Privacy Policy

Effective date:   July 8, 2024
 
This Privacy Policy describes Sudsies, Inc.’s policies and procedures on the collection, use and disclosure of Your personal information (PI) and/or personal data (PD)  when you access and use our website, www.sudsies.com (“SITE”) to avail yourself of our drycleaning and laundering services (“Services”).  It describes how and why we might collect, store, use and/or share (“process”) your PI/PD such as when you:
 
  • Visit our SITE at http://www.sudsies.com or any website of ours that links to the privacy privacy;
  • Download and use our mobile application, if any, or any other application of ours that links to this privacy notice; and 
  • Engage with us in other related ways including any purchase of our drycleaning, laundering, and/or clothes alteration services either via the Site or at our physical location(s). 
 
Questions or Concerns?
 
Reading this Privacy Policy will help you understand your privacy rights and choices.  If you do not agree with our policies and practices, please do not use our Services.  If you still have any questions or concerns, please contact us at privacy@sudsies.com.  If you choose to order and pay for Services through the Site, you are agreeing with the terms with this Privacy Policy. 
 
SUMMARY OF KEY POINTS
 
This summary provides key points from our privacy policy, but you can find out more details about these topics by referring to our table of contents below to find the section you are looking for.  
 
What PI/PD do we process?  We process the information that is required to fulfill any services ordered by you based on the choses you make and services/features you use.  By accessing and using one or more of the Services, you agree to the collection and use of your PI/PD in accordance with this privacy policy.
 
Do we process any sensitive personal information?  We do not process any sensitive personal information.  We use Your PI/PD to provide and improve our Services. By accessing and using one or more of the Services, you agree to the collection and use of Your PI/PD in accordance with this Privacy Policy.
 
Do we collect any information from third parties?  We do not collect information from third parties except as to how that information may relate to our usage of third-party payment sites through which a Site visitor may pay for his/her selected services. 
 
How to We Process Your Information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law.   We process your information only when we have a valid legal reason to do so. 
 
In what situations and with which parties do we share personal information?  We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.  We do not share your information with third parties.  
 
We disclose your information to third parties only as reasonably required to fulfill your requests for our Services and collect sums due (such as to credit card processors), to protect the rights and safety of us, our shareholders, members, employees and customers (such as to legal representatives and law enforcement) as you expressly permit and as required by law (such as the result of a court subpoena). We may transfer your information in the event of the sale of substantially all of the assets of our business to a third party or in the event of a merger, consolidation or acquisition. However, in such event, any acquirer will be subject to the provisions of our commitments to you.
 
How do keep your information safe? We have organizational and technical processes and procedures in place to protect your PI/PD.  Unfortunately, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 
 
What are your rights? Depending on where you are located geographically within or outside the United States of America, the applicable privacy law may mean that you have certain rights regarding our collection of and usage your personal information.  
 
How do you exercise your rights?  The easiest way to exercise your rights is by submitting a data access request by email to privacy@sudsies.com or mailing such a request to our business address 12711 Biscayne Boulevard, North Miami Fl. 33181 addressed to Privacy Officer.
 
Review the Privacy Policy in full to learn more about what we do with any PI/PD information we collect and your legal rights depending upon where you reside.  
 
Canada, the United Kingdom (UK), the European Economic Area (EEA) and Switzerland residents who wish to utilize the Services offered through the SITE should review Sections 5 and 6 for information on their specific privacy rights.  US Residents who wish to utilize the Services offered through the SITE should review Section 7 on their specific privacy rights according to specific laws enacted by their state of residence.  Other US states are expected to follow suit by enacting their own privacy laws.  Any US resident who uses this Site should review Section 9.   Sudsies, Inc. may not meet the need-to-comply criteria required by all current privacy laws in the United States and elsewhere. Nevertheless, Sudsies takes the privacy of all individuals who provide PI/PD through our SITE seriously.  Therefore, we handle the PI/PD of all of our customers throughout the United States, Europe, and Canada according to the terms of this Privacy Policy.  
 
Please note that Sudsies, Inc. provides its Services only within the State of Florida and primarily to Florida residents or Florida visitors.  Florida is, however, a destination for many visitors and from other states as well as international travelers.  Accordingly, this Privacy Policy includes provisions related to obligations we may have in maintaining the privacy of customers whose legal residence is in a state other than Florida or another country and who use our services while in the State of Florida.    
 
