PRIVACY POLICY

Last Updated: January 17, 2024

What Does This Privacy Notice Cover?

This privacy notice (“Privacy Notice”) is intended to provide you (“you” or “your”) with specific details about how Senna Cosmetics, Inc. (“Senna Cosmetics,” “we,” and “us”) collects and processes your personal and personally identifiable information through your use of its website and associated services (collectively, the “Website”).

Before using the Website or providing information to us, please carefully review this Privacy Notice. By using or accessing the Website, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Notice, as revised from time to time. Senna Cosmetics may modify, amend, replace, or suspend this Privacy Notice at any time. If you have any questions or suggestions regarding our Privacy Notice, or if your personal information is not accurate or complete, please contact us at:

Privacy Officer
Senna Cosmetics, Inc.
28042 Avenue Stanford, Unit A
Valencia, CA 91355
[email protected]

Who Do We Collect Personal Data From?

Senna Cosmetics only knowingly collects personal or personally identifiable information from individuals over the age of eighteen (18). By providing Senna Cosmetics with your personal or personally identifiable data and using the Website, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use the Senna Cosmetics Website and please do not provide personal or personally identifiable information to us.

What Are Your Privacy Rights?

Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact Senna Cosmetics’ Data Protection Officer as disclosed in this Privacy Notice.

You do not need to pay a fee to access your PII or to exercise your rights. However, Senna Cosmetics may charge a reasonable fee if your request is unreasonable or excessive.

To confirm your request, Senna Cosmetics may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. Senna Cosmetics will attempt to respond to all legitimate requests within thirty (30) days.

If you are outside of the State of California, to cease our collection, processing, and use of your personal or personally identifiable information, you may cease using the Website, delete your user account, configure your web browser settings to reject all cookies or prompt you before a cookie is set, or contact Senna Cosmetics directly at [email protected]. In some situations, Senna Cosmetics may not be able to fully grant your request, such as where Senna Cosmetics is legally obligated to retain your personal or personally identifiable information under the law, to protect its security, the security of its Website, or the security of its employees or contractors, where your request is frivolous or vexatious, or where your personal or personally identifiable information is subject to a legal or administrative order, such as a subpoena or warrant. California residents may have additional rights provided by statute, as explained below.

Your California Privacy Rights

California residents have a right to request that we disclose what personal or personally identifiable information we collect from you and whether, and how, we disclose or sell that personal or personally identifiable information. California residents may also request that we delete any personal or personally identifiable information collected or maintained by us from you.

California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information” or “Do Not Sell My Info.” By selecting this link or icon, You “Opt Out,” which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal or personally identifiable information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on personal or personally identifiable information that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.

To submit a request for a list of the categories of personal or personally identifiable information collected from you or to request that Senna Cosmetics delete your personal or personally identifiable information, please email us at [email protected] or send a letter to us at the following address:

Privacy Officer
Senna Cosmetics, Inc.
28042 Avenue Stanford, Unit A
Valencia, CA 91355
[email protected]

To verify your request, we may request certain information from you to confirm that you are a Senna Cosmetics user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to Senna Cosmetics to disclose or delete your personal information. To do so, you must provide Senna Cosmetics with proof that the individual or business has been appointed as your agent, such by providing a signed power of attorney form, and provide accurate responses to any information requested by Senna Cosmetics that may be necessary to confirm that you are a Senna Cosmetics user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by Senna Cosmetics for their exercise of these rights conferred under California law.

What Personal Data We Collect From You and How Do We Use It?

When you use the Website, we may collect personal or personally identifiable information from You (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data.

We may collect and process the following categories of PII about you:

  • Communication Data. Communication data includes any communication that you may send to us through the Website, email, or social media. We process this data to communicate with you by email, web form, or other means, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. Senna Cosmetics’ lawful ground for collecting and processing this PII is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.

