Privacy Policy

Last Updated: July 13, 2022

This privacy policy (“Privacy Policy”) governs how we, NEPTUNES BLVD. (hello@NEPTUNESBLVD.com) (“NEPTUNES BLVD.” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive to you (“User”, “you”), such as in the following use cases:

• When you browse or visit our website, https://neptunesblvd.com/ (“Website”)
• When you make use of, or interact with, our Website
• When you create an account and purchase a product
• When you request a customized design
• When you use our “drop a hint” functionality
• When you use our “refer a friend” functionality
• When you use our “Tryon share” functionality
• When you use our “Ambassador program” functionality
• When you participate in our Ambassador Surveys
• When you participate in our “Ambassador Pro Tips” functionality
• When you send an “engagement moment”
• When we request a review of our products / services
• When you contact us for support or otherwise (e.g. customer support and/or via chat)
• When you sign up to receive our newsletters/email list/SMS
• When we use the Personal Data of our service providers
• When you make use of the Digital Photo Booth in our store
• When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

• What information we collect, why we collect it, and how it is used
• How we protect and store your information
• How we share your Personal Data
• Additional information regarding transfers of Personal Data
• Your privacy rights and choices
• Cookies, tracking options and California do not track disclosures
• Use by children
• Links to and interaction with third party products
• Specific provisions applicable under California privacy law
• How to contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

How We Protect and Store Your Information

• Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
• Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy.

How We Share Your Personal Data

We may share your information as follows:

• Affiliates: We may share your information with our affiliates and subsidiaries for business, operational, promotional, and/or marketing purposes;
• Our Service Providers: We share your information with our third party service providers that provide business, professional or technical support functions for us (including to the extent necessary or desirable to fulfill or ship your order or complete your transaction; provide customer support; process your purchases), help us operate our business, IT and the Website, or administer activities on our behalf. We also share your Personal Information with our business partners with whom we jointly offer products or services.
• Select Third Parties: With our joint marketing partners for the purposes described in this Policy, including when we believe such partners may have offers of interest to you;
• Legal Matters; Safety: We may share your information to the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. We also may disclose your information to protect the security of our Site, servers, network systems, and databases, including for fraud prevention purposes. We also may disclose your information as necessary, if we believe that there has been a violation of our Terms of Use, any other legal document or contract related to our services, or the rights of any third party.
• Sale or Transfer of Business or Assets: If, in the future, we sell or transfer some or all of our business or assets to a third party, or in the event of bankruptcy or a comparable event, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
• With Your Consent: Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with any marketing consents or opt-in to optional additional services or functionality, if required by applicable law).
• Aggregate or Anonymous Non-Personal Information: We may share aggregate, anonymous, or de-identified non-personal data with third parties for their marketing or analytics uses.

Additional Information Regarding Transfers of Personal Data

• Internal transfers: Transfers within the NEPTUNES BLVD. The group will be covered by an internal processing agreement entered into by members of the NEPTUNES BLVD. group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
• External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When NEPTUNES BLVD. engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. NEPTUNES BLVD. also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.
• Storage: Internal servers of NEPTUNES BLVD. located in Florida, US.

Your Privacy Rights and Choices

Rights under GDPR: The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we rectify any Personal Data we hold that it is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Data (e.g. from our records).. Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;