Privacy Policy

Thank-you for visiting our site, which is part of the Klay & Co. Inc. family of brands and brand sites (“Klay & Co Inc.”, “us”, “our”, or “we”). We value our customers and are committed to being transparent and honest. This policy provides information on how we collect, use, share and protect information collected from our sites and social media pages (collectively call the “Sites”), when you interact with us. By providing us with your personal information, you agree to the terms of this policy.

It is important to note that our site may contain links to other third-party websites that are not controlled or operated by Klay & Co Inc. This Privacy Policy does not apply to such third-party websites, and Klay & Co. Inc. is not responsible for the content of such third-party websites or the privacy practices of such third parties. We encourage you to review the respective privacy policies of any third parties before disclosing your personal information.

Collection of Personal Information

What is personal information:

“Personal Information” refers to any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. through pseudonymized data such as a unique ID number). Personal data includes things like email/home addresses/mobile phone, usernames, profile pictures, beauty profiles, personal preferences and shopping habits, user generated content, financial information, and welfare information. It could also include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies.

Personal Information does not include anonymous or aggregated information that cannot be tracked back to you personally.

What information is collected?

We may collect information that you provide to us directly, information automatically collected and information from third parties. We may combine information that we collect via one method (e.g., a website, our digital advertising) with information that we have collected via another method (e.g., an offline event). We do this to get a more complete view of our consumers, which, in turn, allows us to serve you better and allow for more customization.

If you submit any personal information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.

Information you provide to us and is collected:

  • Registration on a Site
  • Making a purchase
  • Subscribing to email newsletter, offers, communications or join a subscription program
  • Enter a contest or promotion
  • Submit a beauty profile, a consumer survey, photo, video or product review
  • Communication via a third-party platform, such as tagging us in a social media post

Collection of Non-Personal Information

Information From Site Usage :

Our Sites and its third-party service providers may also technologies that passively or automatically collect information about how the Sites are accessed and used including but not limited to your browser type, device type, operating system, application version, the pages served to you, the time you browse, preceding page views, and your use of features or applications on the Sites.

Device Identifiers:

Our Sites automatically collects an IP address or other unique identifier information ("Device Identifier") for the computer, mobile device, technology or other device (collectively, "Device") you use to access the Sites or on third party websites that publish our advertising. We may use a Device Identifier to, among other things, administer the Sites, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your shopping cart, deliver advertising and gather broad demographic information.

Cookies:

Like many websites, we utilize “Cookies” to maintain a record of your visit to the Sites. Cookies are data tiles that are sent through your web browser to your computer when it is used to visit the Sites to facilitate site navigation and to personalize your experience. Cookies may also be used to collect your MAC address for analytics purposes or associate you with social networking sites like Facebook and Twitter and, if you so choose, enable interaction between your activities on the Sites and your activities on such social networking sites. Note that cookies may be used and linked to other personal data you have shared with us (such as previous purchases or newsletter subscriptions). Most web browsers automatically accept cookies.

If you would prefer to not accept cookies, you may follow your Internet browser’s steps for doing so. Please be aware that some features and services on our Sites may not work properly because we may not be able to recognize and associate you with your account.

Pixels or Web Beacons: 

We use pixel tags or web beacons, which are transparent graphic images placed on a web page or in an email to indicate that a page or email has been viewed or to let your browser retrieve content from another server. These are use to measure our marketing campaigns.

Derived Information:

We may derive information or draw inferences based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

Collected Third Party Information:

We may receive information from third party partners, which includes marketing and demographic data, offline records and information from an advertiser about your experiences or interactions with them. We may also receive information from other companies that collect or aggregate information from publicly available databases or if you consented to allow them to use and share your information. We also collect information about users who share common interests or attributes to create user “segments,” which help us to better understand and market to our customers. We may use your data as part of health-related segments about non-sensitive conditions such as dry skin.

We may combine such third party data with other information we receive from or about you.

Our websites and Apps may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we are not responsible or liable for these policies. Please check these policies before you submit any personal data to these websites.

Protection of Information

We take reasonable steps to ensure that personal information in our control is protected by security safeguards appropriate to the sensitivity of the information.

Use of Personal Information

Unless otherwise permitted or required by law, we will make reasonable efforts to only collect personal information that is necessary in the following contexts and for the associated purposes:

  • Develop, enhance, market, sell or otherwise provide our products and services.
  • Analyze trends and statistics, develop features and offerings, assess patterns of use, and plan and evaluate marketing initiatives.
  • Personalize the advertisements you see on third-party platforms and websites.
  • Conduct and administer contests or other promotions in which you have participated.
  • Contact you and to respond to any communications that you may have had with us.
  • Troubleshoot problems with the Sites.
  • Customize and personalize your experience.
  • Develop and manage our business and operations.
  • Enforce our Terms of Use.
  • Detect and protect us and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with our policies and contractual obligations.
  • To comply with, any financial, legal or regulatory requirements or provisions.
  • Carry out any other purpose described to you at the time the information was collected.

Personal information collected by may be transferred to, stored and processed in the United States and Canada.

Transfer of Personal Information

Personal information collected by or on behalf of our Sites may be transferred to, stored, and processed in the United States and Canada. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

Sharing Of Information

When information is collected by one of our Sites, we may share that information with our affiliates and other Klay & Co Inc. brands.

