Who we are?
Our website address is: http://pmkclub.com.
1. Scope of this Policy
2. Agreement to Terms
3. Effective Date and Changes to this Policy
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
4. The Information We Collect
We collect the following categories of personal information directly from you, as you visit our website, reach out to us, create an account with us, or place an order with us:
- Personal details: Such as your name, email address, telephone number, shipping address, company name (if applicable).
- Account information: Such as your order history, wishlist, birthday, preferences, beauty profile (including hair, eye, and skin color, skin type etc.), and any other information you provide to us when you complete the registration form, in addition to personal details.
- Log information: Such as your IP address, geolocation, webpages accessed, information requested along with the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), browser version, operating system.
- Marketing information: Such as your marketing preferences, the level of engagement our emails receive, such as the delivery rates, open rates and click through rates which our emails achieve.
- Billing information: Such as credit, debit, or other payment card information, billing name, billing address.
- Communications you send us: Such as survey responses, correspondence, any other information you provide to us.
- Visual information: Such as photographs and videos from social media platforms and/or submitted directly.
We collect what is commonly referred to as “sensitive personal information” if you choose to provide your skin tone preferences. Providing this information is completely optional, is collected only with your explicit and freely given consent, and is securely stored on our web servers for use in personalizing our correspondence with you via email or on site. Any information stored can be viewed on your account page. This information can be deleted using the same mechanism that it is provided to us in your account page or by emailing us at [email protected] Please do not submit other sensitive personal information about you to us.
We may also receive certain categories of personal information from third parties, such as partner companies involved in any joint promotions. Information we obtain from third parties will generally be your name and contact details.
What are the consequences of not providing personal information?
A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for targeted advertising (as discussed in more detail below). Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.
Similar to cookies, we may automatically collect certain information about the device you use to access the Site. For example, we may collect and analyze information such as IP addresses, geolocation information, unique device identifiers, browser types, browser language, operating system, the state or country from which you accessed the Site, and other information about your mobile phone or other device(s). In addition to analytical purposes, this information helps us diagnose problems with our server, administer the Site, and display the content according to your preferences.
Do Not Track
pmkclub respects your privacy, but we do not alter the information we collect or change the Site upon receiving “do-not-track” signals, as the term appears in Cal. Bus. & Prof. Code §§ 22575(b)(5). For more information about DNT signals, visit http://allaboutdnt.com.
6. Children’s Privacy
The Site is not intended for users under the age of 16. We do not knowingly or intentionally gather personal information about visitors who are under the age of 16. If you are aware of, or suspect that, someone under the age of 16 is using the Site without permission, please notify us immediately by contacting us as detailed below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.
7. How We Use Your Personal Information
We use the above categories of personal information for the following purposes:
|Purpose of Use||Legal basis for processing||Categories of personal information|
|Perform transactions||– Necessary for legitimate interests – Necessary for compliance with a legal obligation – Necessary to perform a contract or to take steps at your request to enter into a contract – Consent (where you have provided consent as appropriate under applicable law)||Personal details, Account information, Log information, Marketing information, Billing information|
|Respond to inquiries and messages we receive and keep records of correspondence||– Necessary for legitimate interests – Necessary to perform a contract or to take steps at your request to enter into a contract||Personal details, Account information, Log information, Billing information, Communications you send us|
|Manage your accounts and generally facilitate the running and operation of our business.||– Necessary for legitimate interests – Necessary for compliance with a legal obligation||Personal details, Account information, Log information, Marketing information, Billing information, Communications you send us, Visual information|
|Make our website more intuitive and easier to use and conduct research regarding opinion of customer services||– Necessary for legitimate interests – Consent (where you have provided consent as appropriate under applicable law)||Personal details, Account information, Log information, Marketing information, Communications you send us, Visual information|
|Protect the security and effective functioning of our website and information technology systems. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.||– Necessary for legitimate interests – Necessary for compliance with a legal obligation||Personal details, Account information, Billing information, Log information|
|Provide relevant marketing||– Necessary for legitimate interests – Consent (where you have provided consent as appropriate under applicable law)||Personal details, Account information, Log information, Marketing information, Visual information|
|Address our compliance and legal obligations and exercise our legal rights||– Necessary for compliance with a legal obligation||Personal details, Account information, Log information, Marketing information, Billing information, Communications you send us|
8. How We Share Your Personal Information
We may share personal information, for the purposes outlined above, with the following categories of recipients:
- Group companies, including Seed Beauty, LLC and our affiliates.
