Your Personal Information Choices” section below.

Note regarding sensitive personal information. Certain jurisdictions have enacted laws with different requirements regarding the processing of certain sensitive personal information. “Sensitive Personal Information” includes health-related information, government identifiers such as social security numbers, biometric data, and special categories of personal information identified by European and other data privacy laws. We do not require sensitive personal information from you when using the Website or purchasing our products. In the cases where we do seek to collect sensitive personal information, for example when conducting recruiting activities, we will seek to do so in accordance with applicable data privacy laws. Do not provide us with unsolicited sensitive personal information.

How We Collect Your Information

We may collect or may have collected personal information about you from various sources. The categories of sources from which we may collect personal information are the following:

1. Direct interactions. We collect information directly from you, such as when you make a purchase on our Website, contact us with a question or complaint, create an account on our Website, register for our loyalty program (Pepper Perks), respond to a survey, participate in a contest or other promotion, or sign up to receive marketing communications. Please note that in order to create an account, the only personal information you have to provide is an email address.
2. Friends or family members. If your friend or family member sends you a gift or makes a referral to you through our Website.
3. Cookies and automatic collection methods. As you interact with our Website and when you open or click on emails we send you, we (and third parties we work with) may automatically collect information from your browser or device using technologies such as cookies, web beacons, pixel tags, and similar technologies. For additional information about cookies and other automatic collection methods, see “Cookies and Automatic Data Collection Technologies” below).
4. SMS Abandoned Cart: The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.
5. Third Party Sites or publicly available sources. We may receive information about you if you visit Third Party Sites.
6. Third Party Data Sharing: We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.
7. Business partners, service providers, and affiliates. We may receive information about you from our business partners and service providers, such as demographic companies, analytics providers, advertising companies and networks, third party retailers, and other third parties with which we work and/or collaborate. We may receive information from you from affiliates of ours if you have interacted with such affiliates.
8. Social media platforms. We may receive information about you from social media platforms and networks, such as Facebook, Twitter, Pinterest, TikTok, YouTube, and Instagram. For example, we may obtain your information from a social media platform or network if you interact with us on social media.
9. User Contributions. You also may provide information, data, and materials, including, but not limited to, product reviews, photographs, and personal anecdotes, for us to publish or display (“post”) on public Website areas, transmit to other Website users or third parties, and/or post publicly to social media platforms (including, but not limited to, Third Party Sites) that mention our Company via our handles (collectively, “User Contributions”). You submit User Contributions for posting and transmission to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Website users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions. Please see our Terms of Use for additional restrictions governing User Contributions. 
10. Employment application process. We may also receive information about you if you submit a job application, inquire about opportunities at Pepper, provide us your information at a recruiting event, or if we receive information about you from third parties in connection with our recruiting activities. 

How We Use Your Personal information

We may use or have used the information we have about you, including your personal information, for the following purposes:

• To provide products and services to you, such as fulfilling orders and processing payments, creating, servicing and/or maintaining your account or any loyalty program membership you may have with us, assisting with product selection and replenishment, and managing current or past purchases.
• To communicate with you, including to respond to your inquiries or complaints, and to help you place an order.
• To administer your participation in special events, contests, sweepstakes, surveys, promotions and our referral and loyalty programs.
• For marketing and advertising, such as to send you marketing and advertising materials via postal mail, text message or email, to show you advertisements for products and/or services tailored to your interests on social media and other websites, and to acknowledge certain dates that you have provided to us (e.g., your birthday).
• For analytics purposes, such as to understand how you use our Website, understand your preferred method of purchasing with us; determine what browser and devices you use to visit our Website; and to evaluate and improve our products, services, advertisements, and website and mobile applications.
• To operate and improve our business, including to provide quality assurance, conduct research and development to develop new products and services, and perform accounting, auditing and other internal business functions.
• For legal and security purposes, such as to detect, prevent, and prosecute harmful, fraudulent, or illegal activity, loss prevention, identify and repair bugs on our Website, and to comply with applicable legal requirements, relevant industry standards and our policies.
• We also may use or may have used the information in other ways for which we provide specific notice at the time of collection.
• For other business purposes in the context of a merger, acquisition, asset sale/purchase or administration/bankruptcy.
• To detect your geographic region to provide a version of our Website specifically created for your country of access.
• To respond to your inquiries related to employment opportunities or other requests.
• Provide you with targeted offers and advertising, including on the Website, via direct mail, SMS messages, e-mail, or push notifications, and to contact you about upcoming sales, promotions, offers and product information to help to promote our business and tailor our advertising to you.
• You may also receive our offers in advertising that is directed to you via Third Party Sites and media properties, including in social media to help to promote our business and personalize our ads. 

