Privacy Policy
PRIVACY NOTICE/YOUR PRIVACY RIGHTS
Effective Date: May 20, 2025
LAST UPDATED: May 13, 2025
Table of Contents
2. Types of Personal Data We Collect
4. How We Disclose Personal Data
6. Data Security and Data Retention
10. Supplemental U.S. States Privacy Disclosures
11. Supplemental Information for the EEA, Switzerland and the UK
Peach and Lily, Inc., together with its subsidiaries and affiliates (collectively, “Company,” “us,” “we,” or “our”) is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events and purchases; and other online and offline interactions.
This Privacy Notice applies to information we collect about individual consumers, such as general website visitors (“Individuals”) as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions (“Business Contacts”). However, this Privacy Notice does not apply to information about our current/former employees, applicants, and other individuals who interact with us for employment-related purposes. This Privacy Notice also does not apply to data that we handle on behalf of and under the instructions of our business customers.
Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.
Changes: We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates. If required by law, we will obtain your consent or contact you directly if there are material changes to this Privacy Notice.
We collect Personal Data about you from the following sources:
- Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; interact with us in person; sign up for offers or newsletters; communicate with us; place or customize orders; or sign up for an account or other services.
- Data collected automatically and through Cookies. We may automatically collect information or inferences about you; such as through cookies, pixels, tags, scripts, and other tracking technologies (collectively, “Cookies”), when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information. For more information about Cookies, please see Section 5.
- From third parties. We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us.
- From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites.
We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.
2. Types of Personal Data We Collect
We may collect the following types of Personal Data about you. Except as otherwise specified, we may collect this Personal Data from both Individuals and Business Contacts.
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Identifiers such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
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Records about you, such as signatures; physical characteristics or a description of you; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties, such as reviews and comments.
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Demographic information, such as age (including birthdates) and gender.
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Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
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Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties. For more information about Cookies, please see Section 5.
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Non-precise geolocation data, such as your location as derived from your IP address.
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Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
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Professional or employment-related information (for Business Contacts), such as job title; organization; professional licenses, credentials, or affiliations; and other professional information.
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Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
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Sensitive Personal Data, including the following: health information about your skin if you choose to provide it in our diagnostic quiz.
We may use Personal Data for the following purposes:
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To provide you or your company products and services, such as making our Digital Properties and other products and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request, including facilitating our Peach Perks rewards program and providing you with personalized skincare recommendations; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
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For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
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For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; developing and improving algorithms, artificial intelligence or machine learning tools and models; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
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For legal, safety, or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
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In connection with a corporate transaction, such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
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For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe from our email marketing via the link in the email, by responding “STOP” to the text message, or by contacting us using the information in Section 9 (Contact Information) below.
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
4. How We Disclose Personal Data
We may disclose Personal Data to third parties, including the categories of recipients described below:
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Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
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Service providers, that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, data and web hosting providers, software service providers, email marketing providers, payment processing companies, data analytics providers, and companies that provide business support services, financial administration, or event organization.
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Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
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Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
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Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Use and other agreements or policies; and to protect ours, our customers’, or third parties’ safety, property, or rights.
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Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
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Business partners, that may use Personal Data for their own purposes, such as:
- Advertisers, ad platforms and networks, and social media platforms;
- Third parties whose Cookies we use as described in Section 5.
- Commercial data partners to whom we make information available for their own marketing purposes; and
- Partners who work with us on promotional opportunities, including co-branded products and services.
Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.
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The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
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Entities to which you have consented to the disclosure.
Our Digital Properties and authorized third parties use Cookies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about:
- The types of Cookies we use and the purposes for which we use them
- The types of information we collect using these technologies
- How we disclose or make information available to others
- Choices you may have regarding these technologies
A. Types of Cookies
We and the third parties that we authorize may use:
- Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit a website. Some Cookies exist only during a single session and some are persistent over multiple sessions over time.
- Pixels, web beacons, and tags, which are types of code or transparent graphics. In addition to the uses described below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
- Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
- Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on our Digital Properties
B. Purposes for using these technologies
We and authorized third parties use these technologies for purposes including:
- Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties
- Improving performance, such as maintaining and improving the performance of our Digital Properties;
- Analytics, such as analyzing how our websites are used. For example, we use Google Analytics to help us improve the user experience. Google Analytics may use Cookies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners;
- Advertising, such as conducting advertising and content personalization on our Digital Properties and those of third parties; tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”); providing you with offers and online content that may be of interest to you; and measuring the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with one of our emails; and
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Security, such as preventing fraud and malicious behavior.
C. Information collected
These Cookies collect data about you and your device, such as your IP address, location (both approximate and precise) cookie ID, device ID, Ad ID, operating system, browser used, browser history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).
D. Disclosures of your information
We may disclose information to third parties or allow third parties to directly collect information using these Cookies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties.
E. Your choices
As described in Section 10 (“Supplemental U.S. State Privacy Disclosures”) below, residents of certain states may be able to disable Cookies that constitute a “sale,” “sharing,” or “targeted advertising,” as those terms are defined under applicable laws.
