Privacy Policy

Data Protection Information GDPR

Duties of disclosure upon collection of personal data from the data subject in accordance with Article 13 paragraphs 1, 2, and 4, as well as Article 21 paragraph 3 of the EU General Data Protection Regulation (GDPR).

We have issued below its Privacy Statement in the light of the upcoming enactment of GDPR, the new data protection and privacy regulation of the European Union (EU). Privacy and security are very important to us. GDPR imposes high standards of personal data protection with extra-territorial reach which means that companies based outside the EU are, in certain circumstances bound by its provisions. We ask you to familiarize yourself with the Data Protection Information found below as well as our general Privacy Policy.

Data Protection Information

The following data protection information gives an overview of the collection and processing of your data. With the following information, we would like to give you an overview of how we will process your data and of your rights according to data privacy laws.

1. Who Is Responsible For Data Processing and How Can I Contact Them?

 

Data Protection Officer: 

Rubys, Inc.

809 Laurel St. #875

San Carlos, CA 94070

us@hellobeni.com

2. What Sources and Data Do We Use?

We process personal data you entered in our website, and information from your browser and connected devices. The sources of the data are our website, social media accounts, event management software, online surveys and any other related online sites.

If you choose to use social media account to log in or create an account, we have access to your name and email address from them.

For customer support and recruitment purposes we may also gather information from your web browser and partners including your mobile device information and computer / browser information. We use cookies in your browser to help identify you across time and partner sites.

3. What Do We Process Your Data for (Purpose of Processing) and On What Legal Basis?

We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR):

●  For enabling communications to you via your email and phone.

●  For providing curated professional introductions and content personalized for you.

●  As a result of your consent. You have to permit us to collect your information both on our websites and on your smartphone.

4. Who Receives My Data?

Your personally identifiable information (such as name, email address, phone number) are only available to our match-making service, to partners who send us your information when you signed up and to customer service if needed for support.

Your de-identified data (such as interaction with the service) are available to us and authorized staff at our site for the purposes of learning and improving the experience for everyone.

5. Will Data Be Transferred to a Third Country or an International Organization?

Your data is transferred outside of the EU - it is all securely stored and processed  in Shopify and by managed services at graph.cool and Prisma in the USA.

Please contact us if you would like to request to see a copy of the specific safeguards applied to the export of your information (Article 13 para 1f of the GDPR).

6. For How Long Will My Data Be Stored?

We will process and store your personal data for as long as it is necessary in order to fulfill our contractual and statutory obligations. 

7. What Data Privacy Rights Do I Have?

You have the right to access according to Article 8 FADP (Article 15 of the GDPR), the right to rectification according to Article 5 FADP (Article 16 of the GDPR), the right to erasure according to Article 5 FADP (Article 17 of the GDPR), the right to restrict processing according to Articles 12, 13, 15 FADP (Article 18 of the GDPR), the right of object according to Article 4 FADP (Article 21 of the GDPR), and if applicable – the right to data portability according to Article 20 of the GDPR. Furthermore, if applicable on you, there is also a right to lodge a complaint with an appropriate data privacy regulatory authority (Article 77 of the GDPR).

You can withdraw consent granted to us for the processing of personal data at any time. This also applies to withdrawing declarations of consent that were made to us before the GDPR came into force (i.e. before May 25, 2018). Please contact us if you would like to request to see, amend or request removal of your data.

Please note that the withdrawal only applies to the future. Processing that was carried out before the withdrawal is not affected by it.

8. Am I Obliged to Provide Data?

We are not able to provide personalized effective introductions without access to your information.

 

9. To What Extent Is There Automated Decision-Making?

We use automated decision-making pursuant to Article 22 of the GDPR in order to provide personalized introductions.

 

10. Will Profiling Take Place?

Information on Your Right of Objection According to Article 21 of the General Data Protection Regulation (GDPR)

You shall have the right of objection, at any time to processing of your personal data which is based on Article 6 paragraph 1 subparagraph e of the GDPR (data processing in the public interest) and Article 6 paragraph 1 f of the GDPR (data processing based on balancing interests). This also applies to profiling based on this provision in terms of Article 4 No. 4 of the GDPR.

If you object, please delete your account by cancelling and sending us an email asking us to delete your information. This will cease all information gathering and processing.

The GDPR policies are effective and were last updated on May 24, 2018. 

 

 

 

Updated as of May 24, 2018

 

Rubys, Inc. (“Company”) values your privacy and is committed to maintaining your trust.  We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received from users of websites located at https://shopify.webkul.com/multivendor/?sid=6225 and www.hellobeni.com(collectively referred to herein as the “Website”), and all of the Company’s other products and/or services, interactive features, widgets, and/or other online services that post a link to this Privacy Policy, and all content offered as a part thereof (the "Services"). 

