Privacy Policy

CuraLabs, LLC. and its subsidiaries and affiliates (“CuraLabs”, “StriCura”, “we”, or “us”) knows that you value your privacy. This privacy policy explains the information we collect through the websites available via CuraLabs.com, StriCura.com and its subdomains as well as through other CuraLabs-managed websites or pages where this privacy policy is posted or linked (collectively, the “Sites”). This policy describes how the above information is collected, used, shared, and secured, as well as your related choices regarding use, access and correction.

CuraLabs, LLC works with affiliates, which include other entities, directly or indirectly controlled by, or under common control with, us (“Affiliates”). Capitalized terms not defined herein shall have the meaning set forth in the StriCura Website Terms of Use (“Terms of Use”).

The Site is intended for users who are located in the United States and is hosted and operated in the United States, pursuant to United States law. By providing personal information through the use of the Site, you understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories.

Information Collected

You may visit and browse the Site without providing personally identifiable information about yourself. However, this may limit your ability to receive certain features, products or services from Us.

By continuing to use StriCura’s Site or Services on or after June 1, 2018, you acknowledge our updated Privacy Policy and Terms of Service.

To review our previous Privacy Policy, please contact: care@StriCura.com to get a copy of the old Privacy Policy. 1. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, including what categories of personal information we have shared with third parties in the preceding year, and the names and addresses of those third parties. To make such a request, please send an e-mail to: Support@StriCura.comor contact us via mail at: StriCura 2604-B El Camino Real, Ste 214, Carlsbad, CA 92008.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please e-mail us at: Support@StriCura.comcall us at: (800) 430-0227; or send us mail to: StriCura 2604-B El Camino Real, Ste 214, Carlsbad, CA 92008.

INFORMATION COLLECTED

We collect information about you either: (i) directly from you when you provide it to us, including when using the Site; (ii) automatically as you use the Site; and (iii) from Affiliates and other sources, as described in this Privacy Policy.

Personal Information Collected: We collect several types of information from and about users of the Site and/or the StriCura Offerings, including the following: name, mailing address, billing address, email address, phone number, credit/debit card information, password, personal description, age, birthdate, gender, photograph, and purchase history.

Information Collected through Automatic Data Collection Technologies: As you navigate through and interact with the Site and/or the StriCura Offerings, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including, IP address, login information, browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform, products viewed, searched for or purchased, page response times, download errors, length of visit to certain pages, page interaction (scrolling, clicks, mouse-overs) and methods used to browse away from the page.

We may also receive and keep information you provide to us regarding other people. For example, if you instruct us to ship your order to someone else, you may provide us with the name and contact information of the intended recipient, and we may use that information to process the shipment and, in some cases, communicate with the intended recipient. We rely on you to obtain the intended recipient's consent to our use of their Personal Information for these limited purposes.

CREDIT / DEBIT CARD INFORMATION COLLECTION AND USE

We use credit/debit card information solely for billing purposes and to fill your Products/Gift Card orders. If we have trouble processing an order, we will use this information to contact you. Also, please rest assured that all purchases and credit/debit card transactions that are processed through the Site are private and secure, in accordance with Payment Card Industry standards. We use industry standard encryption technology to secure your information.

AUTOMATIC DATA COLLECTION TECHNOLOGIES

Site Usage Information: StriCura and its third–party service providers may also use a variety of technologies that passively or automatically collect information about your device and how you access and use the Site, including your browser type, device type, operating system, application version, the pages served to you, the time you browse, preceding page views, and your use of features or applications on the Site ("Usage Information"). This data helps us understand what is interesting and relevant to users of the Site, so we can best tailor our content.

The tracking technologies we use for automatic data collection may include:
Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Site. For information about managing your privacy and security settings for cookies, see Section 13 “Opting Out of Newsletters, Special Offers and Product Updates.” To find out more about cookies, please visit www.cookiecentral.com/c_concept.htm.

Web Beacons: Pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Site statistics (for example, recording the popularity of certain Content and verifying system and server integrity). We utilize web beacons to help us better manage the Content by informing us what Content is effective. For information about managing your privacy and security settings for web beacons, see Section 13 “Opting Out of Newsletters, Special Offers and Product Updates.”

BEHAVIORAL TRACKING; DO NOT TRACK DISCLOSURES; CROSS DEVICE TRACKING

StriCura does not itself use cookies, web beacons, pixels and other tracking technology on the Site for purposes of tracking end-user’s activities after they leave the Site.

Third parties acting on behalf of us or our Affiliates may use cookies, web beacons or other automatic data collection technologies:

to help us measure and determine how visitors use our Site and the effectiveness of our Site;
to help us improve and optimize the products and services we or our Affiliates offer; or
to collect your non-personally identifiable information regarding your online behavior to provide you with use-tailored and targeted advertisements.

To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third parties in connection with the Site.

At this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.

StriCura tracks end-users’ use of the StriCura Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your StriCura Offerings experience. StriCura may collect certain of your personal information across various devices. For information about managing your privacy and security preferences, see Section 13 “Opting Out of Newsletters, Special Offers and Product Updates.”

