Privacy Policy
PRIVACY POLICY
Effective Date: March 11, 2020
Introduction
Welcome! You have arrived at a website that is provided by Dharma Studio, LLC (“Dharma” or “we,” “our” or “us”). This “Privacy Policy” governs your use of www.dharmaworldwide.com (including, without limitation, both mobile and online versions of our site), and also applies to your use of all features, applications, content, downloads and other products or services that we make available through the site and/or that post a link to this Privacy Policy (collectively, referred to herein as the “Site”), regardless of how you access or use the Site, whether via personal computers, mobile devices or otherwise.
Our Privacy Policy explains our data collection practices when collecting, storing and or using your data. To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
In addition, please review the Site’s Terms of Service, which governs your use of the Site. By using our Site, you consent to our Privacy Policy and Terms of Service and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information (defined below) and do not use this Site.
If you are located or a resident of the EU, please review Section 14 of this Privacy Policy, which contains our supplemental privacy notice that applies to you. If you are located or a resident of Canada, please review Section 15 of this Privacy Policy, which contains our supplemental privacy notice that applies to you.
Table of Contents
It is important that you read and understand the entire Privacy Policy before using the Site. However, this table of contents highlights the topics covered.
1. What Information Does the Site Collect?
(a) Information You Provide to Us
(b) Information We Collect and Store As You Access and Use the Site
(b) Information Third Parties Provide About You
(c) Interactions with Third-Party Services
(d) Information You Provide About a Third Party
(e) California / Delaware Do Not Track Disclosures
2. How Do We Use the Information Collected?
3. How and When Do We Disclose Information to Third Parties?
(a) When You Request Information From or Provide Information to Third Parties
(b) Third Parties Providing Services on our Behalf
(c) Administrative and Legal Reasons
(d) Affiliates and Business Transfer
(e) Sweepstakes, Contests and Promotions
4. Your California Privacy Rights
(a) Categories of Personal Information We Collect
(b) Sources of Collected Personal Information and Purposes of Collection and Disclosure
(c) Categories of Personal Information We May Share and Who We May Share It With
(d) Your Privacy Rights
(e) Exercising Your Rights
(f) Non-Discrimination
5. Your Nevada Privacy Rights
6. Ads and Information About You
7. What About Information I Disclose Publicly?
(a) User Content and Public Information
(b) Name and Likeness
(c) User Testimonials
8. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Site?
How Do I Change My Information and Communications Preferences?
9. What About Transfer of Information to the United States?
10. What Should Parents Know About Children?
11. What About Security?
12. What About Changes to the Privacy Policy?
13. Supplemental Privacy Notice For Residents of the EU and EEA
14. Supplemental Privacy Notice For Residents of Canada
The Full Detailed Privacy Policy
1. What Information Does the Site Collect?
(a) Information You Provide to Us
On the Site, we or our service providers may ask you to provide certain types of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, email address, home address, credit card number and phone number (“Personal Information”); and (2) demographic information, such as information about your gender and age (“Demographic Information”). We may collect this information through various forms and in various places on the Site, including through “contact us” forms, when you purchase products or services from us or if you request to receive our electronic newsletter or when you otherwise interact with the Site. In addition, Personal Information once “De-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction non-personally identifiable elements including through anonymization, pseudonymization and/or hashing) is not considered Personal Information and may be used and shared by us or other third parties without obligation to you, except as prohibited by applicable law.
(b) Information We Collect and Store As You Access and Use the Site
In addition to any Personal Information or other information that you choose to submit to us via our Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect and store certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may be non‑identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information. This Usage Information may include:
- your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our Site;
- the areas within our Site that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the date and time of day of your visit, among other information.
We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
- Cookies. A cookie is a data file placed on a Device when it is used to visit the Site. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.
- Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
- Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
- ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.
- Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
- Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Site, your device location may be tracked.
We may use Tracking Technologies for a variety of purposes, including:
- Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Site functionality.
- Performance‑Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.
- Functionality‑Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you visit our Site or keeping track of our specified preferences, including in terms of the presentation of content on our Site.
- Targeting‑Related. We may use Tracking Technologies to deliver content relevant to your interests on our Site and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.
There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with our Site, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.
(c) Information Third Parties Provide About You
We may receive information about you from your friends and others that use the Site, such as when they submit your information to us about you, if for example, they buy you a gift on the Site. Additionally, we may, from time to time, supplement the information we collect directly from you on our Site with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content and ads to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.
(d) Interactions with Third-Party Services
The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party web site, application or other service. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, we may provide third-party sites’ interfaces or links on the Site to facilitate your sending a communication from the Site. For example, we may use third parties to facilitate emails, Tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Dharma may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Site.
(e) Information You Provide About a Third Party
You may send someone else a communication from the Site, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Site, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).
(f) California / Delaware Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
2. How Do We Use the Information Collected?
We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:
- to process, track and complete purchase, return and similar transactions;
- to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about upcoming events;
- to enable you to participate in a variety of the Site’s features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;
- to improve the Site, marketing endeavors or our product and service offerings;
- to customize your experience on the Site or to serve you specific content that we believe is relevant to you;
- to process Site account registration;
- to offer location-based services;
- to provide customer service and support, including responding to your inquiries regarding our merchandise or services;
- to notify you of any product recalls or providing other information concerning products or services you have purchased;
- to send you information about orders you have placed on the Site;
- to identify you as a customer and to identify your product and service preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you;
- to contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site’s policies;
- to measure and analyze audience traffic and to improve the overall experience at the Site and our merchandise and services;
- to understand whether you read our communications and clicked on links within those messages;
- to develop aggregated data and statistics;
- for internal business purposes; and
- for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
3. How and When Do We Disclose Information to Third Parties?
We may share non-Personal Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. Also, we may share your Personal Information with third parties with whom we have marketing or other relationships for the third parties’ direct marketing purposes. If you are a California resident, you have the right to request additional information about this sharing, so please see Section 4 below. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We may disclose your information as follows:
(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Site or link to them from our Site. This may include using third party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
(b) Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Site, such as: (i) to assist us in Site operations; (ii) to manage a database of customer information; (iii) hosting the Site; (iv) designing and/or operating the Site’s features; (v) tracking the Site’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 6 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
(c) Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Site’s Terms of Service or other policies applicable to the Site, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Site or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
(d) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
(e) Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Site that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
4. Your California Privacy Rights
This Section applies to any California residents about whom we have collected personal information from any source, including through your use of our Site or by communicating with us electronically, in paper correspondence, or in person. Any terms defined in the CCPA have the same meaning when used in this Section 4. This Section only applies to non-California residents as may be required by applicable state law in your state of residence.
(a) Categories of Personal Information We Collect. We have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account number, name and password, driver’s license number, passport number, state or other government-issued identification card number and/or other similar identifiers. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
D. Commercial information. | Records of personal property; products or services purchased, obtained, or considered; vehicle identification number (VIN); account balances, payment history, or account activity; bank account information and other information relating to your financial institution; credit application, credit checks, and information from credit reporting agencies; and/or other purchasing or consumer histories or tendencies. | NO |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, facial scans, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
F. Internet or other similar network activity. | Cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”). | YES |
G. Geolocation data. | GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s). | YES |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information, including records of calls to or from our customer service centers; and/or video surveillance information. | YES |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
J. Non-public education information (per the Family Educational Rights & Privacy Act) (20 U.S.C. Section 1232g, 34 C.F.R. Part 99) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |