Effective Date: June 19, 2023
Date Last Updated: June 19, 2023
PRIVACY STATEMENT – YOUR PRIVACY RIGHTS
1. Introduction
Thank you for your interest in K Sahai,LLC (“K Sahai,” “we,” “us,” or“our”). We are committed to protecting the privacy of those with whom weinteract. This Privacy Statement (“Statement”) contains details about howwe collect, use, and share Personal Information about you (defined below) thatwe obtain from you when you interact with us via our website, email, mobileapplication, and in other online and offline interactions, and from othersources.
Please read this Statementcarefully. It applies to the following websites owned and operated by KSahai, and our other websites where we post this document as the applicablePrivacy Policy, along with any related websites, mobile apps, networks,applications, insurance agent and representative services, and communicationchannels (including online chat and email), and other services provided by us(collectively, the “Service”).
Applicability:
We collect Personal Information inseveral contexts as described below. However, this Statement does notapply to the following information:
Information about our employees,contractors, agents, and job applicants. Such information is subject to aseparate privacy notice that we will make available to individuals.
Information we collect from individuals with whom we engage in solelybusiness-to-business communications and transactions, such as information aboutthe employees of our business partners and customers.
Changes:
We may update this Statement from timeto time. The current Statement will be effective when posted. Please check this Statement periodically for updates. If any of thechanges are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to thisStatement by posting an update on this website. When required underapplicable law, we will seek affirmative consent from you before makingmaterial changes to the way we handle Personal Information previously collectedfrom you. If you do not provide such consent, Personal Information willcontinue to be used in a manner that is consistent with the version of thisStatement that was in effect when the information was collected.
2. Sources of Personal Information
We collect information about you andhow you interact with us in several ways, including:
1. Information youprovide to us directly. We collect information that you provide to us directly,such as when you register with us through our Skin Quiz, Soul Quiz, or emailnewsletter or other product through our Services.
2. Informationautomatically collected or inferred from your online interaction withus. We automatically collect technical information about your onlineinteractions with us (such as IP address and browsing preferences).
3. Information frompublic sources, such as information from public records maintained bygovernment entities, and information you submit in public forums.
4. Information fromthird parties. We receive information about you and your interactions withus from third parties, such as marketing and advertising providers, socialnetwork services, data brokers, and companies that provide or sell lists ofpotential purchasers. We also may receive information about you fromfriends and family members.
We may combine information that wereceive from the various sources described in this Statement, including third-partysources and public sources, and use or disclose it for the purposes identifiedbelow.
3. Types of PersonalInformation We Collect
Thetypes of Personal Information that we may collect about you include:
1. Identifiers, suchas your name, alias, postal address, country of residence, unique personalidentifier, online identifier, internet protocol address, email address, username,phone number, social media identifiers (e.g., Twitter handle, Instagram name,etc.).
2. Customer records,such as your name, address, telephone number, PayPal, After Pay, credit cardnumber, or other payment information.
3. Birthday, SkinType, Goals & Concerns, Location of Birth, and general wellness profile arecollected through the Skin Quiz and Soul Quiz.
4. Commercialinformation and preferences, including product preferences, advertisingpreferences, products or services purchased, obtained, or considered, or otherpreferences or interests.
5. Internet or otherelectronic network activity information, such as your browsing history, searchhistory, IP address, and information regarding your interactions with us(including interacting with us online, by the mobile application, and throughadvertisements).
6. Geolocationinformation, such as approximate location based on your IP address.
7. Audio, electronic,visual, or similar information, such as telephone messages, or customersupport chat logs.
8. Professional oremployment information, such as job title, employer, business address andcontact information.
9. Inferences drawn from any of the information we collect to create aprofile about you reflecting your preferences, characteristics, psychologicaltrends, predispositions, behavior, attitudes, intelligence, abilities, andaptitudes.
4. How We Use Your Personal Information
We may use each category of yourPersonal Information described above in the following ways:
1. To enableinteractions between you and us, such as to facilitate applications for, andpurchases of our products; to register and administer your account, to supportyour interactions with us; to provide information about skin care and essentialoil blends; to communicate with you about your policy or our data practices; toinstall and configure changes and updates to programs and technologies relatedto interactions with us; to authenticate those who interact with us; and torespond to your requests, complaints, and inquiries.