The topics covered in this Privacy Policy are: (1) Interpretation and Definitions; (2) Collecting and Using Your Personal Data; (3) How We Process Your Information; (4) GDPR Privacy for European Union residents; (5) The Legal Bases We Rely on to Process Your PI/PD; (6) Cookies & Google Analytics; (7) Logins Via Social Media Accounts; (8) International Transfers of Data; (9) Retention of Information; (10) Keeping Your Information; (11) No Collection of Data from Minors; (12) Your Privacy Rights; (13) Controls for Do-Not-Track Features; (14) Specific Privacy Rights for US Citizens; (15) Updates to this Privacy Policy; and (16) How to Contact Us. 
 
1. INTERPRETATION AND DEFINITIONS
 
(a) Interpretation
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. 
(b) Definitions.  For the purposes of this Privacy Policy:
 
Account means a unique account created for you to access our Services or parts of our Services as those services relate to our drycleaning and laundry services.  
 
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company (Sudsies, Inc.) as the legal entity that collects Consumers’ personal information or personal data and determines the purposes and means of the processing of a Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California. 
 
CCPA or the California Consumer Privacy Act refers to privacy laws enacted by the State of California to protect the privacy of its residents. The CCPA includes stronger privacy protection provisions that may not be followed by other jurisdictions.  Since our Website and Services may be accessed by or utilized by California residents or businesses, our Privacy Policy covers Our obligations under the CCPA.  California residents should be sure to review the section of this Privacy Policy specific for California residents. 
 
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Sudsies, Inc., a Florida Corporation with a business address of 12711 Biscayne Boulevard, North Miami Fl. 33181.
 
Consumer for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
 
Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
 
Country. Unless otherwise designated, country refers to the United States of America. 
 
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to Sudsies, Inc. as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
 
Data Processor means any natural person or legal entity which processes PI/PD on behalf of Sudsies.  It refers to third-party companies or individuals employed or hired by Sudsies to facilitate processing of PI/PD to facilitate Sudsies’ ability to provide the services you retain Sudsies to perform via the Site or to assist Sudsies in analyzing how the Site is used.  
 
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet no matter where physically located. 
 
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
 
General Data Protection Act (GDPR) was enacted by the European Union in 2018 to protect the personal data of its residents.  Since individuals or businesses located in the European Union may conceivably access our Website and utilize our Services, our Privacy Policy covers our obligations under the GDPR.  Residents and businesses located in the European Union should be sure to review the section of this Privacy Policy specific for them. 
 
Personal Data is any information that relates to an identified or identifiable individual. This Policy uses Personal Data and Personal Information interchangeably. 
For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
 
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
 
Personal Information Protection and Electronic Documents Act (PIPEDA) means the privacy laws enacted by Canada to cover those provinces which do not have substantially similar privacy laws.  Currently, the provinces of Alberta, British, and Quebec have privacy laws in place. 
 
Sale of Personal Data/Information for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Data/Information to another business or a third party for monetary or other valuable consideration.
 
Service(s) refers to the Website and the Services provided by us directly or indirectly through the Website.  
 
Service Provider means any natural or legal person who processes PI/PD on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Services/Site are used. For the purposes of the GDPR, Service Providers are considered Data Processors.
 
Third-Party Links.  Links to Third Parties may be provided within the Site.  Once you leave the Site by clicking on the link, this Privacy Policy no longer applies.  You should review the privacy policy to any website you visit after leaving our Site. 
 
United Kingdom Privacy Laws.  The GDPR is still retained in domestic law as the UK GDPR, but since Brexit, the UK has the independence to keep the framework under review. The ‘UK GDPR’ sits alongside an amended version of the UK’s Data Protection Act of 2018. 
 
U.S. State Law Privacy Law means the individual privacy policies which have been adopted to date by certain individual states.  
 
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to access our Website and use our Services.
 
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a webpage visit).
 
We, Our, and Us means Sudsies, Inc. 
 
Website and Site refer to Sudsies, Inc. accessible http://www.sudsies.com.
 