  • Identification and Contact Data. Identification and contact data includes data that you submit to us or authorize to be submitted to us through our Website or e-mail, such as your name, address, country, phone number, and email address, data that you voluntarily provide when submitting customer support requests or other communication to Senna Cosmetics, and identification data that is collected automatically when you use our Website, such as data stored in persistent cookies when you login to our Website or analytics data that is collected from you when you use our Website. We collect and process identification and contact data to respond to your requests for products or customer support, to operate our Website, to authenticate you as a user of our Website, to ensure that timely and relevant content is provided to you, to secure our Website, to ensure that our Website operates in a fast and efficient manner, and to maintain backups of our Website and any submissions that you may have made to it. Senna Cosmetics’ lawful grounds for processing this data are (1) its legitimate business interests in administering and offering its Website and products, (2) to comply with legal obligations to which Senna Cosmetics is subject, (3) to utilize user data as necessary for the performance or administration of a contract, such as a contract related to the sale of Senna Cosmetics’ products, and (5) your explicit consent. Where our collection and processing of Your identification and contact data is based on your explicit consent, you have the right to revoke your consent at any time.

  • User Data. User data includes data that you voluntarily submit to Senna Cosmetics when you create a user account and data about how You use the Website, such as your name, address, country, phone number, and email address. This includes data stored in persistent cookies when you login to the Website and analytics data that is collected when you use the Website. We collect and process this data to operate the Website, to authenticate you as a user of the Website, to ensure that timely and relevant content is provided to you, to secure the Website, to ensure that the Website operates in a fast and efficient manner, and to maintain backups of the Website. Senna Cosmetics’ lawful ground for processing this user data is its legitimate business interests in administering and offering the Website and to fulfill your orders for products through the Website.

  • Technical Data. Technical data includes data about your use of the Website, such as your IP address, your login data, your phone number, your mobile device model, your operating system, your geolocation, and your time zone. We may collect this data from your use of the Website and from advertising IDs, including from Meta’s pixel, TikTok conversion tracking pixels, or Google Analytics IDs. Senna Cosmetics processes this data to analyze your use of the Website, to route Website traffic, to administer and secure the Website, to provide location-relevant content, and to troubleshoot problems with the Website. Senna Cosmetics’ lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy.

  • Marketing Data. Marketing data includes data about your preferences in receiving and interacting with Senna Cosmetics’ advertisements or content on the Website and your contact information when you subscribe to our email newsletters. We collect this data from your use of the Website and from advertising IDs created through advertising programs, such as Google Advertising IDs, TikTok conversion tracking pixels, and Meta pixels. Senna Cosmetics does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. Senna Cosmetics’ lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy by providing advertisements, including remarketing advertisements, to you.

  • Personally Sensitive Data. Personally sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, or information about your health. Senna Cosmetics does not collect personally sensitive data. However, California law states that geolocation information may be considered sensitive personal information. Senna Cosmetics may collect your geolocation via your IP address, as otherwise specified in this Privacy Notice.

Senna Cosmetics will only use your PII for the purpose for which it was collected. If Senna Cosmetics needs to use your PII for an unrelated new purpose, Senna Cosmetics will provide you with notice of this new use and will explain the lawful ground for such processing. Senna Cosmetics may process your PII without your knowledge or consent where required or permitted by law.

Senna Cosmetics does not use your PII to automatically make any decisions or to create an automated profile about you.

What Information Do We Collect From Third Parties?

Senna Cosmetics may collect data about you through cookies and other behavioral advertising technologies. This helps Senna Cosmetics understand how you use the Website, to understand any patterns that may be associated with your use of the Website, and to serve contextually relevant advertisements to you. This aids Senna Cosmetics in developing or improving its Website and marketing communications in response to your needs or wants.

Senna Cosmetics may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the Website and are automatically deleted when you close your web browser. Session cookies may be used to direct internet traffic to a server that is closer to you or to allow us to identify you as you move between pages of the Website. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the website that created the cookie when you revisit it again. Senna Cosmetics may use persistent cookies to authenticate you when you return to the Website so that you do not have to login again or when it utilizes Google Analytics or other analytics providers, which is intended to track the origin and behavior of traffic to the Website. Senna Cosmetics may use the following analytics providers, and You are directed to review their cookie policies:

Adobe Dynamic Tag Management: https://www.adobe.com/privacy/policy.html
Adobe Marketing Cloud: https://www.adobe.com/privacy/policy.html
Lucky Orange: https://www.luckyorange.com/legal/privacy
Microsoft Clarity: https://learn.microsoft.com/en-us/clarity/

Senna Cosmetics may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, TikTok, or Apple, Google and Webmaster Tools like Google Search Console, Google Analytics, Google Maps, Google Maps API.