We may also use personal information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your personal information in this way, please see “Your Personal Information Use Choices” for opt-out methods.

We may use personal information to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may use non-personal information for any business purpose.

Disclosure of Your Personal information

We may share your personal information with:

• Service providers that provide products or services to us, that help us market or advertise to you (including co-branded marketing and advertising and other brand collaborations), that provide products or services to you (such as delivering packages to you), that collect and process payment information, or that manage our loyalty program (including sending you loyalty rewards). Even with this access to personal information necessary to perform these functions, those third parties are not authorized by Pepper to disclose your information for any other purposes. If, however, you become a direct customer with such third party (e.g., by subscribing to a mailing list of such third party or opening an account directly with such third party), then the third party’s privacy policy would apply to the collection of your personal information for that purpose and not this Privacy Notice. 
• Social media platforms and networks such as Facebook, Twitter, Pinterest, TikTok, YouTube, and Instagram that offer functionalities, plugins, widgets, or tools in connection with our Website (e.g., to share inspiration, finds, purchases, and other content with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies—for more information about what information is shared or collected, and how it is used, see the applicable social media company's privacy policy.
• Online third party companies (including Third Party Sites) for advertising purposes, including to: serve advertisements across the Internet; track and categorize your activity and interests over time on our Sites and mobile application, and on third party websites and mobile applications; and to identify the different device(s) you use to access websites and mobile applications. We share information with these companies, and these companies may collect information—including automatically collected information when you use our Website. These third party companies also may possess or obtain information about you from your interactions: directly with the third party companies; with other websites, mobile applications, or companies that the third party companies work with; or from your interactions with advertisements the third party companies help to display to you. The information that these companies collect or that we share may be used to customize or personalize the advertisements that are displayed to you. We may share personal information with the third party companies we work with for our purposes, though in general we do not share personal information about you with third parties for third party marketing or advertising purposes. We may also share other information at our discretion, including automatically collected information, which may be used by third parties for third party marketing, advertising, and other purposes.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• For any other purposes that we disclose when you provide the information.
• With your consent.

We may also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
• To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal information we hold.
• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply our Terms of Use. 
• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We may share non-personal information without restriction.

Cookies and Automatic Data Collection Technologies

A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. To collect information automatically, Pepper and its service providers may use cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Website, as well as track and understand email campaign effectiveness. Our use of cookies is specified in our Cookies Policy, which is updated regularly to reflect current practices. You can turn off your web browser's ability to accept cookies, but if you do so, certain parts of our Website may not work for you.