 

Changes.   This Privacy Policy may be updated from time to time for any reason, at our sole discretion.  We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Website.  You are advised to consult this Privacy Policy regularly for any changes.

Incorporation into Terms of Service.   By using or accessing the Website or the Services, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. This Privacy Policy is incorporated into, and considered a part of, the Company’s Terms of Service.

Personal Information.   “Personal Information” may include, but is not limited to information that identifies you as an individual or relates to an identifiable person, such as name, postal address, telephone number, email address, etc.  Personal Information may also include things like your birthday, telephone number, photographs, personal images, or any beauty profile information you provide such as your hair color and eye color, or information about the products you purchase on our Website.

The Company does not collect any personal data from visitors to its website that is not voluntarily provided.  The Company only collects your Personal Information if you register for an account with the Company’s Website, when you use the Company’s Services, and when you send the Company communications in connection with your use of the Services. 

Use and Sharing of Personal Information.  We use the information we collect from our Website and your use of our Services to provide and improve existing Services; to develop new Services; and to protect you and the Company.  We also may use this information to offer you tailored content when you visit our Website.  We will not share your personal information with anyone except for our Company’s authorized service providers,[1] business affiliates,[2] and business partners[3] for business purposes; or unless we specifically inform you and give you an opportunity to opt out of our sharing your personal information.

 

In general, we may use and/or share your Personal Information: 

  • To respond to your inquiries and your requests regarding our Services.
  • To send you information regarding our services and changes to our terms, conditions, and policies.
  • To complete your registration, process your payments, and communicate with you regarding your purchase of our Services.
  • To send you marketing communication and newsletters about our Services.  The Company likes to keep its clients, personnel and other interested parties informed of legal developments of interest to them.  If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by emailing us@hellobeni.com.
  • To personalize your experience on our Website.
  • To inform you and allow you to participate in our promotions. 
  • To facilitate social sharing functionality.
  • To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services.
  • In connection with our business purposes, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or Services, expanding our business activities, etc.

We will not use and/or share your Personal Information:

  • To run interest-based advertising campaigns that collect personal data such as email addresses, telephone numbers, and credit card numbers.
  • To use or associate personal data with remarketing lists, cookies, data feeds, or other anonymous identifiers.
  • To use or associate targeting information, such as demographics or location, with any personal data collected from the ad or its landing page.
  • To share any personal data with Google or third party companies through our remarketing tag or any product data feeds which might be associated with our ads.
  • To send Google or third party companies precise location information without obtaining your consent.

However, we reserve the right to disclose Personal Information that we believe to be necessary or appropriate in the following circumstances:

  • As required by law, such as to comply with a subpoena, or similar legal process.
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • To enforce our Terms and Conditions.
  • To allow us to pursue available remedies or limit the damage we may sustain.

 

Personally Non-Identifiable Information:   We may collect personally non-identifiable information, including but not limited to demographic data, age, education level, profession, geographic location or gender, from you at the time of registration, or when you choose to use our Services. This information is not, by itself, sufficient to identify or contact you.  The Company may store such information, or it may be included in databases owned and maintained by partners, affiliates, agents, or service providers of the Company.  The Company may use such information and pool it with other information to track data related to growing the business, such as the total number of visitors to our Website and the domain names of our visitors' Internet service providers. 

 

Location-Based Information.   Our Service may use location-based services in order to locate you so we may verify your location, deliver you relevant content based on your location as well as to share your location with our vendors as part of the location-based services we offer. We may, from time to time provide settings in the Services that permit you to disable location-based services. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Users should carefully consider the use of such settings to improve information display options and to ensure the settings are properly set and functioning in the manner desired. Notwithstanding the availability of privacy preference settings, you should be aware that these settings are for convenience only, do not employ complex data security protection and may not be error free. However, please note that we will only directly provide third parties we work with access to your exact location information if you first give us permission to do so. You should consider the risks involved in disclosing your location information to other people.

 

Passively Collected Information:   Your visit to our Website may allow us to obtain certain additional, personally non-identifiable information that is collected passively using various technologies.  This information includes but is not limited to, for example, IP addresses, browser types, date and time of page views, location information associated with your IP address, domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or our services.  This information cannot presently be used to specifically identify you. 

 

Aggregated Personal Data:   The Company may analyze your personal data provided through the Website or in connection with rendering the Services, in aggregate form.   This aggregate information does not identify you personally.   We may share this aggregate data with our partners, affiliates, agents, or service providers for business purposes.   We may also disclose aggregated statistics to explain our Services to current and prospective business partners, and to other third parties for other lawful, business-related purposes.

