Messaging Service Privacy Policy
This Messaging Service Privacy Policy explains how SWG Brands, Inc. and its affiliated brands including Hello Cake, Hello Comfort, Wet Lubricants, and Turn On (hereinafter, "SWG," "We," "Us," "Our") collects, uses, and shares personal information about you in relation to Our text message marketing program (the "Messaging Service"). This Messaging Service Privacy Policy supplements Our Primary Privacy Policy. For more details, see the section titled "Primary Privacy Policy" below.
Changes to the Messaging Service Privacy Policy
We may revise this Messaging Service Privacy Policy from time to time in our sole discretion. If there are any material changes to this Messaging Service Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Messaging Service Privacy Policy if you continue to use the Messaging Service after the new Messaging Service Privacy Policy takes effect.
Personal Information We Collect
When you sign up for the Messaging Service, We collect personal information such as your name, phone number, and email address. When you use the Messaging Service to send or receive messages, We collect communications metadata (e.g., the time/date a message was sent or received) and the contents of any communications you send or receive via the Messaging Service.
We may also collect information about you using cookies or similar technologies on Our website or other digital properties. Cookies are small text files placed on device browsers that store preferences and facilitate and enhance your experience. Cookies enable personalization of your experience via the Messaging Service (e.g., sending you personalized text messages such as shopping cart reminders).
If you participate in a contest, sweepstakes, research study, or email survey associated with the Messaging Service, We will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your personal information if you contact Us with questions about the Messaging Service or for customer service.
Use of Personal Information
We use your information to deliver, analyze, maintain and support the Messaging Service. We may also use your information to enhance the Messaging Service features and customize and personalize your experiences on the Messaging Service; to identify and prevent security risks; to prevent fraudulent, deceptive, and malicious activity including harassment and identify theft; and to verify and maintain the safety, quality, and accuracy of the Messaging Service. For example, We may use cookies to prefill your contact information, and to verify that you are authorized to consent to receive marketing messages to your device.
We may use your personal information to generate aggregated and/or de-identified information. Aggregated and/or de-identified information is not personal information and may be shared with any third party, including advertisers, promotional partners, and sponsors.
Sharing of Personal Information
We may share your personal information as contemplated in Our primary privacy policy, if you consent to Us doing so, as well as in the following circumstances:
- Third Parties that Help Provide the Messaging Service. We may share your personal information with third parties that help Us provide the Messaging Service (including, but not limited to, platform providers, phone companies, and other vendors who assist us in the delivery of text messages, fraud prevention, maintaining the security of the Messaging Service, and to verify your device and contact information).
- Legal Requirements, Disclosures to Protect Us or Others. We may disclose any information We store associated with you to external parties if We, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, Our, or others' rights, property, or safety; enforce Our policies or contracts; collect amounts owed to Us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Accurate Information
When you complete forms online or otherwise provide Us information in connection with the Messaging Service, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in Our sole discretion, We believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Messaging Service for an ulterior purpose, We may refuse you access to the Messaging Service and pursue any appropriate legal remedies.
Choices and Controls
Text messages may be sent via an automatic telephone dialing system. Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of Our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. For additional opt-out information, please review Our Terms of Service.
Customer Care
If you are experiencing any problems with the Messaging Service, please Contact Us and submit the form with details about your problem or your request for support, or email hello@hellocomfort.co.
Supplemental California Privacy Notice
This Supplemental California Privacy Notice only applies to Our processing of personal information via the Messaging Service that is subject to the California Consumer Privacy Act of 2018 ("CCPA"). The CCPA provides California residents with the right to know what categories of personal information We have collected about them and whether We have disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
| Category of Personal Information Collected by Us | Categories of Third Parties Personal Information is Disclosed to for a Business Purpose |
|---|---|
| Identifiers | • Service providers |
| Personal information categories listed in Cal. Civ. Code § 1798.80(e) | • Service providers |
| Commercial information | • Service providers |
| Internet or other electronic network activity | • Service providers |
| Inferences drawn from other personal information to create a profile about a consumer | • Service providers |
The categories of sources from which We collect personal information and Our business and commercial purposes for using personal information are set forth above and in Our primary privacy policy.
Additional Privacy Rights for California Residents
Individual Rights under the CCPA.
The CCPA provides California residents with the right to request:
- Access to Personal Information, including obtaining access to or a copy of your personal information.
- Deletion of Personal Information
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact Us at hello@hellocomfort.co. We will process such requests in accordance with applicable laws.
"Sales" of Personal Information under the CCPA. For purposes of the CCPA, unless otherwise stated in Our primary privacy policy, We do not "sell" personal information, nor do we have actual knowledge of any "sale" of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by Us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact Us at hello@hellocake.com.
Verification. When you make a request, We will ask you to provide sufficient information that allows Us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address or phone number associated with any personal information We have about you.
Primary Privacy Policy
By signing up to receive text messages from us, you also agree to Our Primary Privacy Policy. This Messaging Service Privacy Policy is strictly limited to the Messaging Service and does not limit or restrict any other privacy policy(ies) that may govern the relationship between you and Us in other contexts.