Your Personal Information Use Choices

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We have established the following personal information control mechanisms:

1. Promotional Offers from the Company. If you do not want us to use your contact information to promote our own products and services, or third parties’ products or services, you can opt-out by checking the relevant box located on the form where we collect your data (the order form or registration form), at any other time by clicking “unsubscribe” on the email communication or by replying “STOP” to a SMS communication, or by sending us an email with your request to privacy@wearpepper.com. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.
2. Third Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form where we collect your data (the order form or registration form), at any other time by clicking “unsubscribe” on the email communication or by replying “STOP” to a SMS communication, or by sending us an email with your request to privacy@wearpepper.com.
3. Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about tracking technologies, please see “Cookies and Automatic Data Collection Technologies”. 
4. Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by checking the relevant box located on the form where we collect your data (the order form or registration form), by adjusting your settings in your account profile, and by sending us an email stating your request to privacy@wearpepper.com. For this opt-out to function, you should opt out of all cookies except Essential cookies using the “Cookies Preferences” link in the footer of our Website.
5. Do Not Share/Sell My Information. You may exercise your right not to have your personal information sold or shared by clicking “Do Not Share/Sell My Information” in the footer of our Website or click on the following link:

Do Not Sell or Share My Personal Information

Our Website contains links to and from Third Party Sites. If you follow a link to any third party website or engage a third party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these third parties.

The Company currently does not support Do Not Track (“DNT”). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.

Social Commerce and Third Party Sites

We work with third parties, including social network sites like Twitter, Facebook, YouTube, Instagram, Pinterest, and Google+, and with application developers who specialize in social commerce so we can connect to your social networks. All of these companies operate Third Party Sites. We provide access to our Website by third parties and business partners so we can generate interest in our products among members of your social networks and to allow you to share product interests with friends in your network.

The use of any features made available to you on our Website by a third party may result in information being collected or shared about you by us or by the third party. Information collected or shared through any such third party features is considered public information by us because the Third Party Sites made it publicly available. If you do not want us to be able to access information about you from Third Party Sites, you must instruct Third Party Sites not to share the information. Pepper is not responsible for how these third parties may use information collected from or about you so be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a Third Party Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt out of sharing such information. However, we do identify any areas on our Website where third parties share information about you.

We use features on Third Party Sites that allow you to express positive opinions about our products or purchase our products. Those Third Party Sites may collect or register your views about our products (including whether you purchased a product) and make those views available to Pepper and on public portions of the Third Party Sites. If you do not wish any of this to happen, you should not express your views about our products on Third Party Sites, you should not buy our products through Third Party Sites, and you should review your privacy settings on such Third Party Sites. We are not obligated to display your name or other identifying information, account name, profile photo or other information or content on our Website even if you express an opinion about one of our products or have consented to our use of such information or content.

We reserve the right to remove the information of any person for any reason. We may also remove from our Website, in our sole discretion, any product offering or any photo or product description relating thereto. If you would like us to delete the data we have collected about you that we have received through any social media provider or Third Party Site, please contact us. However, if your information is deleted you may not have access to certain promotions, product information or opportunities as a result. In addition, we may not delete your personal information if an exception under applicable data protection privacy laws and regulations applies.

Linked Websites

For your convenience, hyperlinks may be posted on the Website that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Website. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy policies of each Linked Site that you visit to understand how the information that is collected about you is used and protected.

Accessing and Correcting Your Personal Information

You can access, review, and change your personal information by logging into the Website and visiting your account profile page. You may also send us an email at privacy@wearpepper.com to request access to, correct, or delete personal information that you have provided to us. Alternatively, you may submit a Data Subject Access Request Form (https://www.wearpepper.com/pages/data-subject-access-request-form). We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy. Once deletion is requested, we will also transmit your request to Shopify, which will in turn transmit your erasure request to all Shopify apps installed on our Website that may have access to your personal information. Shopify will not erase personal information if you have placed an order in the last 6 months (180 days) (the “Order Window”)  in case a chargeback occurs. If a request for erasure is submitted during the Order Window, the request will remain pending until the Order Window closes and Shopify will take appropriate action at that time. You do not need to submit an additional request.

You may request deletion of your online reviews, as well as any social media content you have created that was linked to or reported by Pepper by emailing privacy@wearpepper.com. Please note that if your User Contributions are deleted from the Website, copies of your User Contributions may remain viewable in cached and archived pages or because other Website users may have copied or stored them. Our Terms of Use govern proper access and use of information provided on the Website, including User Contributions. 

