Privacy Policy

Last Updated: August 2018

This Privacy Policy describes how Secret Sauce Partners, Inc. and our services, including Fit Predictor (collectively, "Secret Sauce Partners", "we" or "us") collect, use and share information about you. This policy applies to information we collect when you use our services, such as Fit Predictor that help in determining your size, Style Finder, Outfit Maker and other functionalities we may provide from time to time (the "Services").

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

YOUR CHOICES

Information that you provide to us

We collect information that you provide to us directly. For example, we collect information that you provide about yourself in response to our questionnaire, such as your size in another brand, in order to create your Fit Profile (which is the profile that you create using Fit Predictor). If you do not want to create a Fit Profile you should disable cookies on your browser and not fill in the questionnaire. If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses.

Information that we collect when you use our Services

Similar to applications on other commercial website, our application utilizes a standard technology called "cookies" (see explanation below, "What Are Cookies?"), IP addressed, and web server logs to collect information about how our Services are used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our website, and the websites visited just before and just after our website.

Information we collect from our partners and other sources

We may also obtain information about you from other source, such as our business partners, and combine that with information we collect about you.

WHAT ARE COOKIES?

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a Web site, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each Web site can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a Web site to access the cookies it has already sent to you, not the cookies sent to you by other sites.

How Do We Use Information We Collect From Cookies?

Our cookies are used to differentiate you from other users in order to ensure that you receive personalized recommendations. In some cases, we also use cookies to prevent you from requiring you to log in more than is necessary for security. Cookies, in conjunction with our Web server's log files, allow us to calculate the aggregate number of people visiting our Web site and which parts of the site are most popular. This helps us gather feedback in order to constantly improve our Service. Cookies also allow us to anonymize and aggregate data for statistics and to measure key performance indicators. Cookies do not allow us to gather any personal information about you and we do not generally store any personal information that you provided to us in your cookies.

Can You Opt-Out Of Cookies?

You may only opt of the cookies if you disable cookies on your browser and clear your browser history each time you visit the Web site. Please follow your browser's documentation for instructions on how to disable cookies.

Sharing Information With Third Parties

We do not share any information with third parties.

USE OF INFORMATION

We use this information to:

We are based in the United States and the information we collect is governed by U.S. law. If you are a European resident, please see the Sections on GDPR and Privacy Shield below. By accessing or using our websites or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

PROTECTING YOUR INFORMATION

Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Certain Disclosures

We may disclose your personal information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law or comply with legal process served on us or Affiliated Parties; (b) protect and defend our rights and property, the Site, the users of the Site, and/or our Affiliated Parties; (c) act under circumstances to protect the safety of users of the Site, us, or third parties.

What About Other Website Through Which Our Services Are Available?

We are not responsible for the practices employed by any other website that may/may not link or provide access to our Services.

Please remember that this Privacy Policy is applicable only with respect to our Services. Your browsing and interaction on any other feature on a website that also offers our Services, including websites which have a link to our Services, is subject to that website's own rules and policies. Please read over those rules and policies before proceeding.

YOUR CONSENT

By using our Services and/or by providing the information you consent to our collection and use of your personal information as described in this Privacy Policy.

CHILDREN

We do not knowingly collect any personal information from children under the age of 13. We do not sell products for purchase by children and all children's products we sell are for purchase by adults only.

DATA SUBJECT RIGHTS

You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision. As used herein, "Personal Data" means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc. Disclosure of Personal Data is protected by federal, California and other state laws and GDPR and the laws of other countries.

To make any of the following requests, contact us using the contact details referred to in the "Contact Information" section of this policy.

CALIFORNIA RESIDENTS

Under California's "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of such data, the names and addresses of those businesses with which we shared for the immediately prior calendar year. To request a notice, please email your request to privacy@secretsaucepartners.com. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

EUROPEAN UNIION RESIDENTS (GDPR)

We intend to fully comply with the letter and spirit of the European Union General Data Protection Regulation ("GDPR"). We will not transport your Personal Data for processing outside of Europe without your permission. You can ask us to stop transporting your Personal Data for processing outside of Europe at any time and we will do so. But, if you do so, you will not be able to use our Services. You can ask us at any time for your Personal Data that we maintain on you and we will give you such information. You can ask us to delete the Personal Data that we maintain on you and we will do so. But, if you do so, you will not be able to use our Services. If you have any concerns or questions, please email them to privacy@secretsaucepartners.com.

CONTACTING US

If you have any questions, comments, or concerns about this Privacy Policy, please contact us at privacy@secretsaucepartners.com or at our mailing address:

Secret Sauce Partners, Inc.
20C Trolley Sq
Wilmington, DE 19806
United States of America

INFORMATION FOR EU AND SWISS INDIVIDUALS - EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD

Secret Sauce Partners, Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Secret Sauce Partners, Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

We are subject to the regulatory and enforcement authority of the US Federal Trade Commission.

We acknowledge the right of EU and Swiss individuals to access their data pursuant to the Privacy Shield Frameworks. Individuals wishing to exercise this right may do so by contacting us at privacy@secretsaucepartners.com.

We do not share any information with third parties therefore the Privacy Shield provision regarding liability for the actions of agent processors does not apply. If this practice should change in the future, we will update this policy to identify any third parties and provide individuals with opt-out or opt-in choice where applicable.

Note that we may be required to share EU and Swiss personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.

In compliance with the Privacy Shield Principles, Secret Sauce Partners, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact us at privacy@secretsaucepartners.com, or at our mailing address:

Secret Sauce Partners, Inc.
20C Trolley Sq
Wilmington, DE 19806
United States of America

Secret Sauce Partners, Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.