California Consumer Privacy Act (CCPA)


We collect Data in the following categories: Registration Data, Engagement Data, Usage Data, and Payment Data.


  DATA WE COLLECT AND HOW WE USE IT

Below, we have listed the categories of Data we collect. In each case, you and your use of the Services are the source of the Data we have collected. Over the last twelve months, we have collected those categories of Data (as indicated in the list below). We have also sold or shared with business associates the same categories of Data, all as described below. We always have a lawful basis for gathering the Data, but that lawful basis might be different for different categories, and we describe those uses below. Regardless, we never use the Data for any purpose other than the purpose for which we gathered the Data in the first place, unless we get your prior explicit consent. If you have any questions about this section, please contact us at support@trypura.com. 

 

A. Registration Data  

- Category of Data and Description: Registration Data consists of the name, e-mail address, street address, and other contact information you provide us using the Services, both when you register your account and thereafter. Registration Data also includes your username, client type (e.g., ad-supported or paid membership), and membership end date, if any.  

- Lawful Basis and Business or Commercial Purpose for Collection and Processing: Our lawful basis and purpose for collecting processing Registration Data is to fulfill our contract with you. We can only provide certain of the Services to you if we have the Registration Data, so we need to store and access that Registration Data during the term of our contract. We may also use the Registration Data to email you offers and information regarding our products and services and to send push notifications to the app. Even when the Registration Data is not critically necessary to the provision of the Services, we may still process that Registration Data to facilitate our contractual interactions with you. We may also sell certain of the Registration Data to third parties to enable them to contact you and offer their services to you.

- How We Use It and Who We Share It With: Registration Data is accessible only to us and, in certain circumstances, the parties to whom we may sell your Data. We use the Registration Data to provide the Services to you, including to allow us to identify you across different devices you may use. At times, we will share the Registration Data with third parties at your request or to fulfill requests that you make of us. We may also sell your Data to third parties to allow them to learn about the overall market and to specifically market their services and products to you. For example, we sometimes sell your Data to third parties who manufacture and sell fragrances, either branded or wholesale, and who serve as resellers of our products and services. Giving them access to your Data allows them to contact you and to understand the market better. Typically, fragrance houses (non-branded manufacturers) are not interested in personally identifiable information, but only in trends and statistics, and those would typically only get de-identified information. We may also use your Registration Data to offer our own goods or services to you via email and to provide push notifications to the app, either directly or through third party platforms.  You may opt out of the sale of your Registration Data by visiting us at www.trypura.com/pages/optout.

 

B. Engagement Data

- Category of Data and Description: Engagement Data consists of all the information you input or record using the Services, other than the Registration Data. It also includes all information that is proprietary to you regarding your use of the Services (other than the data that qualifies as “Usage Data” below) that is collected or processed by the Services. For example, Engagement Data would include the types of fragrances you purchase and use, the location and time of their use, patterns of use, and your preferences, which we would learn from surveys in which you participate.  

- Lawful Basis and Business or Commercial Purpose for Collection and Processing: Our lawful basis for processing Engagement Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Engagement Data we receive from you. If we sell your Engagement Data to a third party, the purpose would be to allow them to understand their market better, which allows them to more effectively meet their customers’ needs.  

- How We Use It and Who We Share It With: Your Engagement Data is accessible only to us, to you, to the companies to whom we may sell the Engagement Data, and where it relates directly toa party who either provides services to you or receives services from you, to that party, in which case that party will be obligated to protect the confidentiality of your Engagement Data. We do not share Engagement Data with other third parties other than provided herein, except at your specific request, but we may use Engagement Data to make inferences that help us provide and improve the Services and communicate offers to you for our own goods and services. Both during the term of our agreement with you and thereafter, we may also use Engagement Data in an anonymized and aggregated format that is not identifiable to any individual, and that anonymized and aggregated information belongs solely to us to use in our sole discretion (including to sell anonymized and aggregated information, which is not Data). To the extent we are required to delete any Engagement Data about you, we may still retain aggregated and anonymized information that may have originated as your Engagement Data. You may opt out of the sale of your Engagement Data by visiting us at www.trypura.com/pages/optout.

 

C. Usage Data

-Category of Data and Description: Usage Data consists of the following and similar information:

- Information about your interactions with the Services, most commonly our website, which includes the date and time of any requests you make. This also may include details of your use of Third-Party Applications and any advertising you receive via the Services.

- The timing of the information you post to the Services including messages you send and/or receive via the Services and your interactions with our customer service team, but not including the content of those interactions and messages, which would be included as Engagement Data.

- Technical data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Services, unique device IDs, device attributes, network connection type (e.g. WiFi, 4G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and application version.

- Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope), if any, required for the purposes of providing specific features of the Services to you.

- Lawful Basis and Business or Commercial Purpose for Collection and Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Usage Data we receive from you. If we sell your UsageData to a third party, the purpose would be to allow them to understand their market better, which allows them to more effectively meet their customers’ needs.  

- How We Use It and Who We Share It With: Usage Data is accessible to us, to you, and to any company to whom we may sell it. We do not share it with third parties, except at your specific request, and as provided herein, but we may use Usage Data to make improvements to the Services. Both during the term of our agreement with you and thereafter, we may also use Usage Data in an anonymized and aggregated format that is not identifiable to any individual, and that anonymized and aggregated information belongs solely to us to use in our sole discretion (including to sell anonymized and aggregated information, which is not Data). To the extent we are required to delete any Usage Data about you, we may still retain aggregated and anonymized information that may have originated as your Usage Data. You may opt out of the sale of your Usage Data by visiting us at www.trypura.com/pages/optout.

 

D. Payment Data

- Category of Data and Description: Payment Data is only collected when your use of the Services is subject to the payment of a fee or other charge. Payment Data is the information necessary for us to process your payments for premium Services. Payment Data will vary depending on the payment method you use (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:

- Name;

- Date of birth;

- Credit or debit card type, expiration date, and certain digits of your card number;

- Address and postal code; and

- Mobile phone number

- Lawful Basis and Commercial or Business Purpose for Collection and Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Payment Data we receive from you.  

- How We Use It and Who We Share It With: We only use Payment Data to facilitate payment, and we only communicate it to those parties who are strictly necessary for that purpose.

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