You and Your means the individual accessing or using the Website, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.  Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
 
2. COLLECTING AND USING YOUR PERSONAL DATA
 
(a) Types of Data Collected
 
i. Personal Data
 
We collect PI/PD that you voluntarily provide to us when you wish to avail yourself of the Services available for purchase on our Site, express an interest in obtaining information about us or our Services, or otherwise when you contact us.  The personal information that we collect depends on the context of your interactions with us and choices you make from the Site’s available services, and the Site’s features you use. The PI/PD we collect may include, but is not limited to:
 
• Names
• Email address
• First name and last name
• Phone numbers
• Billing Addresses 
• Delivery addresses if different from the billing address
• Usernames
• Passwords
• Credit/debit card numbers
 
ii. Sensitive Information.   We do not collect or process sensitive information.  
 
iii. Payment Data.  We may collect data necessary to process your payment if you choose to purchase our services, such as your payment instrument number and the security code associated with your payment instrument.   If you choose to pay through a third-party payee listed at the Site, your payment data will be handled and stored by it by that third-party payee which has its own obligations to protect your PI/PD.  You should review the third-party payee’s own privacy policy prior to providing any PI/PD.  Sudsies is not responsible for any PI/PD you may provide to third-party payees, 
 
iv. Social Media Login Data.  We may provide you with the option to register with us using you existing social media account details, like you Facebook, X, or other social media account.  If you choose to register in this way, we will collect certain profile information about you from the social media provider as described in Section 7 below.
 
All personal info that you provide to us must be true, complete, and accurate and you must notify us of any changes to such personal information.
 
v. Automatically Collected Information. Usage and Device Data (UDD) are automatically collected when you visit, use, or navigate the Site.  UDD may include information such as your device’s Internet Protocol (IP) address (e.g. IP address), browser and device characteristics, operating system, language preferences, referring URLs, device name, country location, information about how and when access the Site, and other technical information.  Such information does not reveal your specific identity (e.g., your name). It is primarily needed to maintain the security and operation of the Site and for our internal analytics and reporting purposes. 
 
Like many businesses, we also collect information through cookies and similar technologies.  You can find out more about this in our Cookie Policy available at www.Sudsies.com/cookies.   
 
3.  HOW WE PROCESS YOUR INFORMATION
 
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.  We may also process your information for other purposes with your consent.
 
We may use your PI/PD for a variety of reasons, depending on how you interact with our Site, including:
 
  • To facilitate account creation and authentication and otherwise manage user accounts.  We may process your information so you can create and log in to your account as well as keep your account in working order.  
  • To deliver and facilitate delivery of services to the user.  We may process your information to provide you with the service(s) you have purchased through the Site. 
  • To respond to user inquiries/offer support to user.  We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. This may include notifications regarding updates on the status of your service order
  • To send administrative information to you.  We may process your information to send you details about our services, changes to our terms and conditions and privacy policy policies, security updates, and similar information at our option. Please be advised that   you are bound by the terms of any changes we post online concerning our terms and policies whether or not we notify you by email and as otherwise required by law.
  • To fulfill and manage your purchased services.  We may process your information to fulfill and manage your orders, provide information on your service order’s pickup and delivery schedule, and manage your payments for the services we render on your behalf.  
  • For our protection. To protect the rights and safety of us, our shareholders, members, officers, employees and customers. 
  • For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the PI/PD held by us about our Service users is among the assets transferred.
  • With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.                                                           
  • For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services and marketing and your experience with the Site.      
  • Payment partners:  If you opt to pay for our service(s) by credit or debit card through a third-party payee, you will be notified that you are leaving our website.  In that event, you will be taken to a third-party payment management service which We have retained to collect payments from our Users.   You should review the privacy policies of any third-party payment management service.  

And as which may otherwise be required by law.  

 
 
4. THE LEGAL BASES WE RELY ON TO PROCESS YOUR PI/PD 
 
We only process your PI/PD if we believe it is necessary and we have a valid legal reason basis to so under applicable law, like with you consent to comply with laws to provide you with services to enter into or fulfill our contractual obligations, to protect our rights, or to fulfill our legitimate business interests.
 
(a) If you are located in the EU or the UK, this section applies to you. 
 
The GDPR and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information.  As such, we may rely on the following legal bases to process your personal information. 
 
  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes. 
  • Performance of a service contract as it relates to our services: It will be necessary to obtain PI/PD to fulfill out contractual obligations to you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Where we believe that it is necessary for compliance with the legal obligations to which we are subject, such as to cooperate with a law enforcement body, regulatory agent, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person such as situations involving potential threats to the safety of any person.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us.
 
