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Privacy Policy

Last Updated May 2018

I at SoulintheRaw.com (“Marina or Marina Yanay-Triner or Soul in the Raw,” “I”, “me”) have created this privacy policy (this “Privacy Policy”) becamee I know that you care about how information you provide to me is meed and shared. This Privacy Policy applies to my information collection and mee practices: (i) online when you visit any of my websites, including, without limitation, SoulintheRaw.com (the “Websites”); and (ii) offline when you provide information to me.

This privacy notice provides you with details of how I collect and process ymy personal data through ymy mee of my site SoulintheRaw.com.

By providing me with ymy data, you warrant to me that you are over 13 years of age.

SoulintheRaw.com is the data controller and I am responsible for ymy personal data (referred to as “I”, or “me” in this privacy notice).

It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time ymy personal information changes by emailing me at rawsoulnutrition@gmail.com.

Acceptance of Terms

By visiting any of my Websites, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service, both of which govern ymy mee of the Websites. By providing me information offline, you are also agreeing to the terms of this Privacy Policy.

The Information I Collect

In the cmyse of operating the Websites and/or interacting with you, I will collect (and/or receive) the following types of information.

  1. PERSONAL INFORMATION.

When you sign up to receive any of my newsletters, respond to a survey, register for a class, or purchase any product or service, you may be required to provide me with personal information about ymyself, such as ymy name, address, email address, and phone number. I do not collect any personal information from Visitors when they mee the Websites unless they provide such information voluntarily, such as by registering or sending me an email or signing up for a newsletter. All information I collect and/or receive under this section is collectively called “Personal Information.”

1B: WHAT DATA DO I COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND I PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymized data.

I may process the following categories of personal data about you:

Communication Data that includes any communication that you send to me whether that be through the contact form on my website, through email, text, social media messaging, social media posting or any other communication that you send me. I process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. My lawful ground for this processing is my legitimate interests which in this case are to reply to communications sent to me, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. I process this data to supply the goods and/or services you have purchased and to keep records of such transactions. My lawful ground for this processing is the performance of a contract between you and me and/or taking steps at your

request to enter into such a contract.

User Data that includes data about how you use my website and any online services together with any data that you post for publication on my website or through other online services. I process this data to operate my website and ensure relevant content is provided to you, to ensure the security of my website, to maintain back- ups of my website and/or databases and to enable publication and administration of my website, other online services and business. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer my website and my business.

Technical Data that includes data about your use of my website and online services such as your IP address, your login data, details about your browser, length of visit to pages on my website, page views and navigation paths, details about the number of times you use my website, time zone settings and other technology on the devices you use to access my website. The source of this data is from my analytics tracking system. I process this data to analyze your use of my website and other online services, to administer and protect my business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of my advertising. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer my website and my business and to grow my business and to decide my marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from me and my third parties and your communication preferences. I process this data to enable you to partake in my promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. My lawful ground for this processing is my legitimate interests which in this case are to study how customers use my products/services, to develop them, to grow my business and to decide my marketing strategy.

I may use Customer Data, Meer Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising I serve you. My lawful ground for this processing is legitimate interests which is to grow my business. I may also use such data to send other marketing communications to you. My lawful ground for this processing is either consent or legitimate interests (namely to grow my business).

Sensitive Data

I do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. I do not collect any information about criminal convictions and offences.

I require your explicit consent for processing sensitive data, so when you submit your details, I will send you a further communication asking for you to confirm your consent to this processing.

Where I am required to collect personal data by law, or under the terms of the contract between me and you do not provide me with that data when requested, I may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide me with the requested data, O may have to cancel a product or service you have ordered but if I do, I will notify you at the time.

I will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email me at rawsoulnutrition@gmail.com. In case I need to use your details for an unrelated new purpose I will let you know and explain the legal grounds for processing.

I may process your personal data without your knowledge or consent where this is required or permitted by law.

I do not carry out automated decision making or any type of automated profiling.

  1. ORDER INFORMATION.

When you place an Order, you must provide me with certain information about the products and services you are seeking to purchase. Such information is collectively called the “Order Information.”

  1. BILLING INFORMATION.

When you wish to purchase a product or service, you will be required to provide certain information in addition to the Personal Information and Order Information noted above. Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. Such information is collectively called the “Billing Information.” Although I will have access to the Billing Information, it will also be collected and processed by my third-party payment vendors pursuant to the terms and conditions of their privacy policies and terms of use.

  1. OTHER INFORMATION

In addition to the information noted above, I may collect additional information (collectively, the “Other Information”). Such Other Information may include:

  1. From You. Additional information about yourself that you voluntarily provide to me (e.g., via a survey), such as household income range, gender, product and service preferences, and other information that does not identify you personally.
  1. From Your Activity. Information that I automatically collect when you use the Websites, including, without limitation:

IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.

  1. From Cookies Information that I collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. I may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help me collect Other Information and to enhance your experience using the Websites. If you do not want me to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from me, the Websites may not function properly.
  1. Third-Party Analytics I use third-party analytics services (such as Google Analytics) to evaluate your use of the Websites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Websites and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide me the data. By accessing and using the Websites, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Websites.

  1. From Other Sources. I also may collect or receive information from third parties, such as Facebook and/or other third-party social media sites.

