Effective Date: October 27, 2020
Last Updated: October 27, 2020
- Information We Collect
- Information Collected Related to California Residents
- Cookies and Similar Technologies
- How We Use Information We Collect
- Our Legal Basis for Collecting Personal Information
- Your Failure to Provide Personal Information
- Our Retention of Your Personal Information
- Sharing Personal Information
- Sale of Personal Information
- Transfer of Data
- Your Rights and Choices
- Rights Specific to Californians
- Rights Specific to European Union Residents
- Third Party Links
- How We Protect Personal Information
- Children’s Privacy
- Direct Marketing and “Do Not Track” Signals
- Customer Information
- How to Contact Us
Information We Collect
We collect information, including personal information, to provide better services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, information about your device, and certain metadata.
“Sensitive Personal Information” refers to a smaller subset of Personal Information which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.
The Personal Information which we collect includes, but is not limited to, the following circumstances and data elements:
- If you express an interest in obtaining additional information about our services, request customer support, use our “Contact Us” or similar features, register to use our Sites or Services, or download certain content, we may require that you provide to us your contact information, such as your name, address, phone number, or email address;
- If you interact with us on social media accounts, we may ask you to provide, a name, age, gender, email address, and zip code;
- If you use and interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information;
- If you use and interact with our services, we automatically collect information about your device and your usage of our services, through log files and other technologies, some of which may qualify as Personal Information;
- If you register the product you bought, we will collect product registration information.
- If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; and
- Mobile Application
Certain information is required when creating an account to use our Services on the mobile application, such as your name, email address and password.
In addition, in order to improve your experience with the Services, you may choose to provide additional information such as your home address, mobility device information, and personal medical information may be requested to assess eligibility based on the type of service requested. You can choose not to provide certain information, but then you may not be able to register for the ECOLANE Services or take advantage of some features of the Services.
In connection with the use of the Services, your mobile device may collect certain data points like activity and sleep habits. When your device syncs with ECOLANE’s application, certain data recorded on your device is transferred from your device to our servers.
- Health and Other Sensitive Personal Information
To the extent that information we collect is [health data] [or another Sensitive Personal Information subject to the European Union’s General Data Protection Regulation], we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data. [You can use your account tools to withdraw your consent at any time].
Information Collected Related to California Residents
During the last twelve (12) months, we have collected the following categories of Personal Information from consumers. Some of the categories of information collected specifically concerns our employees or contractors as opposed to consumers who purchase our products.
Type of Identifiers We Collect
First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, physical characteristics or description, address, telephone number.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), sex (including gender, gender id, gender expression, pregnancy or childbirth and related medical conditions).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, product warranty information.
E. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
F. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our customers or from our employees. For example, from documents that our customers provide to us related to the products which they purchase.
- Indirectly from our customer. For example, through information we collect from our customers in the course of providing products to them through our Retail Partners.
- Directly and indirectly from activity on our website. For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
- From social media platforms and networks that you use in connection with our Sites, such as Facebook, LinkedIn, Twitter, Pinterest and Instagram.
- From third parties that interact with us in connection with the services we perform and the products which we produce.
Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our thirdparty advertising and analytics partners include Google, Hubspot, Zapier, Seventh Sense and similar partners.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
- Location Data. If you grant us access to your location, ECOLANE may collect information about your location when you use our Sites and Services. Your location can be determined by: GPS, IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). If you enable location services for our mobile application, we may collect location data periodically as you use or leave open our mobile application. We may associate such location data with Personal Data you provide to us. Depending on the platform you use to access our mobile application (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the mobile application.
How We Use Information We Collect
We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To present, operate or improve the Site and Services, including analysis of Site activity;
- To inform you about Services and products available from ECOLANE;
- To authorize access to our Sites and Services;
- To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
- To offer and administer programs;
- To customize or tailor your experience of the Services;
- To administer content, or other Site features;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, and other offers or promotions, and to deliver pertinent emails;
- To improve our Site and Services;
- To secure our Services, including to authenticate Users;
- To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
- To respond to and support Users regarding their use of the Sites and Services;
- To comply with all applicable legal requirements;
- To perform data analysis and testing;
- To resolve disputes;
- To process warranty claims;
- To improve products and services;
- To provide replacement parts, assembly instructions and refunds,
- To otherwise fulfill the purpose for which the information was provided.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.
We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. We may use your Personal Information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Legal Basis for Collecting Personal Information
Whenever we collect Personal Information from you, we may do so on the following legal bases:
- For compliance with a legal obligation to which ECOLANE is subject;
- Your consent to such collection and use;
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
- Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
- Registering a User as a new user;
- Managing our relationship with Users;
- Intra-organization transfers for administrative purposes;
- Product development and enhancement, where the processing enables ECOLANE to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Improving our website, products/services, marketing, customer relationships and experiences
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
Your Failure to Provide Personal Information
Your provision of Personal Information is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Information, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.
Our Retention of Your Personal Information
We use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
Sharing Personal Information
ECOLANE may disclose your Personal Information to commercial providers for a business purpose. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
- California Customer Records Personal Information categories;
- Protected classification characteristics under California or federal law;
- Commercial information;
- Internet or other network activity information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Commercial providers.
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the services and products we provide to you.
We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of ECOLANE if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of ECOLANE, our Users or the public as required or permitted by law.
