TULA COOKIE POLICY

Last Updated: July 28, 2023

California Privacy Policy
European Privacy Policy

TULA Life, Inc. and its subsidiaries and affiliates (“TULA,” “we,” or “us”) respect your privacy. TULA owns, licenses, and operates certain websites, applications, and platforms (each a “Site”) that are primarily designed to sell beauty products, goods, and services (collectively, the “Services”). This Cookie Policy explains our use of “cookies” and other tracking technologies, including, but not limited to, web beacons, pixels, clear gifs, and other similar technologies (collectively, “Cookies and Other Tracking Technologies”) that are employed on our Sites

PLEASE READ THIS COOKIE POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SITE, YOU ARE CONSENTING TO THE TERMS OF THIS COOKIE POLICY AND TULA’S TERMS & CONDITIONS AND PRIVACY POLICY.

To prevent TULA FROM using certain Cookies and Other Online Tracking Technologies, YOU CAN CHANGE YOUR BROWSER SETTINGS IN ACCORDANCE WITH THE INSTRUCTIONS BELOW OR BY USING OUR COOKIE management TOOL AVAILABLE ON THE FOOTER OF OUR SITE.

What are Cookies and Other Online Tracking Technologies?

Cookies are small files that are downloaded to your device when you visit a website. The cookie then sends information back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Other types of tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Sites. Accordingly, Cookies and Other Tracking Technologies allow our Sites to recognize your device and track your activities and preferences, thereby allowing you to navigate between pages efficiently and to generally improve the user experience. The information provided below about cookies also applies to the other tracking technologies referenced above (i.e., web beacons, pixels, clear gifs, and other similar technologies). You can find more information about cookies at www.allaboutcookies.org.

Cookies are often categorized by function. We use four types of cookies by function on our Sites:

Cookies can also be categorized by how long they remain on your device and by who puts the cookie there. There are four broad categories of duration and placement cookies that we use on the Sites:

How do our Sites use Cookies and Other Tracking Technologies?

We use Cookies and Other Tracking Technologies to identify you and your interests, to remember your preferences, to facilitate our marketing, and to track your use of our Sites. We also use Cookies and Other Tracking Technologies to control access to certain content on our Sites, to protect the integrity and security of the Sites, to process any requests that you make of us, and as otherwise set forth herein and in TULA’s Privacy Policy. To administer our Sites and for research purposes, TULA may, from time to time, contract with third-party service providers to track and analyze statistical usage and volume information from our Sites. These third-party service providers use persistent cookies to help us improve the user experience, manage the content on our Sites, and analyze how users navigate and utilize the Sites. The Cookies and Other Tracking Technologies we use on the Sites are as follows:

Google Ads and Analytics

We use “Google Analytics” to collect information about the use of our Sites. Google Analytics collects information such as how often users visit the Sites, what pages they visit when they do so, and what other sites they used prior to coming to the Sites. We use the information we get from Google Analytics only to improve our Sites. Google Analytics collects only the IP address assigned to your device on the date you visit our Sites rather than your name or other personal information. We do not combine the information collected through the use of Google Analytics with other personal information. Although Google Analytics plants a cookie on your web browser to identify you as a unique user the next time you visit our Sites, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Sites by disabling cookies on your browser. Along with cookies, Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) to compile aggregated statistics to analyze how our Sites are used. You can find additional information on how to install a browser add-on to prevent your data from being used by Google Analytics at tools.google.com/dlpage/gaoptout.

Reddit

We use the Reddit Ads Pixel, which is owned and operated by Reddit, Inc. This Pixel allows us to display and measure interest-based advertising on the social network Reddit, and assists with our remarketing and conversion-tracking programs. For more information on data processing by Reddit on your choices, please visit https://www.reddit.com/policies/privacy-policy and https://www.reddit.com/personalization/.

Service Providers

We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions (including rebates and returns), tracking and responding to consumer questions or complaints, and performing analyses to improve the quality of our Services.

Pinterest

We use Pinterest “tags” which means your information may be shared with Pinterest for online behavioral advertising. You can opt out of online behavioral advertising through their Pinterest personalization settings.

How do we use and share information?

The information and data we gather from our Cookies and Other Tracking Technologies will be used, retained, and shared in accordance with this Cookie Policy and TULA’s Privacy Policy.

Rejecting Cookies and your options

To prevent TULA FROM using certain Cookies and Other Online Tracking Technologies, YOU CAN CHANGE YOUR BROWSER SETTINGS IN ACCORDANCE WITH THE INSTRUCTIONS BELOW OR BY USING OUR COOKIE MANAGEMENT TOOL AVAILABLE ON THE FOOTER OF OUR SITE.

You can stop cookies from being downloaded on your device by selecting the appropriate settings on your browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to access or take full advantage of the Sites. Most browsers allow users to use a “private mode” by which cookies are deleted after your website visit. Please read the help section of your browser to learn more about how to activate the “private mode.” You could still visit our Sites if your browser is in “private mode”; however, the user experience may not be optimal, and some features may not work.