In addition, some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.
You can also refuse or delete Cookies using your browser settings. If you refuse or delete Cookies, some of our Digital Properties’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage Cookies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your Cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.
Some browsers have incorporated Do Not Track (“DNT”) preferences. At this time, we do not honor Do Not Track signals.
6. Data Security and Data Retention
Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.
Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest. If you would like to know more about the retention periods applicable to your Personal Data, you can contact us using details provided in the Contact Information below.
Our Digital Properties are intended for individuals 18 years [MWE1] of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 18 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at the address in the Contact Information section below, and we will take prompt steps to delete the information.
Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.
If you have questions regarding this Privacy Notice, please contact us at: hello@peachandlily.com with “PRIVACY POLICY” in the subject line.
10. Supplemental U.S. States Privacy Disclosures
A. Data Subject Rights
Depending on our relationship with you (i.e., whether you are an Individual or a Business Contact), and in which state you reside within the United States (such as California, Colorado, Oregon, or Delaware), you may have certain rights regarding Personal Data that you can exercise via by emailing us at hello@peachandlily.com:
- Right to Know. You may have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why. You may also request the specific pieces of Personal Data we have collected about you. Oregon residents may also request a specific list of third parties to whom we disclose your Personal Data.
- Right to Delete. You may have the right to request that we delete Personal Data that we have collected from you.
- Right to Correct. You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
- Right to Opt Out of Profiling. You may have the right to opt out of certain automated processing activities that are used to evaluate characteristics about you. We do not presently engage in such profiling.
- Right to Limit Use and Disclosure of Sensitive Personal Data. You may have the right to limit the use and disclosure of Sensitive Personal Data. As described below, we do not presently engage in such processing for which there is a right to limit.
- Right to Opt Out of Sale, Sharing, and Targeted Advertising. You may have the Right to Opt Out of Sale, Sharing, and Targeted Advertising (as such terms are defined under applicable laws). We do not knowingly sell data about minors under 18. You can exercise the Right to Opt Out of Sale, Sharing, and Targeted Advertising by accessing our Privacy Preference Center and toggling “Allow Sale/Sharing/Targeted Advertising” to the “off” position or emailing us at hello@peachandlily.com.
To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.
We will not discriminate against you for exercising your privacy rights.
Nevada residents: Individuals may contact us at hello@peachandlily.com to inquire about your right to opt out of the sale of your Personal Data.
Verification: To process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request.
- For Requests to Opt-Out of Sale, Sharing, and Targeted Advertising: We collect your email to locate you in our records.
- For Requests to Know, Delete, and Correct: We collect information necessary to verify your identity including name, email address, and phone number[MWE5] .
Authorized Agents: Authorized agents may exercise rights on your behalf by submitting a request via hello@peachandlily.com
- If you designate an authorized agent to submit a Request to Opt Out of Sale, Sharing, and Targeted Advertising, we may seek additional information directly from the authorized agent to process the request.
- If you designate an authorized agent to submit a Request to Know, Delete, or Correct, we may require the agent to provide us with your signed permission stating the agent is authorized on your behalf and/or we may reach out to you directly to verify your own identity or to confirm that you provided the authorized agent permission to submit the request.
Appeal: If we deny your rights request, you may have the right to appeal. To submit an appeal, hello@peachandlily.com. We will inform you in writing of our response to your appeal.
B. Additional Data Processing Disclosures for California Residents
In addition to the disclosures above, this section provides supplemental information about how we process Personal Data. These additional disclosures apply only to individuals who reside in California as required by the California Consumer Privacy Act (“CCPA”).
Disclosure of Personal Data
Below please find a chart detailing the categories of Personal Data we collected and to whom it was sold, shared, or disclosed for a business purpose in the past 12 months.
Categories of Personal Data We Collect |
Categories of Third Parties to Whom We Disclose Personal Data for a Business Purpose |
Categories of Third Parties to Whom Personal Data is Sold or Shared for Targeted Advertising |
Identifiers(Section 2.A) |
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Records about you (Section 2.B) |
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Demographic Information(Section 2.C) |
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Commercial information (Section 2.D) |
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Internet or other electronic network activity(Section 2.E) |
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Geolocation data(Section 2.F) |
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Audio, electronic, visual, or other sensory information(Section 2.G) |
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Professional or employment-related information (Section 2.H) |
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Education information (Section 2.I) |
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Inferences(Section 2.J) |
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Sensitive personal information (Section 2.K) |
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Sensitive Personal Data: We only use and disclose Sensitive Personal Information for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.
California Shine the Light: If you are a California resident, you may opt out of sharing your Personal Data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes by emailing us at hello@peachandlily.com or submitting a request through our webform.