 

We partner with Microsoft Clarity and Microsoft Advertising to capture how You use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses Your data, visit the Microsoft Privacy Statement

How Do We Use Your Personal Data For Marketing?

As stated above, Senna Cosmetics’ lawful ground for sending you marketing communications is either consent or its legitimate business interests, such as to grow its business by advertising products to you. Senna Cosmetics may send you marketing communications, such as e-mail newsletters, if you have asked for information concerning its goods or services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask Senna Cosmetics to stop sending you marketing messages at any time by logging into the Website to adjust your subscriptions to our marketing within your user account or by following the opt-out link in any marketing message sent to you. If you opt out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.

As stated above, Senna Cosmetics may also use PII to provide behavioral or cross-context advertising to you through third party platforms and websites based on your consent to Senna Cosmetics’ privacy practices as outlined in this Privacy Notice in jurisdictions where such consent is required. In jurisdictions where consent is not required, you can prevent Senna Cosmetics from using your PII to provide behavioral or cross-context advertising by ceasing your use of the Website, deleting your User Account, configuring your web browser settings to reject all cookies or to prompt you before a cookie is set, or by contacting Senna Cosmetics directly at [email protected]

When Do We Disclose Your Personal Data?

Senna Cosmetics may share Your PII with the following parties:

Service providers that provide Senna Cosmetics with information technology, software as a service, cloud storage, content delivery networks, advertising, or other administrative services;

  • Service providers, such as distributors, wholesalers, or 3PLs that provide Senna Cosmetics with shipping or order fulfillment services in order to fulfill your product orders;
  • Senna Cosmetics’ accountants, auditors, insurers, or attorneys;
  • Law enforcement agencies upon the receipt of a subpoena or court order or where necessary to protect Senna Cosmetics’ personnel or property; and
  • Government bodies or regulators that require Senna Cosmetics to report its processing activities.

Senna Cosmetics may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets. In the event of a sale, transfer, or merger of Senna Cosmetics, its business, or its assets, the acquiring entity shall be subject to the same terms of this Privacy Notice until otherwise amended, modified, suspended, or replaced. Senna Cosmetics requires all third parties that receive a transfer of PII from Senna Cosmetics to maintain the same level of respect for the protection of PII as Senna Cosmetics and Senna Cosmetics only allows third parties to process your personal data for the specific purposes listed in this Privacy Notice.

How Do We Secure Your Information?

We implement a variety of security measures to maintain the safety of your personal information, such as the use of industry-standard encryption when you place an order. However, no security measures are impenetrable and there are always security risks. Senna Cosmetics will notify you and any regulatory body of any breach of your PII or Senna Cosmetics’ security measures if it is legally required to do so. Senna Cosmetics has put into place data security measures to protect Your PII. Senna Cosmetics allows access to Your PII only by employees and service providers who have a need to know or access your PII on Senna Cosmetics’ instructions. Senna Cosmetics will notify you and any regulatory body of any breach of your PII or Senna Cosmetics’ security measures if it is legally required to do so.

Do We Use Cookies?

Yes, as stated above, we do use persistent and session cookies. Cookies are small files that a site or its service provider transfers to your computer or mobile device through your web browser (if you allow) that enables the sites or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us remember and process the items in your shopping cart, understand and save your preferences for future visits, and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

How Long Do We Retain Your Data?

We will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for the purposes of satisfying any legal, accounting, or reporting requirements. With respect to location data, information and contact data, technical data, usage and interaction data, and marketing data, we may retain this data for so long as it is relevant to the uses disclosed in this Privacy Notice. We may retain account data, public data, and communications data for so long as you maintain a user account with Senna Cosmetics, and we may retain this data for longer periods where there is a need to retain this data to comply with Senna Cosmetics’ legal obligations, such as the preservation of electronic evidence or compliance with a preservation order.