Consent to Transfer of Your Personal Information

We are based in the United States of America (“USA”). We may process, store, and transfer the personal information we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. By submitting your personal information or engaging with our Website, you consent to your information being transferred to our systems and facilities, and to the systems and facilities of those third parties with whom we share information, as described in our Privacy Notice. If we do this, we have procedures in place to ensure your data receives the necessary protections. Any transfer of your personal information will follow applicable laws and we will treat the information according to the principles set out in this Privacy Notice.

If you are located outside of the USA, Canada, the United Kingdom, and Australia, you may provide us with your email address to be notified when our products are available for purchase in your country. By providing us with your email address, you explicitly consent to such notification and to the transfer of your personal information from the country where you are located to the USA.

Privacy Notice for Residents of Certain States in the USA

Some USA state laws  provide state residents with additional privacy rights. This Privacy Notice meets current U.S. state privacy and data protection law and will be updated as these laws evolve. We do not sell your personal information as defined by any applicable US law, including the California Consumer Protection Act (2018), as amended by the California Privacy Rights Act (the “CCPA”).

California Residents: Additional Disclosures Related to Collection, Use, and Disclosure of Personal Information

If you are a California resident, the CCPA requires us to disclose the following information with respect to our collection, use and disclosure of personal information (referred to in this section as “personal information”).

• Categories of Personal Information Collected: In the preceding 12 months, we have collected the following categories of personal information: identifiers, personal information categories listed in the California Customer Records statutes, protected classification characteristics under California or federal law, commercial information, internet or other similar network activity, geolocation data, sensory data, professional or employment-related information, inferences drawn about your preferences and sensitive information. For examples of the personal information we collect, please see “Information We May Collect About You” above.
• Business or Commercial Purpose for Collecting and Using Personal Information: We collect personal information for the business purposes described in “How We Use Your Personal information” above.
• Categories of Sources of Personal Information: We collect personal information directly from you, automatically, and from other sources, each of which is more particularly described in “How We Collect Your Information” above.
• Categories of Personal Information Disclosed for a Business or Commercial Purpose: In the preceding 12 months, we have disclosed personal information for business or commercial purposes as described in “Disclosure of Your Personal Information” above. 
• Categories of Third Parties with whom We Share Personal Information: We may share your personal information with the third parties as described in “Disclosure of Your Personal information” above.
• Sale of Personal Information: We do not as a matter of course “sell” personal information as defined in the CCPA; however, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)) and you have a right to opt out of such sharing. To exercise your opt-out right, see the subsection “Do Not Share/Sell My Information” in the section entitled “Your Personal Information Use Choices” above or send an email to privacy@wearpepper.com. Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.

Your Consumer Rights

California consumers have the right to request access to their personal information, additional details about our information practices and deletion of their personal information (subject to certain exceptions). We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information.

Right to Know: You may request access to the specific pieces of personal information we have collected about you in the prior 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the sources of such collection, the categories of personal information we share for a business or commercial purpose, the categories of third parties with whom we share your personal information, and the specific pieces of personal information we collected about you (also called a data portability request). We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

Right to Deletion: You may request that we delete the personal information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law, and we may deny your deletion request if retaining the personal information is necessary for us or our service providers under one of the nine statutory exceptions listed in Cal. Civ. Code § 1798.105, as amended by AB 1146. We are required by law to verify your identity prior to deleting your information in order to protect your privacy and security. If you request to delete your personal information, certain of our products and services may no longer be available to you.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us in writing at Pepper Body Inc., 263 South 4th Street, PO box 169, Brooklyn, NY 11211, USA, send an email to privacy@wearpepper.com. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; and/or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Financial Incentive
We may offer you various financial incentives such as discounts and special offers when you provide us with contact information and identifiers such as your name and email address. When you sign-up for our loyalty program, email list, or other discounts and special offers, you opt-in to a financial incentive. You may withdraw from a financial incentive at any time by opting out from our email or closing your loyalty member account. Generally, we do not assign monetary or other value to personal information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the personal information is related to the estimated cost of providing the relevant financial incentive(s) for which the information was collected.