- Service providers: We share personal information with service providers, acting as data processors, to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above (e.g., information technology services, information storage, payment processing, fraud detection, marketing management and communications, customer service functions, statistical analysis). We require such parties by contract to provide reasonable security for personal information and to use and process such personal information only on our behalf, and in compliance with applicable law. A limited number of service providers will act as data controllers (e.g., fraud detection, statistical analysis) and will be contractually obligated to comply with applicable data protection laws, rules, and regulations.
- Auditors, advisors, and financial institutions: We share personal information with auditors for the performance of audit functions, and with advisors for the provision of legal and other advice, and with financial institutions in connection with payment and other transactions.
- Site visitors, such as when your profile name is chosen for display as part of the social media news feed on the Site;
- Business reorganization: We may share personal information with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which personal information would be transferred as an asset of Company.
- Mandatory disclosures and legal rights: We may share personal information in order to comply with any subpoena, court order or other legal process, or other governmental request. We also share personal information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims or prevent fraud.
If you have questions about the parties with which we share personal information, please contact us as specified below.
9. Your Privacy Choices
At checkout and upon first arriving to the site you will have the option to receive marketing communications from us, by ticking a box indicating that you would like to receive such communications during checkout or at any time while browsing the site by entering your email address into our newsletter sign-up form. You may sign-up for our e-newsletter on our website or opt-in to receive news, offers, or updates on out-of-stock items.
You have control regarding our use of your personal information for direct marketing. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication (e.g., ticking a box to opt-out, clicking “unsubscribe” in email from us, or replying STOP to a text message) or contact us as detailed below.
10. How We Store and Safeguard Your Information
We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. However, no security measure can guarantee against compromise. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third party access, or other causes beyond our control.
You also have an important role in protecting your personal information. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.
11. Additional Disclosures for California Residents
To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section The Information We Collect above.
We collect this personal information, as further described in the How We Use Your Personal Information section above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.
We may share such personal information with the third parties listed in the above section How we share your personal information. California law also requires that we provide you with information about certain disclosures to such third parties, where the disclosure involves monetary or other consideration. California treats these disclosures are “sales” of information, even where no money is exchanged. Some of the disclosures we make constitute “sales” under California law and involve the disclosure of the following types of personal information:
- Identifiers, such as contact information, IP address, and other online identifiers;
- Personal information, as defined in the California customer records law, such as contact information;
- Internet or network activity information, such as browsing history and interactions with our website; and
- Geolocation data, such as IP location.
We do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.
We also disclose the following personal information to third parties for our operational “business purposes” as defined by California law:
|Identifiers, such as name, contact information, IP address and other online identifiers;||Service providers; Business reorganization; Group companies; Mandatory disclosures and legal rights|
|Personal information, as defined in the California customer records law, such as name and contact information, and payment card number;||Service providers; Auditors, advisors, and financial institutions; Business reorganization; Group companies; Mandatory disclosures and legal rights|
|Characteristics of protected classifications under California or federal law, such as skin tone or color;||Service providers; Business reorganization; Group companies|
|Commercial information, such as transaction information and purchase history;||Service providers; Auditors, advisors, and financial institutions; Group companies; Business reorganization, Mandatory disclosures and legal rights|
|Internet or network activity information, such as browsing history and interactions with our website;||Service providers; Business reorganization; Group companies; Mandatory disclosures and legal rights|
|Geolocation data, such as IP location;||Service providers; Business reorganization; Group companies; Mandatory disclosures and legal rights|
|Electronic and similar information; and||Service providers; Business reorganization; Group companies; Mandatory disclosures and legal rights|
|Inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences and characteristics.||Service providers; Business reorganization; Group companies; Mandatory disclosures and legal rights|
You have a right to notice, upon collection, of the categories of personal information collected and for which purposes the data will be used. You have the right to access a copy of the categories and specific pieces of personal information that the company collects, uses, and shares about you, and the right to ask the company to delete/anonymize your personal information, with limited exceptions. You also have the right to opt-out of the “sale” of your personal information. Finally, you have the right to be free from discrimination for exercising your rights.