• Click here to learn more about the “Private Browsing” setting and managing cookie settings in Firefox.
• Click here to learn more about “Incognito” and managing cookie settings in Chrome.
• Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer.
• Click here to learn more about “Private Browsing” and managing cookie settings in Safari.

If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Sites from placing further cookies on your device unless and until you adjust your browser setting as described above.

More Information

You can find more information about cookies, behavioral advertising, and online privacy at www.allaboutcookies.org. For some of our service providers that participate in the Digital Advertising Alliance (DAA), you can exercise your choice to opt out of interest-based advertising at http://optout.aboutads.info. You may also opt out of receiving interest-based ads from many third-party websites and applications through the Network Advertising Initiative’s (NAI) Opt Out Tool, which is available at http://www.networkadvertising.org/choices. Certain types of mobile devices have an identifier that provides organizations with the ability to serve targeted advertising directly to a specific mobile device, and you may (depending on the device) be able to limit advertising, reset the advertising identifier, and turn off your device’s tracking features within your device’s settings. For more information see http://youradchoices.com/appchoices.

Canada Privacy Rights

Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”) will be collected, stored, used and/or processed by TULA in accordance with this Privacy Policy and TULA’s obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to these Canadian laws, you have a right to request access to your personal information and to request that inaccurate personal information be corrected. If you have submitted personal information to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal information, we will require that you verify our request via email, and we will request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee to access your personal information, provided that we advise you of any such fee in advance. Your right to access personal information is not absolute, and we may not be able to allow you to access certain personal information in certain circumstances (e.g., if the information contains personal information of other persons or it is subject to legal privilege). In the event that we cannot provide you with access to, or the ability to correct, your personal information, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or email), please contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

European Union (EU), Switzerland, and United Kingdom (UK)

Data Protection Rights

If you are located in the EU, Switzerland, or the UK, you have the following data protection rights:

• Right to Know: The right to know about what personal information TULA collects and processes about you, including the types and categories of personal information we collect and process, the sources of such personal information, our retention criteria, with whom we share your personal information, cross-border data transfers, and how to file complaints and inquiries. The personal information that we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information, among other issues, are set forth in this Cookie Policy and in our Privacy Policy.
• Access Rights. You may ask us whether we process any of your personal information and, if so, receive access to such personal information. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned as well as any other information necessary for you to exercise the essence of this right.
• Rectification. You have the right to have your personal information corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, update any incomplete personal information, which may include the provision of a supplementary statement.
• Erasure. You have the right to have your personal information erased, which means the deletion of your personal information by us and, where possible, any other controller to whom your data has previously been disclosed. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your personal information is no longer necessary in relation to the initial purposes for which it was processed, your personal information was processed unlawfully).
• Restriction of Processing. You have the right to obtain the restriction of the processing of your personal information, which means that we suspend the processing of your personal information for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal information is contested, but we need time to verify the inaccuracy (if any) of your personal information.
• Data Portability. You have the right to request us to provide you with your personal information in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible.
• Right to Object. You have the right to object to the processing of your personal information, which means you may request us to no longer process your personal information. This only applies in case the “legitimate interests” ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”). However, at any time (and free of charge) you can object to having your personal information processed for direct marketing purposes.
• Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your personal information. However, this will not impact our legal basis to process such personal information prior to the withdrawal of your consent.
• Automated Decision Making. TULA does not engage in any activity that subjects our customers, Site users, survey participants, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significantly results, impacting them.

Legal Basis for Processing. We process your personal information in accordance with the legal bases set forth in law. For example, our processing of personal information (as described herein) is justified based on the following legal grounds:

• Consent: You may consent to our use of non-essential cookies.
• Legitimate Interests. We process essential cookies to host, maintain, and secure our Site.

Complaints

In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority. For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.

Targeted Advertising Opt-Out Rights / California “Do Not Share” Rights

Pursuant to certain U.S. state law (e.g., Colorado, Connecticut, Utah, Virginia) you may have the right to opt out of having your personal information used for targeted advertising purposes. TULA uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.

California Opt-Out Rights / Do Not Share My Personal Information

Pursuant to the California Consumer Privacy Act of 2018, as amended (CCPA), as amended by the California Privacy Rights Act of 2020, California residents have the right to opt out of the “sharing” of your personal information. TULA uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.

Cookie Policy Updates

We reserve the right to amend this Cookie Policy at any time. We will notify you if this Cookie Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Cookie Policy to determine whether any amendments have been made hereto. Your use of the Sites, and continued use of the Sites after any amendments are made to this Cookie Policy, signifies your consent to this Cookie Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Cookie Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review this Cookie Policy to determine whether any amendments have been made hereto.

Contact Us

To prevent TULA FROM using certain Cookies and Other Online Tracking Technologies, YOU CAN CHANGE YOUR BROWSER SETTINGS IN ACCORDANCE WITH THE INSTRUCTIONS BELOW OR BY USING OUR COOKIE management TOOL AVAILABLE ON THE FOOTER OF OUR SITE.

If you have questions regarding this Cookie Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact our Privacy Office at the following:

privacy@tula.com
TULA Life, Inc
ATTN: DATA PRIVACY
228 Park Avenue South
PMB 23606
New York, New York 10003-1502.