Version: 01/2024

Sauna360 and its affiliates (collectively, the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices pertaining to information that we collect in connection with: 

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
• Software applications from which you are accessing this Privacy Policy (the “Apps”);
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other relevant communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.” 

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including: 

• Name
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address
• IP address (we may also derive your approximate location from your IP address)
• Payment card data
• Profile picture
• Social media account ID
• Personal Information contained in surveys or feedback that you provide to us or in competitions in which you participate

Collection of Personal Information  

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.  
  • We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, visit our stores, attend one of our events, place an order over the phone, contact customer service, or make a purchase.
• From Other Sources. 
  • We receive your Personal Information from other sources, for example:
    • publicly available databases;
    • joint marketing partners, when they share the information with us.

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information 

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.
  • To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related benefits, special promotions, or customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
  • To complete your transactions, process returns and exchanges, verify your information, and provide you with related benefits, special promotions, or customer service.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.
  • To allow you to send messages to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
  • To send you marketing related emails, with information about our services, new products and other news about our company.

We will engage in this activity with your consent or where we have a legitimate interest.

• Analyzing Personal Information for business reporting and providing personalized services.
  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
  • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law. 

• Allowing you to participate in sweepstakes, contests or other promotions.
  • We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
  • Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.  Please read those additional rules before choosing to participate.

We use this information to manage our contractual relationship with you. 

• Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. 
• Accomplishing our business purposes.
  • For data analysis, for example, to improve the efficiency of our Services;
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  • For developing new products and services;
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Disclosure of Personal Information  

We disclose Personal Information: 

• To our affiliates for the purposes described in this Privacy Policy.
• You can find the list and location of our affiliates in the annex. Sauna360 is the party responsible for the management of the shared Personal Information. To our third party service providers, to facilitate services they provide to us.
  • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
• To third party dealers. For example:
  • You can use the dealer locator on our Services to send a contact request to the dealer of your choice. We do not check the information submitted by you, but we pass on your enquiry directly to the dealer, who then obtains the information submitted by you, including your Personal Information.
• To third party sponsors of sweepstakes, contests, and similar promotions.
• By using the Services, you may elect to disclose Personal Information.
  • On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages).  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
  • This may include laws outside your country of residence.
• To cooperate with public and government authorities.
  • To respond to a request or to provide information we believe is necessary or appropriate.
  • These can include authorities outside your country of residence.
• To cooperate with law enforcement.
  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). 

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. For more information is our Cookies & Similar Technologies Notice.

Uses and Disclosures of Other Information 

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt out from:

1. Receiving marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by unsubscribing directly in the email.
2. Our sharing of your Personal Information with affiliates for their direct marketing purposes.  If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by sending an email info@sauna360.com.com.
3. Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes.  If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by sending an email to info@sauna360.com.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.  

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).   You may also lodge a complaint with an data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.  A list of data protection authorities for the EU/EEA is available at  https://edpb.europa.eu/about-edpb/about-edpb/members_en and the data protection authority for the UK is the Information Commissioner’s Office. 

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).  

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

THIRD PARTY ADVERTISING 

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

• You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.  

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. 

ADDITIONAL INFORMATION REGARDING THE EEA/UK: Some non-EEA/UK countries are recognized by the European Commission and UK government as providing an adequate level of data protection according to EEA/UK standards (the full list of these countries is available here for the EEA and here for the UK). For transfers from the EEA/UK to countries not considered adequate by the European Commission or the UK government, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and the UK government and binding corporate rules to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership on or through the Services or otherwise to us.

THIRD PARTY PAYMENT SERVICE

The Services may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account.  When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  

CONTACTING US

Sauna360 is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.  If you have any questions about this Privacy Policy, please contact us at: info@sauna360.com

Annex