If you wish to exercise any of these other rights or have any questions or concerns regarding the processing of your personal information, please contact us at https://pmkclub.com/pages/privacy-requests or email us at [email protected]. We will respond to your request consistent with applicable law.
Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. Where we possess appropriate information about you on file (e.g., name, phone number, email, or physical address), we will attempt to verify your identity using that information. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
To use an authorized agent to make a request on your behalf, you will need to directly confirm with us that you provided the authorized agent permission to submit the request, provide the company with signed permission for the authorized agent to act on your behalf, and you will need to verify your identity, directly with the company.
This CCPA Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the personal information we collect about those individuals relates to their current, former, or potential role with us.
12. For Our European Users (including the United Kingdom)
International data transfer.
We take steps to ensure that we handle your personal information subject to appropriate safeguards. As a US company, most of our operations are conducted in the United States and in order to provide the Site, personal information may be processed in the United States and Canada, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. Where required by such laws, you may request a copy of the suitable safeguards we have in place by contacting us as detailed below.
Retention of your personal information.
Lawful bases for handling your data.
Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out in the section above, How We Use Your Personal Information, including: (i) as may be necessary to perform a contract (such as when you choose to purchase pmkclub products); (ii) as necessary to comply with a legal obligation (such as when we use personal information for recordkeeping to substantiate tax liability); (iii) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (iv) as necessary for our legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Site).
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.
To the extent required under applicable law, you have the right of:
- Access. You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
- Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
- Deletion.You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to request that we restrict our processing of your personal information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
- Portability. You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
- Objection.Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation (e.g., direct marketing). We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
- Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at [email protected] with the subject line “Privacy” so that we can get your email to the right team, or log-in to your account. We will respond to your request consistent with applicable law.
If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.
More on the right to object
You may exercise your right to object to us using or processing your information for direct marketing purposes by: clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://pmkclub.com/pages/cookie-policy, or manage your settings below.
Your consent applies to the following domains: pmkclub.com
Your current state: Allow all cookies (Necessary, Preferences, Statistics, Marketing).
Your consent ID: OMHLiq71papjJp53JwIUCsZGIl4foo+OE56w6m3NxKcGBd1xiT9JFg==
change your consent | withdraw your consent
Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. Please contact us, as detailed below, for more information about your rights or to make a request to exercise your rights, as applicable. We will respond to your request consistent with applicable law.
European GDPR Representative:
To comply with Article 27 of the GDPR, we have appointed a representative which can accept communications on behalf of Seed Beauty, in relation to personal data processing activities falling within the scope of the GDPR. If you wish to contact them, their details are as follows:
Bird & Bird GDPR Representative Services SRL
Avenue Louise 235
13. For Our Canadian Users
We retain Personal Information for as long as you have an account with us in order to meet our contractual obligations to you and for seven years after that and/or purchase of services to identify any issues and resolve any potential legal proceedings.
Please contact us at [email protected]:
- If you wish to access, update, and/or correct inaccuracies in your Personal Information or change your consent preferences (note: we may need to collect additional Personal Information for the purposes of verifying your identity before responding to your request);
- For information about how our foreign-based service providers process your Personal Information; or
If you have any questions or complaints about the manner in which we treat your Personal Information.
14. Third Party Links and Third Party Advertising
Third Party Links
Third Party Advertising
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our website and other websites or online services. You may receive advertisements based on information relating to your access to and use of our website and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.