Privacy Policy

Last Updated:   June 22 , 2023 

This privacy policy (“Privacy Policy”) governs how we, Jeffs Brands Holding Inc. (“Whoobli” “we”, “our” or “us”) use, collect, disclose, and store Personal Data we collect or receive from or about you (“you”) such as in the following use cases:

1. When you browse or visit our website, https://www.Whoobli.com/ (“Website”)
   1. When you make use of, or interact with, our Website 
   2. When you create an account and log-in to your account and make a purchase
   3. When you make a purchase in our Website as a guest (without creating an account)
   4. When you participate in our surveys
   5. When you subscribe to our distribution list(s) / newsletter(s)
   6. When you post comments or reviews on our blog posts
   7. When you contact us (e.g. customer support, need help, submit a request)
2. When we use the Personal Data of our service providers (e.g. contact details)  

• When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn) 

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. 

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your privacy rights
6. Use by children
7. Log files 
8. Analytic tools
9. Specific provisions applicable under California law
10. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

• Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

• Retention of your Personal Data. Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. Regarding retention of cookies, you can read more in our cookie policy [https://www.whoobli.com/pages/cookie-notice]

3. HOW WE SHARE YOUR PERSONAL DATA 

• We share your Personal Data as follows:
  • With our partners and other third parties. We may also share information with the companies of our group. 
  • We use third party service providers to process your Personal Data for the purposes outlined above, including, without limitation:
    • With cloud service providers for hosting purposes;
    • Process your purchases, shipping and payment companies;
    • Provide customer support;
    • With websites and web content creation platforms in order to help us manage our Website;
    • With analytic companies and other advertisement providers, in order to help us understand and analyze information we collect in accordance with this policy; and
    • With survey providers and email administration service providers.
  • To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Whoobli, our services, customers, employees, property, and the public..
  • If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
  • Where you have otherwise provided your consent to us for sharing or transferring your information.

• If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to hello@whoobli.com.

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA. In order to run our business and provide our Website and services to you, we transfer Personal Data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your Personal Data may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your Personal Data by implementing safeguards, including, by executing implement data onward transfer instruments such as data processing and protection agreements.

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

• The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
  • You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.
  • You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality; and/or
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
• You can exercise your rights by contacting us at hello@whoobli.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
• Deleting your account: Should you ever decide to delete your account, you may do so by emailing hello@whoobli.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account.
• Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to hello@whoobli.com. Please note that the email must come from the email account you wish to block or if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

6. USE BY CHILDREN. We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at hello@whoobli.com.

7. INTERACTION WITH THIRD PARTY PRODUCTS.We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. AND ANALYTIC TOOLS
   • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 
   • Google Search Console. We use a tool called "Google Search Console" to track the data on how often our Service appears in Google Search, which search queries show our Service, how often searchers click through to those queries and other search features. You can learn more about this tool by reviewing the Google Search Console API terms of service at https://developers.google.com/terms
   • We reserve the right to remove or add new analytic tools.

9. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA LAW

9.1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email hello@whoobli.com. Please note that we are only required to respond to one request per customer each year.

9.2. Our California Do Not Track Notice (Shine the Light):  We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.

10. CONTACT US.If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at hello@whoobli.com.