We attempt to notify consumers about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
We may disclose your Personal Information in the event of a business transfer. If we establish a new related Ecolane, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Information about our users is often a transferred business asset. In the event that Ecolane itself or substantially all of our assets are acquired, Personal Information about our users may be one of the transferred assets.
Sale of Personal Information
[In the preceding twelve (12) months, we have not sold any Personal Information.]
Transfer of Data
We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Information.
If we transfer your Personal Information out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Information is protected.
Your Rights and Choices
You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our services, we aim to provide you with choices about how we use your personal data. We also aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your id for Ecolane before granting you access to the information. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
- Rights Specific to California Residents
Under the California Consumer Privacy Act, California residents have specific rights regarding their Personal Information. This section explains how California residents can exercise those rights and describes Californians’ rights.
- Exercising Your Rights
If you are a California resident who chooses to exercise your rights, you can:
- Submit a request via email at firstname.lastname@example.org
- Call 1-844-ECO-LANE (844-326-5263)
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
- Our Response to Your Request
Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your id before granting you access to the information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
- Californians’ Rights With Respect to Personal Information
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
- Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
- Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
- Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 );
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Rights Specific to European Union Residents
The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, United Kingdom and Swiss residents with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
- The right of access. You have the right to request a copy of your Personal Data which we hold about you.
- The right of correction: You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
- The right to be forgotten: You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
- The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
- The right to data portability: You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers / IT environment to another service provider’s servers / IT environment.
- The right to refuse to be subjected to automated decision making, including profiling:You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
- Our Opt-in/Opt-out Policy
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a ECOLANE Partner to unsubscribe from the service.
- Your Ad Choices
We or third party partners may place or recognize a unique cookie on a User’s browser when the User visits our Sites for the purpose of serving targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). Users may find more information about entities involved in online advertising and additional choices they may make, including opt-out of having their information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. ECOLANE is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.
The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not ECOLANE. ECOLANE does not control or operate these tools or the choices that advertisers and others provide through these tools.
Third Party Links
The Sites may contain links to webpages operated by parties other than ECOLANE. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. ECOLANE strongly recommends that each User review the third party's terms and policies.
How We Protect Personal Information
ECOLANE maintains administrative, technical and physical safeguards designed to protect the user's Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.
[ECOLANE collects account information for payment or credit, and ECOLANE will use the information only to complete the task for which the account information was offered.]
Direct Marketing and “Do Not Track” Signals
ECOLANE does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request to email@example.com. California users may request further information about our compliance with this law by contacting us at firstname.lastname@example.org or by writing to us at the address listed in the “How to Contact Us” section.
ECOLANE Customer Information
- ECOLANE Customer Information. We collect information about individuals within our ECOLANE Customer organization (“Customer Information”). Customer Information may include information related to the Customer’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Customer Information to support the Customer account, maintain our business relationship with the Customer, respond to Customer inquiries, or perform accounting functions. ECOLANE Customers may update personal information and password by logging into the ECOLANE Platform and updating their account. ECOLANE Customers may contact ECOLANE support in order to delete their Personal Information. In some cases, we may not be able to delete Customer Information, and in such cases we will tell you why.
- Information about our Customers’ Contacts. We collect information about any contacts, such as employees, customers, and others, that may be uploaded into the ECOLANE Platform (“Information about our Customers’ Contacts”). Information about our Customer’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Customer’s Contacts for the purposes of providing Services to such contacts. ECOLANE Customers may update or delete Information about their contacts in the ECOLANE Platform. ECOLANE Customers may also contact ECOLANE support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.
- Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our ECOLANE Customers. This information may include emails, texts, websites, social media messages or posts, and other forms of data or electronic communications (“Archival Information”). Archival Information includes data about our ECOLANE Customers and the third parties they correspond with. We do not control or monitor the information our ECOLANE Customers collect and store through our Services, or their privacy practices or policies. It is our Customer’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Customer’s communications and use of our services. Our Customer’s privacy policies or practices apply to Archival Information, the purposes for which the Customer collects Archival Information, how the Customer may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Customer in order to correct, amend, or delete their information, or to opt out of any collection, uses or disclosure of their information by our Customer.
- Automatically Collected Information. We collect information automatically about how our ECOLANE Customers use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs or other tracking technologies. We collect this information in order to monitor, support and improve our services or to provide ECOLANE Customers with certain customized features. We may use Automatically Collected Information to tell us how our ECOLANE Customers use our services, to improve our services or develop new products, services or features. We may combine this information with other information we collect.
We treat Customer Information, Information about our Customer’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our ECOLANE Customers, subject to the terms of the ECOLANE Terms of Services and any other service agreement between ECOLANE and the Customer. We do not share Customer Information, Information about our Customer’s Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Customer, as may be necessary to provide services to the Customer, to our advisors, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Customer, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Customer Information, Information about our Customer’s Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, ECOLANE Customers, partners or service providers.
We will retain Customer Information we process on behalf of our ECOLANE Customers for as long as needed to provide services to our Customers, or for the period of time requested by a particular Customer.
How to Contact Us
Send e-mail to: email@example.com
Send mail to our address:
North America Headquarters
940 W. Valley Rd.
Wayne, PA 19087
Tel. (844) ECO-LANE
Support: (610) 312-0033 ext. 1
Fax. (888) 712-2499
Tel. +358 9 61 500 901
Fax. +358 9 72 554 272
940 W. Valley Rd.
Wayne, PA 19087