spr1tz, inc. (“company”, “our”, “we” or “us”) provides its customers and potential customers (“you”, “user”, “your”) with access to its website located at spr1tz.com and our mobile application (together, the “website”), through which we provide personally tailored information and offer to purchase our perfumes, cosmetics, and other complementary products (“products”). this privacy policy (the “privacy policy”) is intended to describe our practices regarding the information we may collect from you when you use and interact with the website and when you order and consume our products, including the type of personal information collected, the purpose and manners in which we may use such information, and the choices and rights available to you.
your consent

by accessing the website, you agree to the terms and conditions set forth in this privacy policy, including to the collection and processing of your personal information (as defined below) as further set forth under this policy. if you disagree to any term provided herein, you may not access or use the website.
please note. you are not obligated by law to provide us with any personal information. you hereby acknowledge and agree that you are providing us with personal information at your own free will. you hereby agree that we may collect and use such personal information pursuant to this privacy policy and any applicable laws and regulations.

what information do we collect from our users?
non-personal information: un-identified and non-identifiable information pertaining to users, which may be made available to us, or collected automatically via their use of the website. such non-personal information does not enable us to identify the person from whom it was collected, and mainly consists of technical and aggregated usage information which is not linked to an identifiable individual, such as the operation system and browser, smart-phone version, screen resolution, duration of usage of the website, user's 'click-stream' activity, keyboard language, etc.
personal information: individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of private or sensitive nature. identification of an individual also includes the association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc. we collect personal information from you when you use or interact with our website and/or make inquiries regarding our products, order and/or consume them including:
account information. information such as your name, address, email address, date of birth and phone number provided in connection with your request to sign up for your spr1tz user account and receive updates regarding our newsletters and special offers.
financial information. information such as credit card or any other payment method made available by spr1tz, used by you to order our products, which is processed by our third-party services providers as further detailed below and to which we generally have no access.
impression information. information about your impressions of, and reactions to, advertisements that appear on the website that we receive from devices (including mobile devices) and software you use when you access our website. this information may include the following: device id or unique identifier, device type, id for advertising, operating system, information regarding your clicks, views and engagement with our advertisement and services, information concerning your traffic to and from the website and your referral url.
we do not collect any personal information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of this privacy policy.

how do we collect information on our users?

we collect information through your use of the website. in other words, we are aware of your interaction and usage of the website and may gather, collect and record the information relating to such interaction and usage, including by using “cookies” and other tracking technologies, as further detailed below.
we collect information which you provide us actively. for example, we collect personal information which you actively and voluntarily provide when you request to receive our newsletters, when you sign up for your user account, or when you contact us.
candidates information. we may publish open positions in the company via the website, and/or our linkdin, facebook or other media pages. in connection with this opportunity, we collect information that is provided to us by the job candidates (“candidates”), when they apply to any of the open positions published by us, by e-mail, via linkedin or otherwise, and information we collect or generate following their application.


why do we collect information on our users?

we use the personal information collected by us for the following purposes and uses:
to provide and improve our website and its various functions and features and to manage our business.
to be able to deliver and enhance the website and provide users with technical assistance and support.
to communicate with you including by sending you updates, notices, notifications, articles, recommendations and additional information related to the website and our products.
to verify your eligibility in connection with promotions and referral programs we may hold from time to time.
to conduct surveys regarding our products or regarding the experience of users in our website.
to display or send to you marketing and advertising material and general and personalized content and advertisement via the website, email, telephone, mobile devices, and to track and analyze the effectiveness and relevance of such activity.
to create cumulative, aggregated statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our website and provide related services.
to prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities, including any breaches of this privacy policy or of our terms of service.
to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.

lawful grounds for collecting information on our users

we collect and process your information for the purposes described in this policy, based at least on one of the following legal grounds:
with your consent: we ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. for example, we ask for your consent to send you our newsletters. per to applicable law, we also receive your informed consent to the collection and processing of your personal information through your active acceptance of this privacy policy.

legitimate interests: we process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. this means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this privacy policy; in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our terms of service.

where do we store user’s personal information?