 

Customer Credit Card Information.   The Company uses a third party payment processor, Stripe, to process payments on its Website.  Stripe uses and processes your payment information in accordance with Stripe’s Privacy Policy (https://stripe.com/privacy/).  The Company does not store or save your payment information, other than your zip code and country, which we require for billing and to comply with tax and other government regulations.

 

Tracking and Advertising.   The Company’s Website may use the foregoing technologies to track your activity on our Website:

  • Cookies.   When you visit our Website or otherwise interact with the Service, we may send one or more “cookies” to your computer or other devices.  Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience.  Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites.  Some features on this site will not function if you do not allow cookies.  We may link the information we store in cookies to any Personal Information that you submit while visiting our Website.
    We may use both session ID cookies and persistent cookies.  A session ID cookie expires when you close your browser.  A persistent cookie remains on your hard drive for an extended period of time.  Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site.
    Functional cookies, persistent and session type, store information to enable core site functionality, such as Live Chat and Client ID remembrance.
    Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.
    Advertising cookies may be set through our Website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.
    If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.
    If you reject cookies, you may still use our site, but some features on the site will not function properly.
  • Web Beacons.   Web beacons are electronic files that signal when a webpage, advertisement, video, other content, an email or newsletter has been viewed.  They are usually invisible to you.  We may use web beacons alone or in conjunction with cookies to compile information about our Service.  Web beacons may be used within the Service to track email open rates, web page visits or form submissions.  In some cases, we tie the information gathered by web beacons to your Personal Information to gauge the effectiveness of certain communications and our marketing campaigns.
  • Embedded Scripts.   An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
  • ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

 

Children.   The Website and our related Services are not intended for anyone under 13, and we do not knowingly collect information from anyone under the age of 13.  Anyone aged 18 or under should not submit any Personal Information without the permission of their parents or guardians.  By using the Website and our related Services, you are representing that you are at least 18 years old.

Links to Other Websites.   This Privacy Policy applies only to this Website and the Company’s Services.  It does not apply to any third-party sites.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including but not limited to our third party payment processor, Stripe, or any social media websites such as Facebook, Instagram, or Google.  The inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with accessing the Website or our Services.

Security.   We maintain reasonable and appropriate, although not infallible, security precautions.  However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts.  You should note that in using the Website and our related Services, your information will travel through third party infrastructures which are not under our control.  Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to us@hellobeni.com. 

Data Retention.   We will retain your Personal Information for as long as needed to provide the applicable Services, unless a longer retention period is required or permitted by law.

Do Not Track.   Your browser setting may allow you to automatically transmit a "Do Not Track" signal to websites and online service you visit.  The Company’s Website does not currently respond to "Do Not Track" signals or other mechanisms from a visitor's browser.  If, in the future, we create a program or protocol to respond to such web browser "Do Not Track" signals, we will inform you of the details of that protocol in this Privacy Policy.  To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.  You can also opt-out of some, but not all, online behavioral based advertising by using your browser settings to block cookies or notify you when a cookie is set.

Google AdWords.  This Website uses the Google AdWords in order to advertise on third party websites (including Google) to previous visitors to our site or to similar audiences online. This may result in you seeing an advertisement on the Google search results page, or a site in the Google Display Network.  Google may include in-ads notice labels to disclose interest-based advertising to their users.  Third-party vendors, including Google, use cookies to serve ads based on someone's past visits to the Website.  Any data collected will be used in accordance with our own privacy policy and Google's privacy policy. Google reserves the right to display to users which remarketing lists users are on, along with the corresponding domain name. You can set preferences for how Google advertises to you using the Google Ad Preference Manager (https://www.google.com/settings/ads/onweb/), and you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin. 

Analytics Software.   We and our third party tracking-utility partners use log files on our Service to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes.  Specifically, we analyze trends, administer the site, track users’ movements around the Website, and  gather demographic information about our user base as a in the aggregate. 

We use Google Analytics, which uses cookies and other, similar technologies to collect and analyze information about use of the Service and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Your California Privacy Rights.   Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.  As a courtesy, you may request and obtain from us once a year, free of charge, certain information about the personal data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.  If applicable, this information would include a list of the categories of personal data that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.  If you are a California resident and would like to make such a request, please submit your request in writing to us@hellobeni.com.

Facebook Connect/Open ID Providers.   You may log into your account on our Website (“Account”) and/or access our Services using sign-in services such as Google, Facebook, Instagram, Pinterest, or another third party Open ID provider.  These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our registration form. 

When you log into your Account on our Website via services like Facebook Connect in particular, you have the option to post information about your activities on this Website to your profile page to share with others within your network if you so choose.  This may result in information being collected or shared between us and the third party, Facebook.  For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook.