We share personal information in the following circumstances or as otherwise described in this Privacy Policy:

  • We may disclose your personal information to our current and future subsidiaries or affiliates
  • We share information with vendors, service providers and consultant that need access to. personal information to provide services on our behalf, including, but not limited to, support services, website services, delivering promotional materials, contests, sweepstakes and other promotions, and answering customer questions about products and services.
  • If you submit a product review or post content in another public area, this information may be visible to other visitors to the Sites.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of our users, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • We share personal information with your consent or at your direction.

Your Choices Regarding Promotional Communications

You may opt out of receiving promotional email communications from our Sites, by means of a link provided in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Canadian Residents

If you are a Canadian resident, this section applies to you.

CONSENT: By submitting personal information to us or our service providers and agents, you consent to the collection use, disclosure and transfer of your personal information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent at any time to the collection, use, disclosure or transfer of your personal information time by contacting us at the address provided below. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide you, or continue to provide you, with certain products, services or information which may be of value to you.

ACCESS AND CORRECTION: We will take reasonable steps to ensure the personal information we hold is accurate, complete and up-to-date. Upon your written request, and subject to certain exceptions provided by law, we will inform you of the existence, use and disclosure of your personal information and give you access to that information. We may charge a minimal fee for providing such access to you. If you believe that the personal information that we hold about you is not accurate or complete, you may write to us at the address provided below. If you are able to establish that the information is not accurate or complete, we will take reasonable steps to delete and/or correct the information so that it is accurate, complete and up-to-date. In order to facilitate a request to correct or update information, we may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by us. 

Additional Disclosures For California Consumers

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

In the preceding 12 months, we have collected the following categories of personal information:

  • Identifiers, such as your name, email address, shipping address, phone numbers, username, and IP address.
  • Characteristics of protected classifications under state or federal law, such as gender, or, if you apply for a job with us, your residency status.
  • Commercial information, such as information about products and services you have purchased, personal shopping appointments, and participation in our subscription program.
  • Internet or other electronic network activity information, such as browsing and other activity on our website, and interactions with our advertisements and marketing emails.
  • Audio or visual information, such as recordings of customer service phone calls, or photos you may share with us.
  • Professional or employment information, such as your resume, if you apply for a job with us.
  • Education information, such as the college you attended if you attended, if you apply for a job with us.
  • Inferences, such as information about your location or product preferences.
  • Other personal information described in Section 1798.80(e) of the California Civil Code, such as a credit card number.

For details about the precise data points we collect and the categories of sources of such collection, please see the information above. We collect personal information for the business and commercial purposes described in the sections above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

 

Category of Personal Information

Categories of Recipients

Identifiers

Advertising networks, marketing partners, data analytics providers, payment processors, shipping and delivery partners, customer support partners, Internet service providers, operating systems and platforms, fraud prevention partners, cloud service providers, event partners, and other users (if you choose to share certain information, such as product reviews, publicly on our website)

Characteristics of protected classifications under state or federal law

Survey partners, cloud service providers

Commercial information

Advertising networks, marketing partners, data analytics providers, payment processors, shipping and delivery partners, customer support partners, Internet service providers, operating systems and platforms, fraud prevention partners, cloud service providers, and other users (if you choose to share certain information, such as product reviews, publicly on our website)

Internet or other electronic network activity information

Advertising networks, marketing partners, data analytics providers, payment processors, shipping and delivery partners, Internet service providers, operating systems and platforms, fraud prevention partners, and cloud service providers

Audio or visual information

Marketing partners, customer service partners, operating systems and platforms, cloud service providers

Professional or employment information

Cloud service providers

Education information

Cloud service providers

Inferences

Marketing partners and data analytics providers

Other personal information described in Section 1798.80(e) of the California Civil Code

Payment processors
  

California law requires that we provide transparency about personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. We “sell” personal information for the commercial purposes of marketing and advertising our products to you. In the preceding 12 months, we have “sold” the following categories of personal information to the following categories of third parties:

Category of Personal Information

Category of Third Parties

Identifiers

Advertising networks, marketing partners

Internet or other electronic network activity information

Advertising networks, marketing partners

You have the right to opt out of these sales at any time by contacting us below. We do not knowingly sell personal information about consumers under the age of 16.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, disclose, and sell, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by contacting info@backtoearthskin.com. We will verify your request by asking you to provide information related to your recent interactions with us, such as information about a recent purchase. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent registered with the California Secretary of State, we may ask you to verify your identity with us directly or confirm with us that the agent otherwise has your permission to submit the request on your behalf. If you are an authorized agent seeking to make a request, please email us at info@backtoearthskin.com.

We offer various financial incentives. For example, we provide discounts, special offers and subscription services and we may offer you a discount if you sign up for our email newsletters or participate in our Refer a Friend program. When you participate in the financial incentives we offer, we collect personal information from you, such as identifiers like your name and email address and commercial information like your purchasing habits. You can opt into a financial incentive by following the instructions provided at sign-up, and you may opt-out of the incentive at any time by contacting info@backtoearthskin.com. In some cases, additional terms and conditions may govern a financial incentive program, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the discount or benefit presented to you.

Contact Us

Questions or comments about this Privacy Policy should be sent to info@backtoearthskin.com.