(i) Your Rights under the GDPR/UK GDPR
 
We undertake to respect the confidentiality of your PI/PD and to guarantee you can exercise Your rights.
 
You have the right under this Privacy Policy, and by law if You are within the EU or the UK, to:
 
  • Request Access to Your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist You. This also enables you to receive a copy of the personal data we hold about you.
  • Request Correction of the Personal Data that We Hold About You. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for our processing and there is something about pour particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request Erasure of Your Personal Data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
  • The Right to Delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm Your request, we will delete (and direct our Service Providers to delete) Your personal information from our records, unless an exception applies. 
  • Request the Transfer of Your Personal Data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw Your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our service. 
 
(ii) Exercising of your GDPR Data Protection Rights
 
You may exercise your rights of access, rectification, cancellation and opposition by contacting Us using one or both of the e-mail addresses provided below.  Please note that we may ask you to verify your identity before responding to such requests. If You make a request, we will try our best to respond to you as soon as possible.
 
privacy@Sudsies.com 
 
You have the right to complain to a Data Protection Authority about our collection and use of your personal data.  For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
 
(b) If you are located in Canada, this section applies to you. 
 
Under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), we may process your information if you have given express consent to use your PI/PD for a specific purpose or in situations where your permission can be inferred (i.e., implied consent).   In our case, your consent relates to our being able to carry out a transaction related to the providing of our drycleaning, laundry, and/or clothing alternation services with optional delivery services.  The transaction requires the providing of certain PI/PD as summarized in Section 1 consistent with Sudsies’ legitimate purpose of providing the services you wish us to provide.  You can withdraw your consent at any time by contacting us at privacy@sudsies.com.
 
In some exceptional cases, we may be legally permitted under applicable law to process your PI/PD without your consent, including, for example:
  • If collection is clearly in the interests of an individual and consent cannot be obtained in any other way.
  • For investigations and fraud detection and prevention.
  • For business transactions provided certain conditions are met,
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
  • For identifying injured, ill, or deceased persons and communicating with the next of kin.
  • If we have reasonable grounds to believe than an individual has been, is, or may be the victim of financial abuse. 
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of court relating to the production of records.
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
  • If the collection is solely for journalistic, artistic, or literary purposes.
  • If the information is publicly available and is specified by the regulations. 
 
5.  WHEN AND WITH WHOM WE MAY SHARE YOUR PERSONAL INFORMATION
 
We may share information in specific situations described in this section and or with the following third parties. 
 
Business Transfers.  We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition or all or a portion of our business to another company.  
 
Affiliates.  We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice.  Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that under the common control of us.
 
Service Providers as defined in Section 1. 
 
Other Third Parties. We do not sell PI/PD to any third parties. 
 
6. COOKIES AND GOOGLE ANALYTICS
 
(a)  Cookies. We may use cookies and other tracking technologies (like web beacons and pixels) gather information when you interact with our Site.  Some online tracking technologies help us maintain the security of our Site and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.  
 
Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements that are used to remember your browser or device during and across visits. We may use and place cookies (and web beacons, mobile device identifiers and other similar technologies) on your device to collect information about the use of our website, customize your visit to the Services and for other purposes to make your visit more convenient or to enable us to enhance our Services. In addition, third party advertisers that appear on our Site may also place cookies on your device and use similar anonymous tracking technologies.
 
Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove and to reject cookies. If you choose to remove cookies, restrict cookies, or reject cookies, the functionality of some features of our Site could be affected. 
 
(b) Google Analytics
 
We may share your information with Google Analytics to track and analyze the use of our Site.  The Google Analytics Advertising features that we may use include Google Analytics Demographics and Interests Reporting.  To opt out of being tracked by Google Analytics across the Site, visit https://tools.google.com/dlpage/gaoptout.  You can opt out of Google Advertising Features through Ads Settings and Add Settings for mobile apps.  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
 
7. LOGINS VIA SOCIAL MEDIA ACCOUNTS
 
We may provide you with the option of registering with and logging in to our Site via your third-party social media account details (like your Facebook or X logins).  Where you choose to do this, we will receive certain profile information about you from your social media provider.  The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you choose to provide such information and personal data, during registration or otherwise, you are giving Sudsies permission to use, share, and store it in a manner consistent with this Privacy Policy.
 
