Privacy policy

Effective date: August 19, 2026

We respect your privacy and are committed to protecting your personal data when you visit or use our online store, including any mobile or device-specific version of the store, place an order, create an account, subscribe to a recurring delivery, sign up for our emails, or otherwise communicate with us, including through our official accounts on social media (collectively, the “Store” or the “Services”).

When we use the term “personal data”, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or another identified or identifiable person.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use, and disclosure of your personal data as described in this Privacy Policy.

If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy controls with respect to the collection, processing, and disclosure of your personal data.

Contents:

1. Who we are

The data controller responsible for processing your personal data is UmiGlow Inc (red. no. 10615905), registered at 3500 South Dupont Highway, Dover, DE 19901, County of Kent, the United States of America (“we”, “us”, or “our”).

If you have any questions about this Privacy Policy and want to know more about how we handle your personal data, please contact us:

By mail to: 3753 Howard Hughes Parkway, Suite 200, Las Vegas, Nevada, the United States of America

By email to: support@frooji.com

2. What personal data we process

We collect personal data from the following sources:

  • Information you provide directly to us (for example, when you place an order, create an account, subscribe to recurring deliveries, sign up for our emails, or contact our support team);
  • Information we receive from our service providers or third parties (such as our payment processors, fulfillment and delivery partners, and our analytics and advertising partners);
  • Information collected automatically when you visit or use the Store, including through cookies and similar technologies.

You are under no obligation to provide us with personal data. However, certain personal data is necessary for us to provide the Services. For example, we need your shipping address to deliver your orders. You may not be able to access or use certain Services if you do not provide the information required for those Services.

When you use our Services, we collect the following categories of information from you:

2.1. Information you provide directly to us

Identifiers and contact details. When you place an order, create an account, sign up for our emails, or contact us, you provide identification and contact information such as your name, email address, phone number (where you choose to provide it), and your address.

Account information. If you create an account, we process your account credentials (username and password), your saved addresses, your saved preferences and settings, and your order history. You may also be able to check out as a guest without creating an account.

Order and delivery information. When you purchase from the Store, we process the products you order, order and invoice numbers, quantities, prices and discounts applied, promotional or discount codes you use, delivery address, delivery instructions and delivery status, and details of any returns, exchanges, cancellations or refunds.

Subscription information. If you sign up for a recurring delivery, we process your subscription plan, delivery frequency, next scheduled billing and shipment dates, subscription status, and details of any pause, reactivation or cancellation.

Marketing preferences. If you subscribe to our email marketing, we process your email address together with your consent or preference record.

Customer service and feedback. When you contact us through any support channel we make available, we process your contact details, the content of your message, any attachments, and our correspondence with you. We also process any feedback or survey responses you choose to submit.

2.2. Information we receive from our service providers or third parties

Payment information. Payments are processed through Shopify Payments. Shopify processes your payment and transaction information to provide the payment services, including to process transactions and refunds and to screen transactions for fraud and compliance purposes. Shopify engages one or more payment processors to provide these services. An applicable payment processor may also process personal information as an independent controller for certain activities, including know-your-customer and anti-money laundering checks, sanctions screening, and compliance with other legal or regulatory obligations. In those circumstances, the payment processor’s own privacy notice applies. Information about the payment processors used by Shopify Payments and their privacy notices is available in Shopify’s Payment Processor List.

Our payment providers confirm to us whether a payment succeeded or failed and provide limited payment data such as the payment method type and the last four digits of your card. We use this limited financial information to fulfil and manage your order and any subscription, to process refunds and handle chargebacks, to detect and prevent fraud, and to keep the accounting and tax records we are required to keep. We do not collect, store, or have access to your full payment card number or your card security code.

Shipment information. Our fulfillment provider and carriers provide us with shipment, tracking, and delivery-status information, and information about failed deliveries or returned parcels.

Store interaction and merchant-network data. We receive information from Shopify relating to your interactions with the Store, and, where we use Shopify’s enhanced merchant features, information derived from Shopify’s wider merchant network.

2.3. Information collected automatically

Device and connection data. We collect information about the device and connection you use to access the Store, such as your IP address, device type and model, operating system, browser type and language, screen and window characteristics, time zone, referring URLs, etc.