information regarding the users will be maintained, processed and stored by us and our authorized affiliates and service providers in the united states and eu in secured cloud storage, provided by our third party service provider.
while the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your personal information on our behalf are each committed to keep it protected and secured, pursuant to this privacy policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
you hereby accept the place of storage and the transfer of information as described above.
who do we share user information with and why?

we may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:
third party services: we partner with a number of selected service providers, whose services and solutions complement, facilitate and enhance ours. these include hosting, merchant processing, shipping, postal and delivery services, website functionality, e-mail and text message distribution and monitoring services, advertising, affiliation and related analytics services, customer support, as well as our business, legal and financial advisors, and others (collectively, "third party service providers"). such third party service providers may receive or otherwise have access to our users’ personal information, depending on each of their particular roles and purposes in facilitating and enhancing our website and related services and may only use it for such purposes.
governmental/law enforcement agencies and legal requests or duties: we may disclose or otherwise allow access to personal information pursuant to any applicable law, regulation, legal process, subpoena or governmental request, whenever we believe in good faith that it is legally bound to share such information.
to enforce this privacy policy and the terms of service including investigation of potential violations thereof.
to detect, prevent, or otherwise address fraud, security or technical issues.
to protect the rights, property, or personal safety of us, our users or the general public.
when we undergo any change in control, including by means of merger, acquisition or purchase of all or substantially all of our assets.
pursuant to your explicit approval prior to the disclosure.
for avoidance of doubt, we may share anonymized or de-identified information with any other third party, at our sole discretion.
using cookies and other tracking technologies

we may use certain industry-wide monitoring and tracking technologies such as "cookies" or “pixel tags” (or similar technologies), which store certain information on your computer ("local storage") and which will allow us to enable automatic activation of certain features, and make your service experience much more convenient and effortless. the local storage is created per session and may be deleted by you or otherwise your browser may be configured by you to not accept any such local storage items. these technologies are used in order to maintain, provide and improve our website on an ongoing basis, and in order to provide a better experience to our users. for example, these technologies enable us to: (i) keep track of our users’ preferences and authenticated sessions, (ii) secure our website by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our website, and (iv) create and monitor analytics.

such tracking technologies may include pixel tags (also commonly known as web beacons), transparent images, iframes, cookies, or java script placed on our website or our advertisements and emails, that is used to understand how you interact with the website, with such advertisements and emails. to learn more about our use of cookies and other tracking technologies, please see our cookie policy [link]. it is important to note that some of these tracking technologies are provided to us by our third party services providers who collect and process personal information in the scope of the services that they provide us.
please note – in certain cases such third party service providers may collect and process personal information, in a scope which is broader than the scope of collection and processing required for the purposes set forth above. this means that sometimes these third party service providers have access to more of your personal information than we do. in such cases all such excess collection and processing is performed pursuant to and under a direct contractual relationship you have with such service providers, as detailed below and any rights you may have with respect to such information, collected by such third party service providers, shall be governed by such contractual relationship. otherwise, the terms of this privacy policy shall fully apply.

we may also use google adwords, facebook and other social media platform’s functionality of re-marketing tracking cookies and pixel-based retargeting (the “social ad platforms”). this means that if you provide your consent to such social ad platforms to be provided with personalized commercial offers, you may be served with ads based on your use of the website, outside of the website and across the internet. in such event the social ad platforms, will place cookies or pixels on your web browser and use such technologies to serve you ads based on past visits to our website.
please visit the social ad platforms’ individual privacy policy to find out how they use such information:
google adwords: https://policies.google.com/technologies/ads
google analytics: https://policies.google.com/technologies/ads
facebook\ig: https://www.facebook.com/about/privacy/
tiktok: https://www.tiktok.com/legal/privacy-policy
snapchat: https://www.snap.com/en-us/privacy/privacy-policy/

learn more about your choices and how to opt-out of tracking technologies:
in order to delete or block any tracking technologies, please refer to the “help” area on your internet browser for further instructions, or you may also opt out of third party tracking technologies by following the instructions provided by each third party service provider in its privacy policy listed above or visiting www.youronlinechoices.eu. please note however that deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our website, or may otherwise adversely affect your user experience. please note however that we do not respond to the ‘do not track’ setting on your browser.
direct marketing