We will use the information we receive only for the purposes that are described in this privacy policy.  Please note we do not control and are not responsible for other uses of your personal information to your third-party social media provider.  We recommend that you review their privacy notice to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps. 
 
8.  INFORMATION TRANSFERRED INTERNATIONALLY
 
If you reside outside of the United States, we may transfer, store, and process your information in countries other than your own.
 
Our servers are located in the United States.  If you are accessing out Site from outside of the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see Section 1 above) in the United States and other countries.  
 
If you are a resident in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country.  However, we will take all means necessary to protect your personal information in accordance with this privacy policy and applicable law. 
 
9.  RETENTION OF YOUR INFORMATION
 
We keep your personal data for as long as is necessary to fulfill the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such is tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.  
 
You may opt out of having us retain your personal data by sending a request to our privacy policy administrator at privacy@sudsies.com.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.
 
10.  KEEPING YOUR INFORMATION SAFE 
 
The security of your information is very important to us. We have put in place reasonable physical, electronic, and organizational procedures to safeguard the information we collect. However, due to the inherent open nature of the internet, we cannot promise and guarantee that communications between you and us or information stored on our servers will be 100% secure.  Accordingly, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.  Although we do our best to protect your personal information, transmission of personal information to and from our Site is at your own risk.  You should only access the Site within a secure environment. 
 
11. NO COLLECTION OF DATA FROM MINORS
 
We do not knowingly collect, solicit data from or market our services to children under the age of 18.  As with all our adult customers, we do not sell personal information to third parties.  By using our Site and the services offered through the Site, you are representing that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site and its services.  If we learn that personal information from users less than 18 years of age, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you become aware of any data we may have collected from children under the age of 18, please contact us at privacy@sudsies.com. 
 
12.  YOUR PRIVACY RIGHTS
 
Depending on your state of residence within the United Sates or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Canada, and Switzerland, you have rights that allow you greater access to and control over your personal information.  You may review, change, or terminate your account at any time, depending on your country, province, or state of residence. 
 
Regarding residents of the EEA, UK, Switzerland, and Canada who access the Site, you have certain rights under applicable data protection rights. These may include the right (i) to request access and obtain a copy of your you personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.  In certain circumstances, you may also have the right to object to the processing of your personal information.  You can make such a request by contacting us at privacy@Sudies.com. 
 
We will consider and act upon any request in accordance with the applicable data protection laws. 
 
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complaint to your Member State data protection authority or UK data protection authority.
 
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. 
 
(a) Withdrawing your consent.  If we are relying on your consent to process your personal information, which may be express and/or implied depending on the applicable law, you have the right to withdraw your consent at any time by contacting us at privacy@Sudsies.com.
 
However, please note that this content withdrawal will not affect the lawfulness of the processing before its withdrawal nor, when applicable law applies, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.  
 
Opting out of marketing and promotional communications.  You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us at privacy@sudsies.com.  You will then be removed from our marketing lists.  However, we may still communicate with you – for example, to send you service-related messages that are necessary to the administration and use of your account, to respond to service requests, to manage service requests, or for other non-marketing purposes. 
 
(b) Account information.  If you would at any time like to review or change the information in your account or terminate your account, you can contact as at contact@sudsies.com. We may ask you for verification of your identify – for example, to provide the information you used to establish the account.
 
Upon your request to terminate your account, we will deactivate or delete your account and your information from our active databases.  However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and comply with applicable legal requirements.
 
13.  CONTROLS FOR DO-NOT TRACK FEATURES
 
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized.  As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
 
In the event you are California resident providing PI/PD on our Site. California law requires us to let you know how we respond to web browser DNT signals.  Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. 
 
14.  SPECIFIC PRIVACY RIGHTS FOR UNITED STATES CITIZENS
 
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virgina, you may have the right to request access to and receive details about the personal information we maintain about you and we have processed to correct inaccuracies, get a copy of, or delete your personal information.  You may also have the right to withdraw your consent to our processing of your personal information.  These rights may be limited in some circumstances by applicable law.  More information is provided below.
 
(a) Categories of Personal Information We Collect
 
We have collected the following categories of PI/PD in the past twelve (12) months. 
 
Category A: Identifiers.
Examples: Contact details, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
 
Collected: Yes.
 
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
 
Collected:  Yes for credit card number or debit card number as used to pay for our services.  No for the other listed examples. 
 