Usage and browsing data. We collect information about how you interact with the Store, including pages and products viewed, search terms entered on the Store, links clicked, items added to or removed from your cart, checkout steps started and completed, session duration, dates and times of access, and error or crash information.

Cookies and similar technologies. We and our service providers use cookies, pixels, tags, software development kits (SDKs), local storage, and similar technologies to operate the Store, remember your preferences, measure performance and, where permitted, deliver and measure advertising. We use the following categories:

  • Required. Strictly necessary to operate the Store and to provide the features you request, including maintaining your session, keeping items in your cart, enabling secure checkout and login, load balancing, and protecting against fraud and abuse. These cannot be switched off through our cookie controls.
  • Personalization. Remember your choices and settings, such as your language, region, and previously entered information to personalize your next visit to the Store.
  • Analytics. Help us understand how you interact with the Store. We use this data to identify areas to improve.
  • Marketing. Set by us or by our partners, including Shopify, to optimize marketing communications and show you ads on other websites.

Where required by applicable law, we place cookies and similar technologies that are not strictly necessary on the basis of your consent, which we collect through our cookie banner and preference center. You can withdraw or change your choices at any time. Depending on your jurisdiction, you can manage non-essential cookies and similar technologies through our cookie banner, “Your Privacy Choices” link in the Store footer, and through your browser settings, which allow you to block or delete cookies. You can also use the industry opt-out tools below, which are operated by third parties and not by us:

Refusing or withdrawing consent to non-essential technologies may reduce personalization and measurement, but will not prevent you from browsing the Store or placing an order.

2.4. Sensitive and special category data

We do not ask you for, and the Services are not designed to collect sensitive or special category personal data. Because we sell functional beverage products that we market by reference to general wellness benefits, information about the products you purchase, browse, or subscribe to may, in some circumstances, be capable of supporting an inference about your interest in a health-related outcome. We do not use your purchase or browsing data to infer any medical condition, diagnosis, treatment, or other health status.

3. How we use your personal data

We will only use your personal data as permitted by law. The “legal basis” identified below is the basis on which we rely where the EU General Data Protection Regulation (“GDPR”) or the UK GDPR applies to our processing. Where you are located outside the European Economic Area (“EEA”) and the United Kingdom (the “UK”), we process your personal data as described in this Privacy Policy and as permitted by the laws applicable to you.

3.1. Selling and delivering our products

What this means for you: We use your data to accept and process your order, take payment, arrange packing and shipping, provide tracking, keep you informed about your order, and handle returns, exchanges, cancellations and refunds.

Data categories used: Identifiers and contact details, order and delivery information, payment information, shipment information.

Legal basis: Performance of a contract with you.

3.2. Managing your account

What this means for you: We create and administer your account, authenticate you, keep your account secure, store the addresses and preferences you save, and show you your order history.

Data categories used: Identifiers and contact details, account information, order and delivery information.

Legal basis: Performance of a contract with you.

3.3. Managing subscriptions and recurring billing

What this means for you: If you subscribe to recurring deliveries, we use your data to schedule and take recurring payments, prepare each shipment, notify you before an upcoming renewal or shipment where required, and process pauses, reactivations, and cancellations.

Data categories used: Identifiers and contact details, subscription information, order and delivery information, payment information, shipment information.

Legal basis: Performance of a contract with you. Compliance with legal obligations (for renewal and cancellation notices required by law).

3.4. Customer support and responding to you

What this means for you: We use your data to answer your questions, investigate and resolve issues with an order or a product, and keep a record of our correspondence so that we can help you consistently.

Data categories used: Identifiers and contact details, customer service and feedback, order and delivery information, payment information, shipment information.

Legal basis: Performance of a contract with you where your request relates to an order or subscription. Our legitimate interests where you contact us without having placed an order (our interest is in responding to people who contact us and keeping records of those interactions).

What this means for you: We send you messages you need to receive, such as order confirmations, shipping and delivery notifications, subscription renewal and payment notices, password resets, product recall or safety notices, and notices about changes to our Terms of Service or this Privacy Policy. These are not marketing messages and you cannot opt out of them while you have an active order, subscription, or account.

Data categories used: Identifiers and contact details, order and delivery information, subscription information, account information, payment information, shipment information.

Legal basis: Performance of a contract with you. Compliance with legal obligations.

3.6. Marketing communications

What this means for you: With the appropriate legal basis, we send you promotional emails about new products, offers, and news. Every marketing email contains an unsubscribe link.