Complaints
In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your personal information. California residents with inquiries or complaints regarding this Privacy Policy should first contact us at please submit your request by calling us at 855-968-2783 or by emailing us at privacy@wearpepper.com.

California’s Shine the Light Law
California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to request more information under the California Shine the Light law, you can email us at privacy@wearpepper.com. 

Privacy Notice for Residents of Canada

We retain personal information for as long as you have an account with us in order to meet our contractual obligations to you and in accordance with “Retention of Data” below.

Please contact us at privacy@wearpepper.com if (i) you wish to access, update, and/or correct inaccuracies in your personal information or change your consent preferences (please note that we may need to collect additional personal information for the purposes of verifying your identity before responding to your request; (ii) you would like additional information about how our foreign-based service providers process your personal information; and/or (iii) if you have any questions or complaints about the manner in which we treat your personal information.

Privacy Notice for European (including UK) and Australian Residents

We take steps to require that we handle your personal information subject to appropriate safeguard. Please see “Consent to Transfer Personal Information” above, which describes how your information may be transferred to and from the United States to other countries.

We retain your personal information in accordance with “Retention of Data” below.

Personal information is collected on the following legal bases for processing:

• Necessary for Performance of a Contract: If we or our affiliates have entered into a contract with you, for example to sell, ship, and support products, we may need to process your personal information.
• Consent: Where you have provided your consent for us to engage in marketing activities with you, we may need to process your personal information. As set forth herein, you have the right to withdraw your consent at any time.
• Legitimate Interest: We may need to process your personal information where we have a legitimate interest in doing so, such as (1) to communicate with you in response to your requests, questions, inquiries, and submissions; (2) to conduct advertising, marketing and promotional activities in connection with operating our business; (3) for Website and product research and development, including operation, security and optimization of our Websites and improvement of our products and product selection; and (4) for fraud prevention.
• Comply with Legal Obligations: Where we are required to comply with laws or legal obligations.

You have certain rights related to the processing of your personal information in certain circumstances:

• Access: You may request to receive a copy of your personal information in machine-readable form.
• Delete: You may request we delete some personal information, subject to certain exceptions.
• Correct or Rectify: You may correct or change some personal information that we store about you; in particular, to correct inaccurate information.
• Object to or Restrict Processing: You may object to our processing of some personal information about you or restrict or limit our use of some personal information about you.
• Transfer: You may request, to the extent feasible, the transfer of your personal information to another data controller.
• Consent Withdrawal: You may withdraw consents you previously granted to us.
• Automated Decision-Making: You have the right not to be subject to automated decision-making, including profiling, which produces legal effects concerning you or similarly significantly affects you, with certain exceptions. We do not generally engage in such automated decision-making in our Website, and if we do, we comply with applicable legal requirements in connection with such data processing. We do not as a matter of course conduct automated decision-making.

Certain other details regarding the processing of personal information that you may be entitled to receive are contained in other provisions of this Privacy Notice. We note that all rights listed above will not apply to all territories.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority:

• For Australian customers: you may be able to lodge a complaint with the Office of the Australian Information Commissioner: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint.
• For UK customers: The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data. For further details please see https://ico.org.uk/.

 Children’s Online Privacy

We do not direct our Website to minors and we do not knowingly collect personal information from children under 13. If we learn we have mistakenly or unintentionally collected or received personal information from a child without appropriate consent, we will delete the information from our records. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at privacy@wearpepper.com.  