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No except user may have option to specify an age range, e.g., 40-49. 
 
Category D.  Commercial Information. Examples.  Transaction information, records and history of products or services purchased or considered at the Site.
 
Collected: Yes
 
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
 
Collected: No
 
Category F: Internet or other similar network activity.
Examples: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements. 
 
Collected: No
 
Category G: Geolocation data.
Examples: Approximate physical location of device.
 
Collected: No
 
Category H: Audio, electronic, sensory, or similar information.
Examples: Images and audio, video, or call recordings created in connection with our business activities. 
 
Collected: No
 
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
 
Collected: No  
 
Category J: Education information. 
Examples: Student records and director information. 
 
Collected: No.
 
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes to create, for example, a profile or summary about an individual’s preferences and characteristics.
 
Collected: No
 
Category L.  Sensitive personal information. 
 
Collected: No
 
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
 
  • Receiving help through our customer support channels.
  • Participation in customer surveys or contests; 
  • Facilitation in the delivery of our services and to respond to your inquiries,
 
We will use and retain the collected personal information as needed to provide services under Category A or for Category B (credit card or debit card info only) – As long as the user has an account with us.
 
(b) Sources of Personal Information
 
Learn more about the sources of personal information we collect in the Section 2. 
 
(c) How We Use & Share Personal Information
Learn about how we use your personal information in Sections 2 and 5.  
 
(d) Will Your information be shared with anyone else?
 
We may disclose your personal information with our Service Providers pursuant to a written contract between us and each Service Provider.  See Section 1 for the definition of Service Provider.
 
We may use your personal information for our business purposes, such as for undertaking internet research for technological development and demonstration.  This is not considered to be “selling” of your personal information. 
 
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.  We will not sell or share personal information in the future belonging to website visitors, users, and other consumers. 
 
(e) Your Rights
 
You have rights under certain US state data protection laws.  However, these rights are not absolute and may not be applicable to us and in certain cases, we may decline your request as permitted by law.  These rights include:
 
  • Right to know whether or not we are processing data.
  • Right to access your personal data.
  • Right to correct inaccuracies in your personal data.
  • Right to request the deletion of your personal data. 
  • Right to obtain a copy of the personal data you previously shared with us.
  • Right to non-discrimination for exercising your rights.
  • Right to opt out of the processing if your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”). 
 
Depending on the state where you live, you may also have the following rights:
 
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law).
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law).
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law).
  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law). 
 
(f) How to Exercise Your Rights
 
To exercise these rights, you can contact us by submitting a data access request by emailing us at privacy@sudsies.com or my referring to the contact details provided at the end of this document. 
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf.  We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. 
Please note if you wish to have us remove your information permanently from our list of active users, you may send an email to us at info@sudsies.com. However, if you make such a request, you will no longer be able to use the Services unless you register again as if you were a new user.
 
Although we will process your opt-out requests within a reasonable period of time, we are not responsible for removing your information from the lists of any third party who has previously been provided your information in accordance with this policy.
 
(g) Requesting Verification
 
Upon receiving your request, we will need to verify your identify to determine you are the same person about whom we have the information in our system.  We will only use personal information provided at your request to verify your identity or authority to make the request.  However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. 
 
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.  
 
(h) Appeals
 
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@sudsies.com.  We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.  If your appeal is denied, you may submit a complaint to your state attorney general.
 
(i) California “Shine the Light” Law
 
Under California Civil Code Section 1798.83 (also known as the Shine the Light law), California residents with an established business relationship with us can request information once a year, free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal 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 by using the contact information provided at the end of this privacy policy. 
 
15. UPDATES TO THIS PRIVACY POLICY
 
We may update this privacy notice from time to time.  The updated version will be indicated by an updated “Revised” date at the top of this privacy policy.  If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes at the Site or by directly sending you a notification.  We encourage you to review this privacy policy frequently to be informed how we are protecting your personal information/data.  Changes to this Privacy Policy are effective when they are posted on this page.
 
16. HOW TO CONTACT US ABOUT THIS PRIVACY POLICY
 
If you have questions or comments about this notice, you may contact our Data Protection Officer by email at privacy@sudsies.com or contact us by post at:
 
Sudsies, Inc.
ATTN: Privacy Officer
12711 Biscayne Boulevard
North Miami, FL. 33181
USA