Data categories used: Identifiers and contact details, marketing preferences, usage and browsing data.

Legal basis: Consent where consent is required by law. Our legitimate interests in promoting our products to existing customers about similar products, where applicable law permits marketing on that basis and you have not objected

3.7. Personalizing the Store and our offers

What this means for you: We use what we know about your purchases and browsing to recommend products, remember items you were interested in, show you relevant content on the Store, and send you offers that are more likely to be useful, for example, reminding you about a cart you left behind.

Data categories used: Identifiers and contact details, store interaction and merchant-network data, device and connection data, usage and browsing data.

Legal basis: Consent  where personalization relies on cookies or similar technologies requiring consent. Our legitimate interests in presenting a relevant store experience to our customers.

3.8. Analytics and improvements to Services and the Store

What this means for you: We analyze how the Store is used to understand what works and what does not, fix errors, test changes, decide which products and flavors to develop, and plan our stock and operations. Where we run A/B tests, different visitors may see different versions of a page.

Data categories used: Store interaction and merchant-network data, device and connection data, usage and browsing data, customer service and feedback.

Legal basis: Consent where analytics relies on cookies or similar technologies requiring consent. Our legitimate interests in understanding and improving our own products and Store.

3.9. Security, fraud prevention and abuse

What this means for you: We use your data to secure the Store and your account, verify that orders are genuine, detect and investigate fraudulent payments, promotion abuse, and other unlawful or harmful activity, and protect our customers, our staff, and our business.

Data categories used: All categories.

Legal basis: Our legitimate interests in protecting the Store, our customers and our business against fraud and misuse. Compliance with legal obligations.

3.10. Payment disputes and chargebacks

What this means for you: If a payment is disputed or a chargeback is raised, we process order records, payment records, delivery and tracking evidence, account activity and correspondence to investigate the dispute and to respond to the payment provider or card scheme.

Data categories used: All categories, with emphasis on order and delivery information, payment information, payment information, device and connection data, customer service and feedback.

Legal basis: Our legitimate interests in defending against unfounded claims and evidencing that we delivered what was ordered. Performance of a contract. Compliance with legal obligations.

What this means for you: We use your data to comply with the laws that apply to us, including tax, accounting, consumer protection, product safety and data protection law, to keep records we are required to keep, and to respond to valid requests from courts, regulators and law enforcement.

Data categories used: All categories.

Legal basis: Compliance with legal obligations.

What this means for you: We process your data to enforce our Terms of Service and other policies, to bring or defend legal claims, and to take part in dispute resolution, litigation or regulatory proceedings.

Data categories used: All categories.

Legal basis: Our legitimate interests in protecting our legal rights. Compliance with legal obligations.

3.13. Corporate transactions

What this means for you: If we buy, sell, restructure, merge or finance all or part of our business, we may process and disclose your data as part of that transaction.

Data categories used: All categories.

Legal basis: Our legitimate interests in carrying out corporate transactions. Compliance with legal obligations.

4. How we disclose your personal data

4.1. Disclosing your personal data to companies within our group

Your personal data will be disclosed to companies within our corporate group in accordance with applicable data protection laws and the terms of this Privacy Policy, for the following purposes:

  • Ensuring uninterrupted business processes;
  • Obtaining legal, compliance, or financial assistance;
  • Fulfilling our regulatory obligations;
  • Conducting reporting and overseeing group activities;
  • System maintenance support and hosting of data; and
  • Maintaining business continuity in the event of a merger or takeover.

Entities within our group are required to implement appropriate technical and organizational measures, including security measures, to safeguard your personal data.

4.2. Disclosing your personal data to our service providers and partners

We may disclose your personal data to our service providers and partners. They process certain personal data on our behalf to achieve the purposes listed above. We enter into contracts with our service providers and ensure that they appropriately protect your personal data. We engage service providers for the following services:

a. E-commerce platform, hosting, and infrastructure

Our Store is hosted by Shopify, which collects and processes personal data about your access to and use of the Services in order to provide and improve the Services for you. Information you submit to the Services will be transmitted to and shared with Shopify as well as third parties that may be located in countries other than where you reside, in order to provide and improve the Services for you. In addition, to help protect, grow, and improve our business, we use certain Shopify enhanced features that incorporate data and information obtained from your interactions with our Store, along with other merchants and with Shopify. To provide these enhanced features, Shopify may make use of personal data collected about your interactions with our Store, along with other merchants, and with Shopify. In these circumstances, Shopify is responsible for the processing of your personal data, including for responding to your requests to exercise your rights over use of your personal data for these purposes.

