Effective Date: October 31, 2022

Last Updated on: June 6, 2023

This Privacy Policy for California Residents supplements the information contained in Pique’s General Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We collect 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 consumer, household, or device (“personal information”). Personal information does not include:

·         Publicly available information from government records.

·         Deidentified or aggregated consumer information.

In particular, we collect the following categories of personal information from consumers within the last twelve (12) months:

 

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES, we collect: A real name, alias, postal address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES, we collect: A name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation.	NO.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES, we collect: Records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES, we collect: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.	Physical location or movements.	NO.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO.
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO.
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO.

 

We obtain the categories of personal information listed above from the following categories of sources:

·         Directly from you. For example, from forms you complete or products and services you purchase.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

·         To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

·         To provide, support, personalize, and develop our Website, products, and services.

·         To create, maintain, customize, and secure your account with us.

·         To process your requests, purchases, transactions, and payments and prevent transactional fraud.

·         To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

·         To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

·         For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

·         To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·         As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for business purposes. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Pique has disclosed personal information for business purposes.

We do not sell personal information.

 

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	Pique may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing payments, and displaying Uber advertising on third party apps or websites.	None.
B: California Customer Records personal information categories.	Pique may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing payments, and displaying Uber advertising on third party apps or websites.	None.
C: Protected classification characteristics under California or federal law.	None.	None.
D: Commercial information.	Pique may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing payments, and displaying Uber advertising on third party apps or websites.	None.
E: Biometric information.	None.	None.
F: Internet or other similar network activity.	Pique may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing payments, and displaying Uber advertising on third party apps or websites.	None.
G: Geolocation data.	None.	None.
H: Sensory data.	None.	None.
I: Professional or employment-related information.	None.	None.
J: Non-public education information.	None.	None.
K: Inferences drawn from other personal information.	None.	None.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, 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.

·         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.

·         The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1.       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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2.       Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.       Debug products to identify and repair errors that impair existing intended functionality.

4.       Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.       Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6.       Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

7.       Comply with a legal obligation.

8.       Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

·         Emailing us at care@piquelife.com

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child.

You may only submit a request to know twice within a 12-month period. Your request to know or delete 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.

You do not need to create an account with us to submit a request to know or delete.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact care@piquelife.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), 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 our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

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.

Non-Discrimination

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

 

 

Pique Online GDPR Privacy Notice

This Notice is for people who are located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”) and supplements our general Privacy Notice.  Our processing of personal data of people who are in the EEA is governed by the European Union’s General Data Protection Regulation (the “GDPR”).  Our processing of personal data of people who are in the UK is subject to the Data Protection Act 2018, which incorporates the GDPR as the UK GDPR.  This Notice refers to the GDPR and the UK GDPR collectively as the “GDPR”.  As of the most recent revision date of this Notice, we anticipate that Switzerland’s updated data protection law will go into effect during the second half of 2022.   For the sake of administrative efficiency, this Notice applies to people in Switzerland as well as people in the EEA or UK.  However, this does not limit any additional right that people in Switzerland may have.

The GDPR requires us to provide certain information to you about your personal data, which we refer to in this notice as your personal information.

Data Controller

The data controller for this website is the Pique, Inc. Our contact information is as follows: care@piquelife.com.

Purposes of the processing

Our General Privacy Policy describes the personal information that we collect, use, share, or otherwise process personal information – and the purposes for that processing–in the course of operating our business.

Lawful basis for the processing

Generally, we process personal information provided by visitors through our website or other interactions with us on the basis our legitimate interests in conducting our business as a law firm.  Where we ask for your consent, we process personal information on the basis of that consent.

We may also process personal information on other bases permitted by the GDPR and applicable laws, such as when the processing is necessary for us to comply with our legal obligations.

Categories of personal information

The categories of personal information that we process are described in our General Privacy Policy.

Recipients of your personal information

We use various service providers to manage our website and provide services such as processing payment or managing e-mail communications.  Our service providers change from time to time.  Note that our service providers have entered into contracts with us that restrict what they can do with your personal information. If you would like specific information about our service providers who have received your information, please contact us at CONTACT and we will provide that information to you.

 

 

Information regarding the transfers of personal data outside of the European Economic Area (EEA)

Pique’s main administrative offices are based in the USA and that’s where we process personal information collected through our website.  When you provide personal information to us, we request your consent to transfer that personal information to the USA.  The USA does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the USA provide adequate protection for personal information.   Although the laws of the USA do not provide legal protection that is equivalent to EU data protection laws, we safeguard your personal information by treating it in accordance with this GDPR Privacy Notice.  We take appropriate steps to protect your privacy and implement reasonable security measures to protect your personal information in storage. We use secure transmission methods to collect personal data through our website.  We also enter into contracts with our data processors that require them to treat personal information in a manner that is consistent with this Notice.

 

Retention period for personal information

How long we retain personal information varies according to the type of information in question and the purpose for which it is used.  We delete personal information within a reasonable period after we no longer need to use it for the purpose for which it was collected (or for any subsequent purpose that is compatible with the original purpose). This does not affect your right to request that we delete your personal data before the end of its retention period.  We may archive personal data for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.

 

Your data subject access rights

You have the right to request access to your personal data, to have your personal data corrected, restricted or deleted, to withdraw any consent that you have given to the processing of your personal data (without affecting the lawfulness of the processing prior to your withdrawal of consent) and to object to our processing of your personal data.  You also have the right of data portability in certain circumstances, which means that you can request that we provide you (or a third party you designate) with a transferable copy of personal information that you have provided to us.   Your rights may be subject to various limitations under the GDPR.  If you wish to exercise any of these rights, or if you have any concerns about our processing of your personal data, please contact us at care@piquelife.com.

 

The right to lodge a complaint with a supervisory authority

You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority.    The EU Commission has a list here:   http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.  The data protection authority for the United Kingdom is the Information Commissioner’s Office (www.ico.org.uk).  The federal data protection authority for Switzerland is the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html.

 

Absence of statutory or contractual requirement or other obligation to provide any personal data

Users of our website are under no statutory or contractual requirement or other obligation to provide personal information to us, but it will not be possible to receive communications from us without doing so.

Changes to Our Privacy Policy

This Notice is for people who are located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”) and supplements our general Privacy Notice.  Our processing of personal data of people who are in the EEA is governed by the European Union’s General Data Protection Regulation (the “GDPR”).  Our processing of personal data of people who are in the UK is subject to the Data Protection Act 2018, which incorporates the GDPR as the UK GDPR.  This Notice refers to the GDPR and the UK GDPR collectively as the “GDPR”.  As of the most recent revision date of this Notice, we anticipate that Switzerland’s updated data protection law will go into effect during the second half of 2022.   For the sake of administrative efficiency, this Notice applies to people in Switzerland as well as people in the EEA or UK.  However, this does not limit any additional right that people in Switzerland may have..

 

The GDPR requires us to provide certain information to you about your personal data, which we refer to in this notice as your personal information.

Contact Information

If you have any questions or comments about this notice, the ways in which Pique collects and uses your information described here and in the General Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: care@piquelife.com

Postal Address:

Pique, Inc.

Attn: Privacy Policy Team

30745 Pacific Coast Hwy

Suite 21, PMB2060

Malibu CA 90265

If you need to access this Policy in an alternative format due to having a disability, please contact care@piquelife.com.