2. For our owninternal business purposes, such as to evaluate or audit the usage andperformance of programs and technologies related to interactions with us; toevaluate and improve the quality of your interactions with us and the qualityof programs and technologies related to interactions with us; to design newservices and products; to process and catalog your responses to surveys orquestionnaires (e.g., customer satisfaction reviews); to perform internalresearch for technological development and demonstration; to conduct dataanalysis and testing; and to maintain proper business records.
3. For legal, safety,or security reasons, such as to comply with laws and other legal requirements;to protect our safety, our property or the rights of those who interact withus, or others; and to detect, prevent, and respond to security incidents orother malicious, deceptive, fraudulent, or illegal activity.
4. In ade-identified, anonymized, or aggregated format. We may convert PersonalInformation into a de-identified, anonymized, or aggregated format, and usesuch information for any legal purpose.
5. Formarketing. We may use your Personal Information to market our products orservices. We may use your Personal Information to invite you to participate inmarketing surveys, questionnaires, promotions, events or contests. We may auditaspects of our ad impressions. We may use your Personal Information forshort-term transient use, including for contextual ad customization. We may useyour Personal Information to enhance our content and to deliver advertisementsto you, including in commercial emails. For more information about onlinemarketing activity, see Section 6 below.
6. To fulfill otherpurposes disclosed at the time you provide Personal Information or otherwisewhere we are legally permitted or are required to do so.
7. For any otherpurposes for which you provide consent.
5. WithWhom We Share Your Personal Information
Wemay share your Personal Information with the categories of recipients describedbelow:
1. Service providers and other third parties that help fulfillrequests and purchases:We may share your Personal Information with Dept of financial service licensedthird-party service providers that facilitate and support us in processing arequest or transaction on your behalf; to provide you with products, andservices; and to process payments. We only share your Personal Information withK Sahai when you request to be contacted by us. You may be connected with ourservice providers: including, but not limited to Klaviyo, Shopify, credit cardprocessors, and USPS.
2. Subsequently,if you choose provide Personal Information to any third-party entity will begoverned by that entity’s privacy policy.
3. Business partners: We may also provide your PersonalInformation or provide access to your Personal Information to our businesspartners on your behalf.
4. For legal, security and safety purposes: We may shareyour Personal Information with third parties such as law enforcement,regulators, or others to comply with federal, state, or local laws, a subpoenaor other legal process, and other applicable legal requirements; to protect theconfidentiality and security of our records; to protect against or preventfraud; for claims administration; to enforce or apply our Terms of Use andother agreements; and to protect our rights and our property or safety of ourusers or third parties.
5. Organizations with which you have a relationship: Wemay disclose Personal information to an affinity group, or other entity withwhich you may have a relationship when you followed such entity online or whenyou use our website or call center in connection.
6. To others with your consent.
We may also de-identity, anonymize, oraggregate Personal Information to share with third parties for any purpose.
6. How We Use Cookies and Automatic DataCollection Tools
We also collect information, viacookies, web beacons, pixels, tags, or other tracking technologies, such asyour Internet Service Provider and IP address, the date and time you access ourwebsite, the pages you access while visiting our website, and the Internetaddress from which you access our website. Some cookies exist only during asingle session, and some are persistent over multiple sessions over time. Weuse these technologies to remember user preferences, maximize the performanceof our website and services, provide you with offers that may be of interest toyou, measure the effectiveness of our email campaigns and to personalize onlinecontent. These cookies and other technologies may be used to track you across devices.