To learn more about how Shopify uses your personal data and any rights you may have, you can visit the Shopify Consumer Privacy Policy.

Depending on where you live, you may exercise certain rights with respect to your personal data here Shopify Privacy Portal.

b. Payment processing, wallets, and fraud screening

Our payment providers process your payment, screen transactions for fraud, and handle refunds and chargebacks.

c. Fulfillment, warehousing, and delivery

Our fulfillment provider picks, packs, and dispatches your order, and carriers deliver it and provide tracking and delivery-status information. We disclose your name, delivery address, contact details, and order contents for this purpose.

d. Subscription management

If you subscribe to recurring deliveries, a subscription management application processes your subscription plan, schedule and billing status.

e. Email, marketing, and customer messaging platforms

These providers send our transactional and marketing emails, manage subscriber lists and preferences, and measure engagement.

f. Analytics and Store measurement

These providers help us understand how the Store is used and how it performs.

g. Advertising

These partners deliver our advertisements, build and match audiences, and measure conversions. They generally act as independent controllers or as third parties for their own purposes, and their processing may constitute a “sale” or “sharing” of personal information under U.S. state privacy laws.

For example, we use Shopify to support personalized advertising with third-party services based on your online activity with different merchants and websites. Our business and marketing partners will use your information in accordance with their own privacy notices. Depending on where you reside, you may have a right to direct us not to share information about you to show you targeted advertisements and marketing based on your online activity with different merchants and websites.

h. Customer support tooling

Where we use a helpdesk, ticketing or live-chat tool, that provider processes your correspondence with us.

i. Professional advisers and auditors

We disclose personal data to our lawyers, accountants, auditors, and other professional advisers where necessary for them to advise us or to protect our legal interests.

j. Corporate and IT service providers

These include providers of business productivity, communications, document storage, security, and IT management tools used by our team.

4.3. Disclosing your personal data to statutory authorities

We will disclose your personal data when it is required by applicable law in the following cases:

  • To comply with a request for information from law enforcement agencies, regulatory agencies, and other public and government authorities;
  • To comply with a court order to disclose your personal data;
  • To protect our rights, privacy, safety, or property, or those of our group companies, you, or others, and to establish, exercise, or defend a legal claim; and/or
  • In other cases provided for by law.

4.4. Disclosing your personal data in other circumstances

As we develop our business, we may buy or sell assets or business offerings. Your personal data is generally one of the transferred business assets in these types of transactions. We may also disclose such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. If any such transfer occurs, the party who acquires the data will assume the rights and obligations described in this Privacy Policy. Where required by applicable law, we will notify you of any such transaction and of any resulting change in the identity of the controller of your personal data.

5. International data transfers

We are established in the United States, and personal data you provide to us will be processed in the United States. As a multinational business, we may also transfer, store and process personal data in other countries where we or our service providers operate.

If you are in the EEA or the UK, the laws of the countries to which your personal data is transferred may not provide the same level of protection as the laws of your own country. Where we transfer personal data out of the EEA or the UK, we rely on one of the following safeguards:

  • Adequacy decision. We may transfer personal data to a third country that has received an official determination of “adequacy” from the relevant regulatory authorities. For more information about “adequacy decisions” for the European Economic Area, click here. For more information about “adequacy regulations” for the United Kingdom, click here.
  • Appropriate safeguards. We establish appropriate safeguards by using binding, standard data protection clauses adopted by the relevant regulatory authorities. These clauses are enforceable by data subjects within the United Kingdom and/or the European Economic Area. For more information about the Standard Contractual Clauses for the European Economic Area and United Kingdom, click here. For more information about the international data transfer addendum and international data transfer agreement for the United Kingdom, click here.
  • Derogations. Depending on the circumstances, we may also collect and transfer personal data based on specific derogations, such as your explicit consent, the necessity of performing a contract involving you, important reasons of public interest, or the establishment, exercise, or defense of legal claims.

If you want further information on the specific transfer mechanism used by us when transferring your personal data, please contact us.