you hereby agree that we may use your contact details provided when requesting to contact the website or otherwise provided to us pursuant to your consent, for the purpose of informing you regarding our products which may interest you, and to send to you other marketing material including newsletters, surveys and recommendations regarding our products and related services. you may withdraw your consent via sending us written notice by email to the following address: ok@spr1tz.com or by pressing the “unsubscribe” button in the email.
please note that the company may also contact you with important information regarding our website. for example, we may notify you (through any of the means available to us) of changes or updates to our website’s terms, service maintenance, etc. you will not be able to opt-out of receive such service messages.
minors

our website is not structured to attract children under the age of 13. therefore, we do not knowingly collect personal information from minors under the age of 13 and do not wish to do so. we reserve the right to request proof of age at any stage so that we can verify that minors under the age of 13 are not using the website. if you are under the age of 18, please have your parent or legal guardian read this with you. if you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13, and that you have read and acknowledged our privacy policy and agree to the use by your child of the website and registration for an account.
information security

we employ industry standard procedures and policies to ensure the safety of its users’ personal information, reduce the risks stemming from loss of information and prevent unauthorized use of any such information. however, no measure can provide absolute information security.
data retention

we retain the personal information we collect only for as long as needed in order to provide you with our services and to comply with applicable laws and regulations. we then either delete from our systems or anonymize it without further notice to you.
if you withdraw your consent to us processing your personal information, we will delete your personal information from our systems (except to the extent such data is in whole or in part required to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates).
your rights

if applicable to you under your country’s jurisdiction, you may have certain rights in connection with your personal information and how we handle it. you can exercise your rights at any time by contacting us via any of the methods set out in below. those rights may include, but are not limited to, the following:
right of access. you may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. we reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. where we are not able to provide you with information that you have asked for, we will endeavor to tell you why. we will try to respond to any request for a right of access as quickly as practically possible, and always within one (1) month.
right to correct personal data. we endeavor to keep the information that we hold about you accurate and up to date. should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.
data deletion. in some circumstances and under certain laws and regulations, you may have a right to request that some portions of the personal information that we hold about you be deleted or otherwise anonymized/de-identified.
data portability. in some circumstances and under certain laws and regulations, you may have the right to request that data which you have provided to us is provided to you, so you can transfer or port it elsewhere.
california privacy rights: residents of california please see our california privacy rights statement [link to cppa statement] for information about california privacy rights, and other required disclosures, if any.
job candidates

we welcome all qualified candidates to apply to any of the open positions posted at our website or any other platform, by sending us their contact details and cv (“candidates information”). since privacy and discreetness are very important to our candidates, we are committed to keep candidates’ information private and use it solely for our internal recruitment purposes (including for identifying candidates, evaluating their applications, making hiring and employment decisions, and contacting candidates by phone or in writing).
please note that the company may retain candidates information submitted to it even after the applied position has been filled or closed. this is done so we could re-consider candidates for other positions and opportunities at the company; so we could use their candidates information as reference for future applications submitted by them; and in case the candidate is hired, for additional employment and business purposes related to their work.
if you previously submitted your candidates information to the company, and now wish to access it, update it or have it deleted from our systems, please contact us at ok@spr1tz.com
updates to this privacy policy

we reserve the right to change this policy at any time, so please re-visit this page frequently. we will notify you regarding substantial changes of this privacy policy by changing the link to the privacy policy in the service and/or by sending you an e-mail regarding such changes to the e-mail address that you provided during registration. such substantial changes will take effect seven (7) days after such notice was provided on our website or sent by email. otherwise, all other changes to this privacy policy are effective as of the stated “last revised” date and your continued use of the website after the last revised date will constitute acceptance of, and agreement to be bound by, those changes.
general information

this privacy policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the state of israel, without respect to its criminal law principles. any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in tel aviv, israel.
how to contact us?

Warnings: for external use only. Flammable. keep away from fire or flame. when using this product do not use in or near the eyes.

if you wish to exercise any of the aforementioned rights, or receive more information concerning this privacy policy, you are welcome to send us an email at: ok@spr1tz.com