SJS Group LLC (“Customcuff”, “we,” “,”), is registered under the laws of the State of Nevada, having its registered address at 10409 Pacific Palisades Ave, Las Vegas, NV 89144, USA, respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using the Site, available at https://www.customcuff.co/ (“the Site”), or explicitly agreeing to this Privacy Policy, when prompted on the Site, you are accepting and consenting to the practices described in this Privacy Policy.

Compliance

Online Brands LLC qualifies as a Data Controller under the Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 (General Data Protection Regulation (the “GDPR”)).  As such, we aim to comply with all legal obligations which the GDPR implies on Data Controllers.

Personal information we collect

By entering your phone number at checkout you consent to receive automated marketing by text message through an automatic telephone dialing system. Consent is not a condition to purchase. Message and Data rate apply. 

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, Paypal, and Apple Pay), email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

How do we use your personal information?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

- Communicate with you;

- Screen our orders for potential risk or fraud; and

- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

 

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

 

Sharing your Personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

 

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful requests for information we receive, or to otherwise protect our rights.

TEXT MARKETING TERMS AND CONDITIONS:

We are using a text messaging platform, which is subject to the following terms and conditions. By opting-in for our text marketing and notifications in, you agree to these terms and conditions.

By entering your phone number in the checkout and initialising a purchase, subscribing via our subscription form, or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. You acknowledge that consent is not a condition for any purchase.

Your phone number, name, and purchase information will be shared with our SMS platform "SMSBump Inc, an European Union company with an office at Sofia, Bulgaria, EU. This data will be used for sending you targeted marketing messages and notifications. Upon sending the text messages, your phone number will be passed to a text message operator to fulfill their delivery.

If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you within any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted for as a reasonable means of opting out. Message and data rates may apply.

For any questions please text "HELP" to the number you received the messages from. You can also contact us for more information. If you wish to opt out please follow the procedures above.

 

Behavioral advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

- Facebook: https://www.facebook.com/settings/?tab=ads

- Google: https://www.google.com/settings/ads/anonymous

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

 

Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

 

Do not track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

 

Special Considerations for Residents of the State of California, USA

Access to Specific Information and Data Portability Rights

You have the right to request that Online Brands LLC disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (See Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

    • The categories of Personal Information we collected about you.
    • The categories of sources for the Personal Information we collected about you.
    • Our business or commercial purpose for collecting or selling that Personal Information.
    • The categories of third parties with whom we share that Personal Information.
    • The specific pieces of Personal Information we collected about you (also called a data portability request).
    • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
      • sales, identifying the Personal Information categories that each category of recipient purchased; and
      • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right request that Online Brands LLC deletes an of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (See Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your Personal Information from our record, unless an exception applies.

    • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

    • Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request to verify the requestor’s identity or authority to make the request.o make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us we will deliver our written response to that account, if you do not have an account with us, we will deliver our written response by mail or electronically, at your option:

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Do Not Sell My Personal Information

CustomCuff will not sell your personal information. California law requires that we maintain a separate webpage that allows you to opt out of the sale of your personal information, which can be accessed by clicking the link below:

https://www.customcuff.co/pages/ccpa-form

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we wiil not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Site. You are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Special Consideration for EU Citizens

 

Your rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

  

Grounds for Data Processing

 

We only collect and use personal data where we have lawful grounds to do so. These include processing User personal data to provide the Services, for purposes of our legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

 

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

To provide the goods

In order to provide the goods, we must collect and use certain personal data. This includes:

  • user profile data, which we use to establish and maintain our subscriber database; verify user identity for the purposes of shipping the goods and to communicate with users of the Site;
  • Usage data, which is necessary to maintain, optimize, and enhance the Site; and
  • Information relating to customer support.

For purposes of our legitimate interests or of other parties

This includes using personal data to maintain and enhance our users’ safety and security. This also includes purposes such as combating fraud or detecting cyberattacks or unlawful attempts to extract personal information, which includes payment information, from the Site.

With consent

We may collect and use personal data based on the user’s consent. For example, we may collect personal data such as your email address when you subscribe to our newsletter or when you join our ambassador program

A user who has provided consent to a collection or use of their personal data can revoke it at any time, however, by revoking such consent your access to the Services may be terminated.

 

Data retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

 

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

 

Minors

The Site is not intended for individuals under the age of 13. You must be at least 13 years old or older to gain access to our website or our services. This website is not intended for those who are under 13 years old. We do not knowingly collect any information from anyone who is under 13 years of age and do so in compliance with the Children’s Online Privacy Protection Act. All of our products and services are directed solely to individuals who are at least 13 years old.

If we learn we have collected Personal Data from a child under 13, we will delete that information, unless we are legally obligated to retain such data. If you have any reason to believe we may have unknowingly collected data from a minor under the age of 13 please immediately send us an email at support@customcuff.co.

 

Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by using the details provided below:

Address: 10409 Pacific Palisades Ave Las Vegas, NV 89144, USA

Email: support@customcuff.co