HOW WE USE YOUR INFORMATION

We may use information that we collect about you or that you provide to us, including any personal information:

to administer and present the StriCura Offerings to you, including: (i) identifying product preferences and shopping preferences and customizing Site pages for you; and (ii) saving your password so you do not have to provide it each time you visit the Site;
to allow you to participate in interactive features of the StriCura Offerings;
to complete, fulfill, manage and communicate with you about your orders or otherwise provide you with the StriCura Offerings;
to fulfill any other purpose for which you provide it;
to contact you regarding any StriCura Offerings we provide or to notify you about changes to the StriCura Offerings;
to inform you and make recommendations about our products and the StriCura Offerings, including sales, special offers and new Site features and to send you other promotional communication;
to provide customer service or support or contact you regarding your account;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to conduct internal research and development and improve the StriCura Offerings;
to perform other logistics and operation activities as needed;
to protect our assets and prevent fraudulent transactions, including: (a) validating credentials and authenticating customers when logging into your online profile or transacting in store; and (b) protecting the security and integrity of the StriCura Offerings and our data;
to share information with Affiliates and third parties, as described in this Privacy Policy;
in any other way we may describe when you provide the information; or
for any other purpose with your consent.

TESTIMONIALS / REVIEWS

From time to time, StriCura may permit end-users to submit reviews and testimonials regarding certain of the StriCura Offerings, as well as biographical material associated with such end-users (collectively “Testimonials”), by and through the Site or otherwise. By submitting a Testimonial, you irrevocably grant to StriCura the right to use the Testimonial (including your biographical information) in any and all forms of marketing and promotional material including, without limitation, website publication, print ads, online ads, television ads, radio ads, interactive media, as well as printed extracts and reproductions of any portion thereof, and for any and all other uses. You should be aware that your Testimonial(s), and any personal information that you submit in connection with same, may be published in a way that such material can be viewed, read, collected and/or used by others including our Affiliates. We are not responsible for the personal information that you choose to submit in connection with your Testimonial(s).

COMBINING INFORMATION

We may combine the information we receive from or about you, including both information that you provide to us and information we collect though automatic data collection technologies on computers or devices that you use, with information that we collect or receive from or about you from other sources, including from business partners, Affiliates (and their business partners), social media platforms and other third-party sources. We may use and share this information for the purposes as described in this Privacy Policy.

SHARING INFORMATION WITH AFFILIATES, BUSINESS PARTNERS AND THIRD PARTIES

We may share the information we collect about you with:
Business partners, suppliers and sub-contractors who provide services in support of our business. For example:

(i) we pass your delivery address and telephone number to our partner courier companies in case they need to contact you directly if there is a problem with your delivery;
(ii) we pass certain personal information to third-party payment management companies to enable them to verify your credit or debit card details;
(iii) we pass your personal information to third-party service providers that assist us with our marketing and data analytics efforts;
(iv) we pass certain purchasing information and use of discounts to business partners who facilitate such discount schemes, provided you have previously registered with them; or
(v) we pass your personal information to business partners who provide us with and assist us in operating customer service management software, designed to improve and manage our interaction with customers and your customer service experience.
Business partners, Affiliates (and their business partners), marketers, advertisers and advertising networks for marketing and advertising purposes, which may include: (a) sending you direct mail or emails about their products, services, sales, promotions, events, news and store openings that may interest you; or (b) serving ads or adverts that may interest you. For information about managing your privacy and opting out, see Section 13 “Opting Out of Newsletters, Special Offers and Product Updates;”
Credit reference agencies for the purpose of ensuring that your credit or debit card is not being used without your consent. This is done only to confirm your identity. No credit check is performed, and your credit rating will be unaffected;
Analytics and search engine providers that assist us in the improvement and optimization of the StriCura Offerings; or
Service providers whom we may employ to assist us in carrying out and then analyzing the results of customer surveys or questionnaires.
to protect our assets and prevent fraudulent transactions, including: (a) validating credentials and authenticating customers when logging into your online profile or transacting in store; and (b) protecting the security and integrity of the StriCura Offerings and our data;
In addition to the ways that we may share information with business partners, Affiliates (and their business partners), and other third parties as described above, we may disclose to third parties’ information collected from you in an aggregate form. However, we will only do so in such a way as to ensure that such aggregated information does not individually identify any user.

OTHER DISCLOSURE SCENARIOS

We may disclose your personal information to third parties.

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

If we plan to merge with or be acquired by that third party or in connection with a partial or total sale of assets, bankruptcy or another corporate change;

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, subpoena or court order, or in order to enforce or apply our Terms of Use and other agreements; or

If we believe in good faith that the disclosure of information is necessary to: (i) prevent imminent physical harm or financial loss to us; (ii) prevent or report suspected illegal activity; and/or (iii) protect anyone’s rights, property or safety. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TEXT MESSAGES

If you have provided prior express written consent to have promotional offers or transactional correspondence from us sent to your mobile device, we may send you a MS, MMS or other text message (“Text Messages”) with such communications to the telephone number you provided to us. Standard text message rates will apply.