Information Collected by or Through Third-Party Advertising Companies

I may share Other Information about your activity on the Websites with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Websites and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable me, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

Accessing and Modifying Personal Information and Communication Preferences

If you have registered for the Websites, you may access, review, and make changes to your Personal Information, Billing Information, and certain Other Information by following the instructions found on the Websites. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Soul in the Raw marketing email. Customers cannot opt out of receiving transactional emails related to their account or their Orders. I will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in my subscription databases.

How I Use and Share the Information

I use the Personal Information, the Order Information, the Billing Information, and the Other Information (collectively, the “Information”) to provide my services; to process Orders; to administer my rewards and promotional programs; to maintain and improve my Websites and services to you; to solicit your feedback; and to inform you about my products and services and those of my third-party marketing partners.

I may also use and/or share Information as described below.

Soul in the Raw will access, use, and share the Information as required to process your Orders and provide support to you. In order to provide my services and administer my rewards and promotional programs, I may share the Information (excluding the Billing Information) with my third-party promotional and marketing partners, including, without limitation, businesses participating in my various programs. With your permission, third-party applications or services may access your Personal Information. I use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as Facebook and Twitter (e.g., when you agree to a pop-up requesting you to allow another application to access your account information). I also use OAuth to allow me to share information about you that is stored by me without sharing your security credentials. I may employ other companies and individuals to perform functions on my behalf. Examples may include providing technical assistance, Order fulfillment, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law. In an ongoing effort to better understand my Visitors, customers, and my products and services, I may analyze the Order Information and Other Information in aggregate form in order to operate, maintain, manage, and improve the Websites and/or my products and services. This aggregate information does not identify you personally. I may share this aggregate data with my affiliates, agents, and business partners. I may also disclose aggregated user statistics in order to describe my products and services to current and prospective business partners and to other third parties for other lawful purposes. I may share some or all of your Information with any of my parent companies, subsidiaries, joint ventures, or other companies under common control with me. As I develop my business, I might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets. To the extent permitted by law, I may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever I believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Soul in the Raw or others.

Information You Share

Please keep in mind that whenever you voluntarily make your Personal Information available to third parties — for example on message boards or web logs; through email; during webinars, classes, telephone conferences, or coaching calls; or in comment or chat areas — that information can be seen, collected, heard, and/or used by others besides me. I cannot be responsible for any unauthorized third-party use of such information.

How I Protect the Information

I take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. I cannot guarantee the security of my databases, nor can I guarantee that the Information that you supply will not be intercepted while being transmitted to and from me over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to me via email.

Important Notice to Non-U.S. Residents

It is important to note that the Websites and their servers are operated in the United States. If you are located outside of the United States, please be aware that any Information you provide to me will be transferred to the United States. By using the Websites and by providing me Information when using my services, you hereby irrevocably consent to this transfer and my use of the Information and data provided by you in accordance with this Privacy Policy.

Children

I do not knowingly collect Personal Information from children under the age of 13 through the Websites. If you are under 13, please do not give me any Personal Information. I encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce my Privacy Policy by instructing their children to never provide Personal Information through the Websites without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to me, please contact me, and I will endeavor to delete that information from my databases.

California Residents

Soul in the Raw does not monitor, recognize, or honor any behavioral advertising opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Users can visit my site anonymously.

Once this privacy policy is created, I will add a link to it on my home page or as a minimum, on the first significant page after entering my website.

My Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

  • On my Privacy Policy Page

Can change your personal information:

External Websites

The Websites may contain links to third-party websites. I have no control over the privacy practices or the content of any of my business partners, advertisers, sponsors, or other websites to which I provide links. As such, I am not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. I may change this Privacy Policy from time to time. By accessing the Websites and/or using my services after I make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, my use of the Information is governed by the Privacy Policy in effect at the time I collect the Information. Please refer back to this Privacy Policy on a regular basis.

  1. HOW I COLLECT YOUR PERSONAL DATA

I may collect data about you by you providing the data directly to me (for example by filling in forms on my site or by sending me emails). I may automatically collect certain data from you as you use my website by using cookies and similar technologies.

I may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators, and integrations such as Zapier.

I may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

  1. MARKETING COMMUNICATIONS

My lawful ground of processing your personal data to send you marketing communications is either your consent or my legitimate interests (namely to grow my business).

Before I share your personal data with any third party for their own marketing purposes I will get your express consent.

You can ask me or third parties to stop sending you marketing messages at any time by emailing me at rawsoulnutrition@gmail.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

  1. DISCLOSURES OF YOUR PERSONAL DATA

I may have to share your personal data with the parties set out below:

Other companies in my group who provide services to me.

Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers

Government bodies that require me to report processing activities.

Third parties to whom I sell, transfer, or merge parts of my business or my assets.

I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.

  1. INTERNATIONAL TRANSFERS

I am subject to the provisions of the General Data Protection Regulations that protect your personal data. Where I transfer your data to third parties outside of the EEA, I will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

I may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

If I use ME-based providers that are part of EU-ME Privacy Shield, I may transfer data to them, as they have equivalent safeguards in place; or

Where I use certain service providers who are established outside of the EEA, I may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, I may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

  1. DATA SECURITY

I have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. I also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on my instructions and they must keep it confidential.

  1. DATA RETENTION

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for I look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires me to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances I may anonymize your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email me at rawsoulnutrition@gmail.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you.

If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I should be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.

  1. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and are not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.