6. Data security

We implement appropriate technical and organizational security measures to protect your personal data against theft, loss, or unauthorized access. These include the security features of our platform, encryption of data in transit, access controls limiting access to those who need it, and the use of payment providers that process card data so that we do not hold full card numbers.

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee absolute security. If you have an account, you are responsible for keeping your credentials confidential, and you should not share your username or password with anyone. If you believe your account has been compromised, contact us immediately.

7. Data retention

We do not retain your personal data longer than necessary. The duration for which we keep your personal data varies depending on many factors. To determine the appropriate retention period for personal data, we consider the volume, nature, and sensitivity of the personal data, the risk of harm from unauthorized use or disclosure, the processing purposes, and whether these purposes can be achieved by other means, along with legal requirements.

When determining the relevant retention periods for your personal data, we will take into account factors including:

  • Legal obligations under applicable law;
  • Our legitimate interests (e.g., to protect our business against potential legal claims);
  • Guidelines issued by relevant data protection authorities.

When we no longer need to keep your personal data, we delete or anonymize it in accordance with applicable security standards so that it can no longer be linked back to an individual.

You can request information about the retention period applicable to you by contacting us.

8. Your rights

Depending on where you live, you may have some or all of the rights described below. These rights are not absolute, apply only in certain circumstances, and in some cases we may decline a request as permitted or required by law.

  • Right to access. You have the right to confirm whether we process personal data about you and receive a copy of that data, together with information about how we use it.
  • Right to rectification. You may ask us to correct personal data about you that is inaccurate and to complete data that is incomplete. If you have an account, you can update much of this information yourself in your account settings.
  • Right to erasure. You have the right to ask us to delete your personal data in certain circumstances. We will do so where the law requires, but we may need to retain certain data (for example, order, payment and tax records).
  • Right to restriction of processing. You have the right to ask us to restrict the processing of your personal data in certain circumstances, but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to object. You have the right to object to processing where we process your data based on our legitimate interests. Please note that in some cases, we may demonstrate that we have legitimate grounds to process your data which override your rights and freedoms.
  • Right to data portability. You have the right to receive the personal data you have given us in a structured, commonly used, and machine-readable format, and, where technically feasible, to transmit it to another controller.
  • Right to withdraw consent. When we rely on consent to process your personal data, you have the right to withdraw your consent at any time. You can unsubscribe from marketing emails at any time using the unsubscribe link in any such email. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.
  • Right not to be subject to automated decision-making. We do not make decisions about you that produce legal effects or similarly significantly affect you based solely on automated processing.
  • Right to complain. You can lodge a complaint about the way we process your personal data with the relevant data protection authority, particularly in the country where you habitually reside, work, or believe an infringement has occurred. We would like the opportunity to resolve any concern you have about how we handle your personal data, so please contact us first. This does not affect your right to complain to a regulator.

To exercise any of your privacy rights described above, please contact us:

  • Response times. We are committed to responding to all legitimate requests in accordance with applicable privacy laws and will process your request as promptly as possible, generally within one month under the GDPR and UK GDPR.
  • Identity verification. To protect your personal data, we need to be reasonably confident that a request comes from you or from someone authorized to act for you. We may ask you to confirm information we already hold and, where the request is high-risk and we cannot otherwise verify you, we may ask for further proof of identity. We ask for as little information as possible, use it only to verify the request, and delete it afterward unless we are required to keep a record of the request. If we cannot verify your identity, we may not be able to act on your request, and we will explain why.
  • Authorized representative. You may use an authorized representative to make a request on your behalf. We will ask the representative to provide proof that you have authorized them, such as a signed permission or a valid power of attorney. We may also contact you directly to confirm the authorization and to verify your identity.
  • No fee, no discrimination. Exercising your rights is free, unless your request is manifestly unfounded or excessive, in which case applicable law may allow us to charge a reasonable fee or to refuse the request. We will not discriminate or retaliate against you for exercising your privacy rights.

9. Children

The Services are not intended to be used by children, and we do not knowingly collect any personal data about children under the age of majority in your jurisdiction. If you are the parent or guardian of a child who has provided us with their personal data, you may contact us using the contact details set out below to request that it be deleted. As of the effective date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal data of individuals under 16 years of age.