If you have provided a telephone number for Text Messages, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (i) have your telephone number reassigned to another person or entity; (ii) give up your telephone number so that it is no longer used by you; (iii) port your telephone number to a landline or vice versa; or (iv) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify us of the Phone Number Change by contacting us as described in Section 20.

SECURITY

The privacy of your personal information is very important to us. We endeavor to safeguard and protect our end-users’ personal information. When end-users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). When our registration process asks end-users to submit sensitive information (such as credit/debit card information), and when we transmit such sensitive information, that sensitive information is encrypted and is protected with transport layer security (“TLS”) encryption software and is compliant with the Payment Card Industry Data Security Standard, PCI-DSS 3.1.

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. The servers that we store personal information in are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure. Computer hackers may circumvent our security measures and gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data done on or through the Site is at your own risk.

Only employees or third-party agents who need personal information to perform a specific job function are granted access to our end-users’ personal information. Employees not adhering to our internal privacy policies are subject to disciplinary action.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail, where possible, in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

OPTING OUT OF NEWSLETTERS, SPECIAL OFFERS AND PRODUCT UPDATES

We strive to provide you with choices regarding the personal information you provide to us. There are various mechanisms to provide you with control over your information, including the following:

Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies, as well as web beacons, or to alert you when cookies are being sent. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies (including those of third party vendors) when you direct your browser to the StriCura Offerings.

Email Communications: To opt out of receiving the Newsletter and/or other e-mail communications from us, you can follow the instructions at the end of the applicable e-mail message, contact us via mail at the address listed in Section 20 “Contact Us,” or call us at (800) 430-0227.

Affiliate and Business Partner Marketing Communications: If you wish to opt out of receiving marketing and advertising communications from our business partners or Affiliates (and their business partners), you must follow the opt-out instructions in each communication or privacy policy.

Text Messages: If you wish to opt out of receiving Text Messages from us, you must follow the opt-out instructions at the end of each text message (e.g., reply “STOP”).

Please note that if you decide to opt out, it may take a few days to process your opt-out request by email and 6–8 weeks to process your postal mail request and that you may continue to receive promotional or marketing materials during this time. Also, please note that opting out will not preclude us from sending you other types of non-promotional messages, such as emails confirming transactions. We will retain your information for as long as your account is active or as needed to provide you with the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

ACCESSING, DELETING AND UPDATING YOUR INFORMATION

At your request, we will inform you of what personal information we have on file for you. In addition, at your request, and to the greatest extent of our abilities, we will remove personal information that you have provided to us, or that we have collected. You may do so by contacting us via e-mail at: Support@StriCura.comprovided, however, that we ask individuals to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information will limit our ability to contact you in connection with the StriCura Offerings, which may limit your ability to utilize the StriCura Offerings. If you wish to be contacted by us in connection with the StriCura Offerings, you may not request that the personal information that we have on file for you be deleted.

Please be further advised that, after your personal information is deleted, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

SOCIAL MEDIA PAGES / INTERACTIVE SERVICES

If you interact with StriCura, its Affiliates or any third parties by and through the Interactive Services or any Social Media Pages, you should be aware that the personal information that you submit by and through such venues can be read, collected and/or used by other users of these forums (depending on your privacy settings associated with the accounts you have with the hosts of such Social Media Pages, if applicable), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire. We are not responsible for the personal information that you choose to submit in these forums.

The Social Media Pages reside on websites (“Social Media Sites”) that are operated independently from StriCura, and we are not responsible for such Social Media Sites’, interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Sites with which you interact to help you understand those Social Media Sites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Sites that you use, please refer to their applicable privacy statements or policies.

LINKS TO THIRD PARTY SITES

The Site may contain links to sites operated and maintained by third parties over which we have no control. Privacy policies on such linked sites may be different from our Privacy Policy. We encourage you to be aware when you leave the Site and to read the privacy statements of each and every site that collects information from you. If you have questions about the security and privacy settings of any sites that you use, please refer to their applicable privacy statements or policies.

MINORS

Visitors under eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age) are not permitted to use and/or submit their personal information at the Site. We do not knowingly solicit or collect information from visitors under eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age). If you register with us and we discover that you are under eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age), we will delete your registration and associated personal information, to the greatest extent of our abilities. We encourage parents and guardians to spend time online with their children and to participate and monitor the Internet activities of their children.

TRANSFER OF PERSONAL INFORMATION INTERNATIONALLY

If you are visiting this Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting this Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

We may change or modify this Privacy Policy at any time in our sole discretion. Such change(s) will be effective immediately upon posting of the change or modification on this Site. We may also elect to notify you of changes or updates to our Privacy Policy by additional means, such as sending you an email. Your continued use of our Site constitutes your acceptance of the terms of the Privacy Policy as updated or changed by us from time to time.

If you have any questions regarding the use of the Site or this Privacy Policy, please contact us at:

StriCura
2604-B El Camino Real

Suite 214
Carlsbad, CA 92008
T: 800.430.0227
E: Support@StriCura.com