Your Account on our Website.  Our online social member-only community (the “Community”) allows you to participate in asking for recommendations of products or Services, “Like” products, add comments, follow other members in the Community, provide ratings and reviews, and to receive product recommendations.

If you select a nickname when you affirmatively choose to be a part of the Community, a public profile page (“Profile”) containing your nickname will be visible to everyone.

Some of the information you provide in association with the Community may also be seen by everyone visiting your Profile, whereas other information can only be seen by you when you visit your Profile, as indicated below:

 

Information Seen Only by You When Visiting Your Profile:

  • Personal traits such as skin concerns and hair concerns.  Please note, even though your skin concerns and hair concerns are only visible to you when you visit your Profile, they will also be public if you submit a rating and review of a product.
  • Race; and
  • Zip code.

 

Additional Information Seen by Everyone Else Visiting Your Profile:

  • Profile and banner photo;
  • Nickname;
  • Number of people that you follow and who follow you;
  • "About You" content created by you;
  • Your Instagram/YouTube handles shared by you;
  • Skin tone and type, hair color and type, eye color, age group, etc;
  • Any conversations in which you may have participated on our Website;
  • Any reviews of your recent purchases;
  • Information regarding your lifestyle that you volunteer; and
  • Any products that we recommended for you.

 

You can update or correct your Personal Information such as your name, e-mail address, and your general preferences by logging into your Account and clicking on the “My Account” page.

 

Public Forum on our Website.   Our Website offers publicly accessible message boards, blogs, and community forums to which you and other users of the Website and/or Services (“User(s)”) may contribute.  You may submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, "User Content"), such as on profiles, blogs and message boards.  We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed), and may or may not attribute it to you. 

Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that the Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure.  Our promises regarding handling of your Personal Information under this Privacy Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Website. We are not responsible for the accuracy, use, or misuse of any User Content that you disclose or receive from third parties through the Website.

To request removal of your Personal Information from our blog or community forum, contact us at  us@hellobeni.com.  In some cases, we may not be able to remove your Personal Information, especially if it was already re-posted by another user.  If this is the case, we will let you know if we are unable to do so and why in response to your request.

Referrals.   If you choose to use our referral service to tell a friend about our Services by email, we will ask for your friend’s email address, and send your friend a one-time email inviting them to visit our Website and inform them of our Services.  We will only stores your friend’s email address for the sole purpose of sending this one-time message and tracking the success of the referral program. Your friend may contact us at us@hellobeni.com to request that we remove this information from our database at any time.

If you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. 

Testimonials, Ratings and Reviews.  If you submit testimonials, ratings, or reviews of the Services directly on our Website, any Personal Information you include will be displayed on the Website.  We may also partner with third-party service providers to collect and display ratings and review content on our Website.  If you provide our third-party service providers with your Personal Information in the process of submitting your rating and review, the content and Personal Information collected by a third party will be posted on our Website, absent your express instruction not to do so.  If you want your testimonial, rating, or review removed from our Website at any time, please contact us at us@hellobeni.com.

Opt-Out/Unsubscribe Policy.   If, at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at us@hellobeni.com.  Additionally, you can click on the “unsubscribe” link at the bottom of any promotional e-mail that you receive.  You can also edit your e-mail preferences on your “My Account” page.

Contact Us.   If you have any questions or concerns relating to our use of your Personal Information, please email us@hellobeni.com.  Additionally, you may reach us by postal mail at:

Rubys, Inc.

809 Laurel Street, #875

San Carlos, CA, 94070

  

[1] Authorized service providers are companies that perform certain services including, but not limited to, fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analyses, supporting the functionality of the Services, and supporting contests, sweepstakes, surveys and other features we offer, on our behalf.  These service providers may have access to your Personal Information, but to the extent necessary to perform or fulfill their business purpose.  We do not permit them to share or use any of your Personal Information for any other purpose.

[2] Affiliate businesses are those businesses with whom we may affiliate to sell our products or Services.  We may share information we collect, including Personal Information, with affiliated businesses.  Sharing such information with our affiliates enables us to provide you with information about a variety of products and Services that might interest you.  We instruct all affiliated businesses to comply with applicable privacy and security laws and, at a minimum, in any commercial e-mail they send to you, to give you the opportunity to choose not to receive such email messages in the future.

[3] Business partners are typically merchants offering the products, services, promotions, contests and/or sweepstakes in connection with or somehow related to our own products and Services.  We will not share your Personal Information with business partners unless you choose to participate in their offer or program.  When you choose to engage in a particular offer or program, you authorize us to share your email address and other Personal Information with the relevant business partner.

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