Childrens’ Online Privacy Protection Act Compliance

Senna Cosmetics complies with the requirements of COPPA (Childrens’ Online Privacy Protection Act). Senna Cosmetics does not knowingly collect any information from anyone under 13 years of age, and its products and services are sold to individuals 13 years of age or older. If you believe that Senna Cosmetics has collected PII from someone under the age of 13, you are directed to notify Senna Cosmetics immediately at [email protected].

What Personal Data Have We Collected From California Residents?

The following rules apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, B, D, E, and F) as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Notice:

Category

Examples

Collected

A. Identifiers

Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

YES

B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))

Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.

YES

D. Commercial

Records of products purchased.

YES

F. Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data

Physical location or movements.

YES

K. Inferences

Inferences drawn from any of the above-identified information to create a profile about a consumer.

YES

We obtain these categories of PII directly from California residents when they complete forms through our Website, email us, or provide it to us as a part of a transaction or inquiry concerning our products. We also obtain these categories of PII indirectly from California residents while observing their actions on our Website and from third parties or service providers that they have authorized to receive and share PII.

Colorado Residents

Senna Cosmetics does not control or process the personal data of more than 100,000 consumers annually or derive its revenue or receive discounts from the sale of personal data of at least 25,000 consumers.

Connecticut Residents

Senna Cosmetics does not process or control the personal data of 100,000 or more consumers and does not earn more than 25% of its revenue from the sale of personal data while processing or controlling the personal data of 25,000 or more consumers.

Montana Residents

Senna Cosmetics does not control or process the personal data of 50,000 or more Montana residents during a calendar year or derive over 25% of its revenues from the sale of personal data and control or processing of personal data of 25,000 or more Montana residents. Therefore, the Montana Consumer Data Privacy Act does not apply to Senna Cosmetics’ collection or use of PII.

Nevada Residents

If You are a resident of Nevada, you may provide notice to us to limit the sale of Your PII to third parties for resale or licensing purposes. However, we do not sell Your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, You may send us an email to [email protected] with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and User Account information.

Tennessee Residents

Senna Cosmetics does not exceed $25 million in annual revenue, control or process the personal information of 175,000 or more Tennessee consumers, or control or process the data of 25,000 consumers while deriving more than 50% of its gross revenue from the sale of personal information.

Texas Residents

Senna Cosmetics is considered a small business as defined by the Small Business Administration and, therefore, is exempt from the Texas Data Privacy and Security Act. However, Senna Cosmetics generally collects and processes PII only to the extent that it is adequate, relevant, and reasonably necessary for the purposes disclosed in this Privacy Notice. The categories of PII collected by Senna Cosmetics are disclosed within this Privacy Notice, and Texas residents may request, free of charge, information of the PII collected from them twice annually.

Utah Residents

Senna Cosmetics does not have annual revenues of $25,000,000 or more and control or process the PII of 100,000 or more consumers. Therefore, the Utah Consumer Privacy Act does not apply to Senna Cosmetics’ collection and use of PII.

Virginia Residents

Senna Cosmetics does not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of its gross revenue from the sale of personal data. For these reasons, the Virginia Consumer Data Protection Act (VCDPA) does not apply to Senna Cosmetics’ collection and use of PII.

Global Privacy Control

Senna Cosmetics does not yet recognize Global Privacy Control signals, but it strives to comply with any requests to opt out from the collection and use of PII. Should you wish to opt out from the collection and use of your PII, please contact our Data Protection Officer through the contact information provided in this Privacy Notice.

Third Party Links

Senna Cosmetics’ Website may include links to third party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. Senna Cosmetics does not control these third-party links and you are advised to review their respective privacy policies.

Responding to Do Not Track Signals

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. Our Website is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure Your browser settings to reject all cookies or prompt You before a cookie is set.

Changes to our Privacy Notice

Whenever Senna Cosmetics changes its Privacy Notice, we will post those changes to this Privacy Notice on the Website and other places that we deem appropriate. Your use of the Senna Cosmetics Website following these changes indicates your consent to the practices described in the revised Privacy Notice.

Contacting Us

If you have any questions about this Privacy Notice or the manner by which we collect or use PII about you, email us at [email protected].

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