10. Regional disclosures

Depending on where you live, you may have specific privacy rights that apply to you. The following disclosures are intended to supplement the rest of this Privacy Policy and provide additional information about those rights and other information relevant to data subjects located in the following jurisdictions.

10.1. U.S. States Privacy Notice

Applicability

This U.S. States Privacy Notice supplements the rest of this Privacy Policy and provides the disclosures required by U.S. state consumer privacy laws. It applies to you if you are a resident of a state that has enacted such a law, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, and additional states as their laws come into force.

For California residents, this U.S. States Privacy Notice also serves as our Notice at Collection and as our CCPA privacy policy.

The rights and obligations described in the U.S. States Privacy Notice apply only to the extent the relevant state law applies to us and to the personal information in question, and each state’s law contains its own definitions, thresholds, and exemptions. The definition of “personal information” varies between states. Generally it means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household.

Categories of personal information we collect

Sections 2 “What personal data we process” and 3 “How we use your personal data” of the Privacy Policy outline the categories of personal information we collect, along with the sources and purposes of such processing. We may also process de-identified data, ensuring it cannot reasonably be linked back to you. We commit to maintaining and using de-identified data responsibly and will not attempt to re-identify such data unless required to validate our de-identification measures.

Sensitive personal information

We do not collect sensitive personal information for the purpose of inferring characteristics about you, and we do not sell or share sensitive personal information. If you voluntarily include health or other sensitive details in a message to us, we use them only to respond to you.

What personal information we disclose

Certain U.S. state privacy laws require us to provide the categories of personal information that we have disclosed to third parties for business purposes over the past 12 months. During this period, we have disclosed all categories of personal information outlined in Section 2 “What personal data we process” of the Privacy Policy for business purposes. For example, we may disclose personal information to service providers that assist us with cloud hosting, technical infrastructure, and log management.

We do not sell personal information in exchange for money. Several state laws define “sale”, “share”, and “targeted advertising” broadly enough to capture the use of cookies, pixels, and similar technologies. We treat these activities as a sale or sharing of personal information and as targeted advertising, and we offer you the right to opt out.

We do not knowingly sell or share the personal information of consumers under 16 years of age, and we do not knowingly engage in targeted advertising directed to them.

Your privacy rights

Subject to the law of your state, you may have the following rights:

  • Right to know and to access. To know the categories of personal information we collect, the sources, the purposes, the categories of third parties to whom we disclose, sell, or share it, and to obtain the specific pieces of personal information we hold about you, generally for the 12 months preceding your request.
  • Right to delete. To request deletion of the personal information we collected from you, subject to the exceptions in applicable law.
  • Right to correct. To request correction of inaccurate personal information we maintain about you.
  • Right to data portability. To obtain a copy of your personal information in a portable and, where technically feasible, readily usable format.
  • Right to opt out of sale, sharing and targeted advertising. Depending on where you reside, you may have a right to opt out of the “sale” or “share” of your personal information or to opt out of the processing of your personal information for purposes considered to be “targeted advertising”, as defined in applicable privacy laws. You can exercise your rights to opt-out by using the “Your Privacy Choices” link in the Store footer. You may also enable the Global Privacy Control signal in a supporting browser or extension. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.
  • Right to limit the use and disclosure of sensitive personal information. Where applicable, you have this right. As explained, we do not use sensitive personal information for purposes that trigger this right.
  • Right to opt out of profiling. To opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not carry out such profiling.
  • Right to withdraw consent. Where we rely on your consent, you have the right to withdraw your consent for data collection and sharing.
  • Right to appeal. To appeal a decision we make on your request, as described below.
  • Right to non-discrimination. To exercise your rights without being denied goods or services, charged a different price, or provided a different level of quality, except as permitted by law in connection with a lawful financial incentive.

