Welcome to StimuSIL! We offer wellness products to enhance hair and scalp health (“Products”).   

This Privacy Notice describes how StimuSIL, Inc. (“StimuSIL”, “we”, “us” and/or “our”), handles the personal information that we collect from and about you when you visit our website, currently located at https://stimufield.com (the “Site”); engage with us through our newsletters, emails, and branded social media accounts; or otherwise interact with us (collectively, our “Services”). This Privacy Notice also describes certain legal rights you may have, subject to applicable law, and how you can exercise them.

For the purposes of this Privacy Notice, “Personal Information” means information about an identified or identifiable person, as defined by applicable law. This includes information that alone or in combination with other information may be used to identify, contact, or locate you, such as your name, address, email address, or phone number. 

Please read this notice carefully. In addition, please review our Website Terms of Use, and General Terms and Conditions for the Sale of Goods, which govern your use of the Services. 

Information We Collect

Information You Give Us Directly 

Some information we collect directly from you. For instance, we collect information that you voluntarily provide in the following ways: 

  • When you set up an account. When you create an account, we ask you to provide your first and last name, email address, and a password we can use to authenticate you at sign in. Creating an account allows you to log in on a different or shared device, purchase Products, and access your order history. Additionally, an account may provide access to certain features, such as product usage instructions, tips, and progress tracking tools.
  • When you make a purchase from our Site.  If you choose to purchase Products through our Site, you will be required to provide certain information including your name, payment information (such as credit/debit card details, Paypal or other payment account details), and billing address in order to facilitate payment. Payments are handled by our third-party partners, including Shopify, Inc. (which hosts our online store). You will also be asked to provide a name, phone number, and shipping address where you’d like us to send your order. If you return a Product, we may collect certain information from the device, including details about whether it was turned on and the frequency of use, to help process the return and ensure product quality.
  • When you sign up to receive communications from us, including signing up for emails, newsletters or SMS updates. When you engage in one of these activities, we may collect your name, email address, telephone number, and any additional information you choose to provide to us as part of that request. We use your email address and telephone number to notify you about Products and promotions we may offer and provide news and information we believe will be of interest to you.
  • When you take quizzes or answer surveys. When you take quizzes or answer surveys on the Site, we collect a variety of information, including your name, email address and any other information relevant to that quiz or survey or which you choose to provide. This can include your gender, age, demographics, and haircare needs. We use this information to provide personalized Product recommendations to you and to direct you to news and content we believe will be of interest to you.
  • When you contact us. When you contact us by email; through our branded social media accounts or customer support site; through any integrated chat providers we may provide; or by telephone, SMS, or physical mail, we may collect your name, social media username (if applicable), email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide.
  • When you send a gift card or invite others to try StimuSIL. When you purchase or send a gift card for one of our Products, we collect your name, contact details, and payment information, as well as the recipient's name and email address. Additionally, if you invite a friend to try our Products, we may collect their name and email address. This information is used solely to process the transaction, deliver the gift card, or facilitate the invitation.
  • Registering for a contest, competition, or sweepstakes. In these circumstances, we may collect your name, contact information, and any other information relevant to that contest or competition or which you choose to provide.
  • When you participate in surveys or research studies. We may contact you to ask if you would be willing to participate in a survey or research study. If you decide to participate, you may be asked to provide demographic information, feedback on your experience (such as satisfaction data, before-and-after pictures, and testimonials), and any other information relevant to that survey or study. This research may be published in aggregated, anonymized form. 

Information We Collect Automatically When You Use Our Services 

We also collect certain information automatically as you navigate our Services or interact with our communications, including the following: 

  • Information about the devices you use to access our Services (including your internet protocol (IP) address, browser type, and operating system); 
  • The address of the web page visited before and after using our Services; 
  • Details about your interactions with our Services (such as the date, time, length of stay, and specific pages accessed during your visits);
  • Search terms used to reach our Services;
  • Usage information (such as the number and frequency of visitors to our Site); and
  • Location information (such as general location information inferred from your IP address)
  • Transaction information. We collect information related to any transactions made through our Services, including date and time of order, items ordered, delivery information, and amount charged. 

We collect some of the information above using cookies or similar technologies. A “cookie” is a small text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or device or to store information or settings in the browser/device. We, and our third-party service providers, use cookies in order to do things such as recognize you when you return to our Site, save your preferences (including your preferences regarding cookie handling), understand usage patterns, and improve our mobile applications. We use both session cookies (which expire when you close your browser or app) and persistent cookies (which stay on your device until you delete them or until they expire).

If you do not want us to collect information through the use of cookies, you can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to the guidance offered by your chosen web browser if you would like help managing your cookie preferences. Please note that if you reject or block cookies, the Services may not work as intended.

