California Privacy Notice

This section provides additional information for California residents under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered "personal information," such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.

Collection and Disclosure of Personal Information

The personal information we collect is described above in Information we collect. The personal information we disclose for business or commercial purposes is described above in How we share and disclose information. The length of time for which we retain personal information is described above in How long we keep your data.

Business and Commercial Purposes for Collection

We collect personal information for the following business purposes:

• Conducting Surveys
• Creating Customer Profiles
• Data Storage
• Delivering Targeted Ads
• Fulfilling Customer Orders
• Meeting Compliance & Legal Requirements
• Operating our Website or Mobile Apps
• Organizing & Managing Data
• Preventing Fraud
• Processing Payments
• Providing Customer Support
• Sending Promotional Communications
• Tracking Purchases & Customer Data

We also "share" and "sell" (as defined in the CCPA) personal information for commercial purposes, including to advertise and market our products.

Information “Sharing” and “Selling”

We “share” certain personal information with third party ad networks for purposes of behavioral advertising, including: Commercial and Financial Information, Internet Activity, Online Identifiers, and Personal Identifiers. This allows us to show you ads that are more relevant to you.

We use third party data analytics providers and this may be considered a “sale” of information under the CCPA.

You may opt-out of these data practices here.

We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age.

CCPA Rights

Your CCPA rights are described below. You can make a Request to Know or a Request to Delete under the CCPA by submitting a Privacy Request or by emailing us at CCPA@eczemacarecompany.com.

Right to Know

You have the right to request to know the following about the personal information we have collected about you in the past 12 months:

• the categories and specific pieces of personal information we have collected about you
• the categories of sources from which we collect personal information about you
• the business and commercial purposes for which we collect personal information
• the categories of third parties with whom we share the information
• the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose

The information we would provide to you in response to a Request to Know Categories is contained in this Privacy Notice. To access the specific personal information we have about you, submit a Request to Know via the link above. If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.

Right to Delete

You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.

We consider information to be necessary for our business operations if it is used to:

• Complete an obligation to you that you have requested
• Detect and resolve issues related to security or functionality
• Comply with legal obligations
• Enable solely internal uses

Right to Non-Discrimination

If you exercise your CCPA consumer rights:

• We will not deny goods or services to you
• We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
• We will not provide a different level or quality of goods or services to you

Right to Opt-Out

You have the right to opt-out of any selling and sharing of your personal information.

You may exercise your right to opt-out here.

Opt-Out Preference Signals. Your browser settings may allow you to automatically transmit the Global Privacy Control (GPC) signal to online services you visit. When we detect such signal, we place a U.S. Privacy String setting in your browser so that any third party who respects that signal will not track your activity on our website. GPC is supported by certain internet browsers or as a browser extension. You can find out how to enable GPC here.

Right to Correct

You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.

Request Verification

Before we can respond to a Request to Know or Request to Delete, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft. Requests to Opt-Out do not require verification.

Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request.

For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.

In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:

• If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
• If the only data we have collected about a consumer is gathered through website cookies (i.e. the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.

Contact Us

If you have any privacy-related questions, please send them to CCPA@eczemacarecompany.com.

Virginia Privacy Notice

This section provides additional information for Virginia residents under the Virginia Consumer Data Protection Act (VCDPA). ​​The terms used in this section have the same meaning as in the VCDPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the VCDPA.

Collection and Disclosure of Personal Information

The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we share and disclose information. The length of time for which we retain personal information is described above in How long we keep your data.

Purposes for Processing

We process personal information for the following purposes:

• Conducting Surveys
• Creating Customer Profiles
• Data Storage
• Delivering Targeted Ads
• Fulfilling Customer Orders
• Meeting Compliance & Legal Requirements
• Operating our Website or Mobile Apps
• Organizing & Managing Data
• Preventing Fraud
• Processing Payments
• Providing Customer Support
• Sending Promotional Communications
• Tracking Purchases & Customer Data

Data “Selling” and Targeted Advertising

We process personal data for purposes of targeted advertising (as defined in the VCDPA), including online identifiers and internet activity. This allows us to show you ads that are more relevant to you.

You may opt-out of these data practices here.

Profiling

The VCDPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.

We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.

VCDPA Rights

Your VCDPA rights are described below. You can make a Privacy Request or contacting us at CCPA@eczemacarecompany.com.

Right to Access

You have the right to confirm whether we are processing personal data about you and to access such data. Where processing is carried out by automated means, you have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.

If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.

Right to Delete

You have the right to request that we delete any personal data provided by or obtained about you. We will permanently delete any such personal data from our records and direct our processors to do the same. However, we may retain your personal data if it is necessary for certain purposes, including the following:

• To comply with legal obligations
• To comply with an official investigation or cooperate with law-enforcement agencies
• To establish or defend legal claims
• To complete an obligation to you that you have requested
• To respond to security incidents, fraud, harassment, and other similar activity
• To identify and repair technical errors
• To conduct internal research to develop, improve, and repair our products and services
• For internal operations that are reasonably aligned with your expectations

Any personal data retained for these purposes will not be processed for other purposes.

Right to Non-Discrimination

If you exercise your VCDPA consumer rights:

• We will not deny goods or services to you
• We will not charge you different prices or rates for goods or services
• We will not provide a different level or quality of goods or services to you

However, we may offer a different price, rate, level, quality, or selection of products or services if your personal data is required in order to provide those products or services and you have exercised your right to opt out, or the offer is related to a voluntary loyalty or rewards program.

Right to Opt-Out

You have the right to opt-out of any selling of your personal data, processing of your personal data for purposes of targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects for you.

You may exercise your right to opt-out here.

Right to Correct

You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.

Right to Appeal

If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time.

If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Virginia Attorney General’s Office.