To provide you with more relevant andinteresting experience, we may work with third party companies to display adsor customize the content on the website and on other websites. These companiesmay use cookies and similar tracking technologies as described in thisStatement to gather information about your visits to the website, as well asyour visits elsewhere on the Internet. These companies use this information toprovide you with more relevant advertising known as interest-based advertising.You may choose whether to receive some interest-based advertising by submittingopt-outs. Some of the companies that perform advertising-related services forus may participate in the Digital Advertising Alliance’s (“DAA”)Self-Regulatory Program for Online Behavioral Advertising. For more informationabout the DAA’s program, including how you can opt-out from receivinginterest-based advertising from some or all of the DAA’s members,visit http://www.aboutads.info/choices. Some of these companies may alsobe members of the Network Advertising Initiative (“NAI”). For moreinformation about the NAI including how you can opt-out from receivinginterest-based advertising from some or all of NAI’s members, pleasevisit http://www.networkadvertising.org/choices/. Opting out ofinterest-based advertising will not opt you out of all advertising, but ratheronly interest-based advertising from us or our agents or representatives. Also,if your browsers are configured to reject cookies when you visit these opt-outwebpages, or you subsequently erase your cookies, use a different device or webbrowser or use a non-browser-based method of access (e.g., mobile app), yourNAI / DAA browser-based opt-out may not, or may no longer, be effective.
Some browsers have incorporated Do NotTrack (“DNT”) preferences. Most of these features, when turned on, send signalsto the website you are visiting that you do not wish to have information aboutyour online searching and browsing activities collected and used. Asthere is not yet a common agreement about how to interpret DNT signals, we donot honor DNT signals from website browsers at this time. However, youmay refuse or delete cookies. If you refuse or delete cookies, some ofour website functionality may be impaired. If you change computers,devices, or browsers, or use multiple computers, devices, or browsers, anddelete your cookies, you may need to repeat this process for each computer,device, or browser. Please refer to your browser’s Help instructions to learnmore about how to manage cookies and the use of other tracking technologies.
7. Security and Retention
We maintain reasonable securityprocedures and technical and organizational measures to protect your PersonalInformation against accidental or unlawful destruction, loss, disclosure,access, alteration, or use. Nevertheless, transmission via the Internet andonline digital storage are not completely secure and we do not guarantee thesecurity of your information collected through the Service.
8. Children’s Privacy
Interactions with us are intended forindividuals 16 years of age and older. Our interactions are not directedat, marketed to, nor intended for, children under 16 years of age. Someof our products are suitable for children ages 2 and above. However, purchases shouldbe made by adults. We do not knowingly collect any information, includingPersonal Information, from children under 16 years of age. If you believethat we have inadvertently collected Personal Information from a child underthe age of 16, please contact us at the address below and we will usereasonable efforts to delete the child’s information from our databases.
9. K Sahai MobileApplication
K Sahai’s mobile application isintended to simplify the process of adding our business contact information andsilencing solicitation calls using the “silence unknown caller” feature withinthe phone settings. Our intention is to also provide greater accessibility andcustomer support using a mobile application.
K Sahai Mobile application requestspermission to access contacts for the purpose of adding K Sahai businesscontact information into the user's contact section. Access to the user’scontact permission also provides K Sahai access to all contacts stored in theuser’s phone. K Sahai does not fetch contact details within the phone at anytime. K Sahai mobile application assists users with enabling features alreadylocated in their phone settings such as silencing unknown callers.
10. External Links
When interacting with us you mayencounter links to external sites or other online services, including thoseembedded in third-party advertisements or sponsored content which we do notcontrol. We are not responsible for the privacy practices and datacollection policies for such third-party services. You should consult theprivacy statements of those third-party services for details.
11. Your Rights
Upon request, K Sahai will provide youwith information about whether we hold any of your personal information. Ifyour personal information changes, or if you otherwise want to correct, update,delete, or make other requests regarding your data (such as limiting sharingwith non-affiliates), you may mail at:
Customer Service, K Sahai email hello@ksahai.com
or by mail at:
K Sahai
4260 NW 1st AvenueUnit 53
Boca Raton, 33431
We will make reasonable efforts torespond to your request but cannot guarantee that we will be able to honor yourrequest. For example, we generally will retain your information for aslong as your account is active, as needed to provide you services, or for otherbusiness purposes. We will retain and use your information as necessary tocomply with our legal obligations, resolve disputes, and enforce ouragreements.
12. Terms of Use
The Terms of Use for interactions withus is incorporated by reference into this Statement and can be found onthis site.
13. Contact
If you have questions regarding thisStatement or our privacy practices, please contact us at:
K Sahai, LLC.