To exercise any of the available privacy rights, please contact us:

  • Response times. We are committed to responding to all legitimate requests in accordance with applicable privacy laws and will process your request as promptly as possible, generally within 45 days under U.S. state privacy laws.
  • Identity verification. To protect your personal information, we need to be reasonably confident that a request comes from you or from someone authorized to act for you. We may ask you to confirm information we already hold and, where the request is high-risk and we cannot otherwise verify you, we may ask for further proof of identity. We ask for as little information as possible, use it only to verify the request, and delete it afterward unless we are required to keep a record of the request. If we cannot verify your identity, we may not be able to act on your request, and we will explain why.
  • Authorized agents. You may use an authorized agent to make a request on your behalf. We will ask the agent to provide proof that you have authorized them, such as a signed permission or a valid power of attorney. We may also contact you directly to confirm the authorization and to verify your identity.
  • Appeals. If we decline your request, you may appeal by replying to our decision or emailing us with the subject line “Privacy Request Appeal”, explaining why you believe our decision was wrong. We will inform you in writing of our decision on the appeal and our reasons within the period required by your state’s law. If your appeal is denied, you may contact the Attorney General of your state to submit a complaint.
  • California “Shine the Light”. California residents may request, once per calendar year, a list of the third parties to whom we disclosed their personal information for those third parties’ own direct marketing purposes during the preceding calendar year. To make a request, email us with “Request for California Shine the Light Privacy Information” in the subject line, and include your state of residence and the email address associated with your orders.

Data retention

Section 7 of the Privacy Policy describes how long we keep personal information. In summary, we retain each category of personal information for as long as reasonably necessary for the purposes described, unless a longer period is required or permitted by law. This may include retaining information to comply with tax and accounting obligations, resolve disputes, enforce our agreements, or protect against fraudulent or unlawful activity.

11. Notice of financial incentive

This notice of financial incentive applies only to California residents. Because the discount is offered in exchange for personal information, California law treats it as a “financial incentive”. This notice explains the terms, so you can decide whether you want to take part.

11.1. What we offer

When you give us your email address through a sign-up form, we provide you with a one-time discount code for your first eligible order, in the amount stated in the offer. We also add you to our marketing email list, so you will hear from us about new products, offers and tips.

11.2. What personal information is involved

To take part, you give us one category of personal information: identifiers (your email address).

We use your email address to send you marketing emails. We share it with the service providers that operate our store and send our emails.

11.3. Material terms

  • The offer is open to new email subscribers who have not previously received our code.

  • The code provides a one-time discount on your first eligible order, in the amount stated in the offer.

  • It cannot be combined with other promotional codes.

  • The discount applies to one-time purchases only and does not apply to subscription orders.

  • Any additional limitations or expiration terms, if applicable, will be stated in the offer.

  • Taking part is entirely voluntary. You can shop without giving us your email address for marketing. Apart from this discount, you will receive the same products, prices, and level of service if you choose not to take part or later change your mind.

11.4. How to opt in

Enter your email address in the sign-up form offering the discount and submit the form. Submitting the form is how you opt in to this offer and agree to receive our marketing emails.

11.5. How to withdraw

You can withdraw at any time, free of charge, by clicking the unsubscribe link at the bottom of our marketing email. If you withdraw, we will stop sending you marketing emails. Any discount code we have already provided to you remains subject to the terms stated in the offer. Withdrawing has no effect on the price you pay, the products available to you, or the quality of service you receive.

11.6. Why the discount is reasonably related to the value of your data, and how we calculated it

We estimate the value of your email address to us as equivalent to the value of the discount we give you in exchange for it: the discount stated in the offer you responded to.

In making this assessment we took into account, among other things: the value of the offer itself (the discount we give up in exchange for your email address); the revenue we anticipate from marketing to a subscriber over the period we keep their information; the expenses we anticipate in collecting, storing, securing, and using that information, including the fees we pay the service providers that host our store and send our email; and the expenses we anticipate in offering and administering the incentive, including issuing and honoring discount codes. Our email program is new, so these are anticipated figures.

Based on this analysis, we consider the value of the personal information to be reasonably related to the value of the benefit offered. We review this assessment whenever we change the offer, and at least once a year.

11.7. Your rights

California residents have the privacy rights specified in Section 10.1 above. We will not discriminate against you for exercising any of these rights. To make a request, please contact us.

12. How to contact us

If you have any questions about the Privacy Policy or our privacy practices, or if you would like to exercise any of your rights, contact us at:

By mail to: 3753 Howard Hughes Parkway, Suite 200, Las Vegas, Nevada, the United States of America

By email to: support@frooji.com

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. When we do, we will post the revised policy on the Store, update the “Effective date” at the top, and, where the changes are material, provide additional notice as required by applicable law. We encourage you to review this Privacy Policy periodically. Your continued use of the Services after a revised Privacy Policy takes effect means you are aware of the changes.