C. Notice of Financial Incentives
Peach & Lily offers programs, benefits, and other offerings to consumers related to the collection, retention, or sale of Personal Data that may be deemed a “financial incentive” or “price or service difference” under the California Consumer Privacy Act (“CCPA”). These offerings may involve collecting the following categories of Personal Data from customers who participate: identifiers; customer records; protected class and demographic information; commercial information and preferences; internet or other electronic network activity information and device information; audio, electronic, visual, or other sensory information; and inferences. We are providing you with this information so that you may make an informed decision on whether to participate in our programs. Examples of the programs we offer include:
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Surveys: We may offer our customers opportunities to participate in surveys. In exchange for participation you may be offered a financial incentive, such as a discount or a coupon. As part of these surveys we may collect Personal Data, such as your name, preferences, experiences, beliefs, opinions, and other responses to the survey questions. Participation in surveys is governed by the applicable terms and conditions for the survey, which will also describe how to participate. You can terminate participation at any time by contacting us at hello@peachandlily.com. Our good-faith estimate of the value of your Personal Data is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.
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Limited-Time Promotions or Sweepstakes: From time to time, we may offer incentives limited to a specific time period, such as limited-time sweepstakes, contests, and other promotions. In exchange for your participation in these promotions, you may be offered a financial incentive, such as a prize. As part of these limited-time promotions or sweepstakes, we may collect your Personal Data, such as your name, email address, and phone number. Participation in a limited-time offer or promotion is governed by the applicable terms and conditions for the program (e.g., Sweepstakes Rules and Prize Acceptance Agreements), which will also describe how to participate. You can terminate participation at any time by contacting us at hello@peachandlily.com. The value of your Personal Data is our good-faith estimate of the value of the prize divided by the number of entrants. We have calculated such value by using the expense related to the benefit.
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One-Time Promotions: In addition to the programs identified above, we may also offer you one-time percentage off coupons, discounts, or other promotions from time to time, such as when you provide us your email address and agree to receive marketing emails in exchange for a one-time coupon. Such offers may not always be available. You can terminate participation at any time by contacting us at hello@peachandlily.com. Our good-faith estimate of the value of your Personal Data is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.
By participating in any of the above promotional programs, you agree that the benefits are reasonably related to the value of the Personal Data collected and retained.
Participation in our promotional programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. You can also contact us at hello@peachandlily.com to unsubscribe or cancel your participation in any program.
11. Supplemental Information for the EEA, Switzerland and the UK
The following terms supplement the above disclosures with respect to our processing of EEA, Swiss, and UK Personal Data, and only apply to the extent that EEA, Swiss, or UK data protection laws apply to our processing of your Personal Data. To the extent applicable, in the event of any conflict or inconsistency between the other parts of the Privacy Notice and the terms of this Section 11, this Section 11 shall govern and prevail with regards to the processing of such EEA, Swiss and UK Personal Data.
D. Data Controller
Peach and Lily, Inc. is the controller responsible for processing your Personal Data.
E. Legal Bases for Processing
We process the following categories of personal data for the following processing purposes based on the following legal bases:
Categories of personal data |
Legal bases[9] |
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To provide you products and services (Section 3.A) |
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For our internal business purposes (Section 3.B) |
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For our internal research and product improvement purposes (Section 3.C) |
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For legal, safety or security reasons (Section 3.D) |
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In connection with a corporate transaction (Section 3.E) |
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For marketing and targeted advertising (Section 3.F) |
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F. Your Data Protection Rights
Under the conditions set by applicable data protection laws, you may exercise certain rights regarding your Personal Data.
- Right to Access. You have the right to obtain confirmation from us whether we are processing your Personal Data and related information, as well as the right to obtain a copy of your Personal Data undergoing processing.
- Right to Data Portability. You may receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format.
- Right to Rectification. You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.
- Right to Objection. You have the right to object to the processing of your Personal Data in certain cases.
- Right to Restrict Processing. You may request that we restrict the processing of your Personal Data in certain cases.
- Right to Erasure. You may request that we erase your Personal Data in certain cases.
- Right to Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority in the country where you reside or where the conduct that is the subject of the complaint occurred.
- Right to Refuse or Withdraw Consent. In case we ask for your consent to process your Personal Data, you are free to refuse to give it. If you have given your consent, you may withdraw it at any time without any adverse consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.
- Right to Not Be Subject to Automated Decision-making. You have the right to not to be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.
You may exercise these rights by contacting us using the details in the Contact Information section above.
G. International Transfers of Personal Data
Due to the global nature of our operations, some of the recipients mentioned in the How We Disclose Personal Data section of this Privacy Notice may be located in countries outside the EEA, Switzerland or the UK that do not provide an adequate level of data protection as defined by data protection laws in the EEA, Switzerland and the UK. Certain third countries have been officially recognized by the European Commission, Switzerland, and the UK Secretary of State as providing an adequate level of protection. Transfers within our corporate group or to third parties located in third countries that have not received such recognition take place using an acceptable data transfer mechanism, such as the EU and/or UK Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and Certifications, on the basis of permissible statutory derogations, or any other valid data transfer mechanism issued by the EEA, Swiss or UK authorities.
Please reach out to us using the contact information in the Contact Information section above if you want to receive further information about how we transfer Personal Data or, where available, a copy of the relevant data transfer mechanism.
EU/UK Representative
Please reach out to privacy@peachandlily.com.