ATTN: Privacy
4260 NW 1st AvenueUnit 53
Boca Raton, 33431
hello@ksahai.com
To opt-out of receiving promotionalemail messages from us, please click on the “Unsubscribe” link contained at thebottom of each email or by contacting us using the information above. Toopt-out of receiving satisfaction surveys and/or information on additionalproducts and services from us, you may contact us at the information above.Please note that you will still receive communications from us regarding yourinsurance quote, application, policy or advanced premium tax credit even if youopt-out of receiving our surveys and/or notices of additional products orservices.
14. Dispute Resolution
If you have an unresolved privacy ordata use concern that we have not addressed satisfactorily, please contact ourU.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
15. California Consumer Privacy Act
In very limited cases, we may collectinformation about certain California residents subject to the CaliforniaConsumer Privacy Act (“CCPA”). However, this CCPA notice does not applyto the following information:
Any information provided in connectionwith seeking a financial product or service (including any data subject to theGramm-Leach Bliley Act (“GLBA”) or the California Financial Information PrivacyAct (“CalFIPA”)).
Information about individuals who are not California residents.
Information about our own employees, contractors, agents, and jobapplicants. Such information is subject to a separate privacy notice thatwe will make available to the applicable individuals.
Information we collect from individuals with whom we engage in solelybusiness-to-business communications and transactions, including due diligencetransactions, such as information about the employees of our business clients.
We collect limited personal information subject to the CCPA from databrokers. We use and disclose such information for our marketing andrelated operational purposes. We do not “sell” personal information as definedunder the CCPA and we do not knowingly sell the personal information of minorsunder 16 years of age. The following chart contains more detail about thecategories of personal information we collect and disclose.
16.Your Rights
Subject to legal limitations andexceptions, California residents may exercise the following rights by emailing us at hello@ksahai.com with a subject line of “Rightto Know.”
You have the right to requestinformation about the categories of personal information we have collectedabout you, the categories of sources from which we collected the personalinformation, the purposes for collecting the personal information, and the categoriesof third parties with whom we have shared your personal information(“Categories Report”). You may also request information about thespecific pieces of personal information we have collected about you (“SpecificPieces Report”).
Right to Delete. You have the right to request that we delete personalinformation that we have collected from you.
Do Not Sell: We do not “sell” personal information as defined under the CCPA.
Non-Discrimination: In accordance with applicable law, we will not discriminateagainst you for exercising these rights.
Verification: In order to exercise your rights, wemay need to obtain information to locate you in our records, verify that youare a California resident, and/or verify your identity depending on the natureof the request. If you are submitting a request on behalf of a household,we may need to verify each member of the household in the manner set forth inthis section.
Please be aware there might becircumstances where we will not honor your request, as permitted under theCCPA. For example, if we are not able to verify your identity and that you area California resident, we may not honor your access or deletion request.
Additionally, we may not delete yourpersonal information if an exception under the CCPA applies to your deletionrequest. When making a request, you will be asked to provide your zip code,first and last name, date of birth, and phone number (optional) and indicatehow you would like to be contacted, which may require you to provide contactinformation. You will also be required to attest that you are entitled to makethe request.
We may request alternativeinformation under certain circumstances and will inform you if such informationis needed in the verification process.
Authorized Agents: Authorized agents may exercise rightson behalf of consumers, but we reserve the right to also verify the consumerdirectly as described above. Authorized agents must contact us by mail at theaddress provided above and include documentation demonstrating the agent has theauthority to exercise rights on the consumer’s behalf. At a minimum, wewill require evidence of the agent’s identity, proof of registration with theCalifornia Secretary of State, and at least one of the following evidencingproof of your legal authority to act on behalf of the individual consumer:
Written authorization signed bythe Consumer; or
Certified copy of a Power of Attorney granted under Probate Code.
In the absence of any of the general conditions detailed above, we are entitledto reject any request submitted through an agent.
Timing: We will respond to Requests to Deleteand Requests to Know within 45 calendar days, unless we need more time (inwhich case we will notify you) and may take up to 90 calendar days in total torespond to your request.
California Shine the Light: We do not share personal informationsubject to California Civil Code § 1798.83 (the “Shine the Light law”) withthird parties for their direct marketing purpose.