Opt-Out from Mailings

From time to time, you may receive periodic mailings, e-mails, or other communications from us with news or other information on events, products, discounts, special promotions, or other offers from or on behalf of Pepper. If at any time you wish to stop receiving communications from us please send us an email to privacy@wearpepper.com with the phrase "Privacy Opt-out: PepperMailings" in the subject line, or write to us at the address provided below, and we will remove you from our mailing list. Alternatively, for email communications, you may opt out of receiving such communications by following the unsubscribe instructions set forth at the bottom of most promotional e-mail messages from Pepper. For SMS/text communications, you may reply with STOP at any time as described above under “Your Personal Information Use Choices”.

Our Communications to You

If you have provided us with your prior express consent to receive communications via an automatic telephone dialing system (auto-dialer), artificial or prerecorded voice messages, or text messages, Pepper may use your information to send text messages to any mobile device connected to your cell phone number, until you opt out from future text messages by texting STOP. Once you cancel, we will send one additional confirmation message stating that you've opted out.

We may send you promotional emails from time to time (with your prior express consent where required) about our new products and other news about Pepper. We may also remind you about items which you have left in your cart but not claimed (with your permission where required) and when you have requested to be notified about items that are back in stock. You may opt out of receiving these emails at any time using the link provided in the email message.

We may also send you emails asking you to review our products and your experience with us (with your permission where required). We currently use Judge.me to help administer our customer feedback program. You can learn more about Judge.me, here https://judge.me/privacy. If you provide a review of Pepper’s products through Judge.me, you consent to Pepper re-posting your review on its Website and/or social media platforms.

Where you have opted-out of receiving our promotional emails, you may still receive service communications related to your purchase or account or services you have directly requested from us.

Data Processors

We rely on the following third party services to help our Website run smoothly:

• Shopify (Canada) – to provide our shopping cart software and payment processing
• Klaviyo (USA) – to send emails to customers
• Amazon Web Services (USA) - to host our infrastructure
• PayPal (USA) – to safely and securely process payments
• GSuite (USA) – for cloud computing, productivity, and collaboration
• Typeform (Spain) – for sending and analyzing customer surveys
• Zendesk (USA) – for customer support purposes
• Wunderkind (USA) – to provide a performance marketing platform and to send SMS to customers
• Loop (USA) – to manage our order returns
• Whiplash (USA) – to manage our order fulfillment 
• Conversocial (USA) – to provide a social customer service platform
• Judge.me (UK) – to process our customer reviews
• Refersion (USA) – to provide our affiliate program
• ShareASale (USA) – to provide our affiliate program
• Facebook (USA) - to provide digital advertising
• Northbeam (USA) - a marketing attribution on ad spend performance
• Triplewhale (USA) - an analytics platform to track marketing campaigns
• Osano (USA) - our cookies management tool
• Loyalty Lion (UK) - our rewards and loyalty program management tool

Security

While no service is completely secure, we use physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse, and unauthorized access, use, alteration, or disclosure. Our Website is hosted by Shopify and you may view Shopify’s current security protocol at https://www.shopify.com/security.  Transactions are completed through our Website by Shopify and you may view Shopify’s PCI compliance at https://www.shopify.com/security/pci-compliant.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of the Website such as product reviews, which any Website visitor can view.

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 our Website. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

Correction of Data

It is your responsibility to provide us with accurate personal information about yourself and to inform us of any changes (e.g., new home address, name change, new email address). If, however, you discover any information previously provided to us is inaccurate or incomplete, you may request that the data be corrected or amended by sending us an email at privacy@wearpepper.com. 

Retention of Data

We will retain your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Notice. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services (including in connection with our guarantees) and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes). 

Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. You should review this Privacy Notice periodically so that you keep up to date on our most current policies and practices. We will post a prominent notice on our Website to notify you of any significant changes to our privacy practices and indicate at the top of the Privacy Notice when it was most recently updated.

Contact Information

Please address questions, comments, and requests regarding this Privacy Notice and our privacy practices to our email address at privacy@wearpepper.com or by mail to Pepper Body Inc., 1624 Market Street Suite 226, PMB 34732, Denver, Colorado 80202-1559, USA.