We also may partner with third parties who provide analytics services and serve advertisements on our behalf across the Internet and in mobile applications. These third-parties may use cookies and similar technologies to track your engagement with our Site as well as our online advertising and email marketing campaigns and permit us and them to analyze and track data, and do things like determine which advertising or marketing source brought someone to our Site and target advertisements to an audience based on prior browsing patterns on our Site. 

Information We Collect from Other Sources 

We may also obtain Personal Information from other sources. For instance, we may collect Personal Information about you from the following third-party sources: 

  • Payment processors. In general, when you purchase Products through our Site, your payment card information is provided directly to our third-party payment processing partners, and StimuSIL does not collect or store that information. However, we may have access to limited information about your payment card from these partners and related transaction details, such as the last four digits of your card, the country of issuance, and the expiration date. 

We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information. 

How We Use Your Information 

We use the information described above to do the following: 

  • Provide our Services (including taking and processing your orders; shipping Products; communicating with you regarding your purchases; and sending you technical notices, updates, security alerts, and support and administrative messages);
  • Operate and improve our Services (including monitoring and analyzing usage, trends, and activities related to the Services and identifying, fixing, and troubleshooting bugs and service errors);
  • Communicate with you (including responding to your requests, inquiries, comments, and suggestions);
  • Personalize content (including tailoring content we send or display to you in order to provide you with information and resources we think will be relevant to you);
  • Further our networking, marketing, and social strategies (including posting testimonials and communicating with you by email or SMS about programs, services, offers, promotions, and events);
  • Conduct data analysis (including de-identifying and/or aggregating information and using it to perform research and provide statistical information and trend data)
  • Protect against, identify, investigate, and respond to misuse of our Services (including preventing and detecting fraud, unauthorized access, and other unlawful behavior);
  • Support our general business operations (including maintaining our business and legal recordkeeping); and
  • Carry out any other purpose described to you at the time the information was collected. 

How We Share Your Information 

We may share information about you with third parties in the following circumstances: 

  • Companies under common control. We may share Personal Information between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with StimuSIL. 
  • Vendors and service providers. We may share Personal Information with vendors, consultants, and other service providers who need to access the data in order to perform services on our behalf. For instance, your Personal Information is stored through Shopify’s data storage, databases, and the general Shopify application.
  • Advertising and Analytics Partners. We may share your Personal Information with other third parties that provide online analytics and advertising services in order to better understand how individuals interact with our Services and other online services over time and across devices.
  • Business transfers. We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, re-organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.
  • Legal requirements. We may share Personal Information when we believe it is necessary to comply with a legal obligation, including lawful requests from public authorities to meet national security or law enforcement requirements. We may also share Personal Information when we believe it is necessary to protect our rights and property, to protect the safety of our users, and to defend against legal liability.
  • Consent. We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information.
  • De-identified/Aggregate Information. We may also share aggregate or de-identified information, which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations; for business or marketing purposes; or to assist third parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services. Additionally, we may use such information to support the design and analysis of clinical trials, evaluate the performance of our products, and enhance our understanding of user experiences. Any de-identified data used in research will not be associated with personal identifiers and will be solely for scientific and development purposes.

Your Rights and Choices 

You have a variety of rights and choices related to our use of your Personal Information. 

  • Opting out of promotional communications. You can opt out of receiving our promotional communications emails and texts at any time. You may do so by contacting our customer service team or by following the opt-out instructions in the promotional emails or texts we send you. Please be aware that it may take up to ten (10) days for us to process your request, and you may continue receiving promotional communications from us during that period. If you opt out of receiving such communications, please be aware that we may continue to send you non-promotional emails (such as emails related to our business relationship or emails about changes to our legal terms).
  • Restricting cookies/Do Not Track. StimuSIL does not currently change its behavior in response to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” or similar opt-out signals, we will assess and provide an appropriate response to those signals.
  • Limiting information available through social media platforms.  If you want to limit or stop receipt of information from third-party social media platforms, you can change your privacy settings on those other websites. You also may choose not to use social features we make available.
  • Access, update, or delete your information. If you would like to access, update, or delete Personal Information you have provided you may do so by emailing us at privacy@stimusil.com. To learn how to close your account, please contact us by email. Please note that we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time. 

Additional Disclosures for Residents of the EEA, UK, and Switzerland 

The laws in the European Economic Area (“EEA”), United Kingdom (“UK”), and Switzerland require businesses to disclose certain information, including (i) the controller(s) of your Personal Information, (ii) the legal bases relied on to use or disclose your Personal Information (iii) your legal rights with respect to your Personal Information, (iv) safeguards used for transferring your Personal Information outside of these jurisdictions, and (v) the contact details of the controller and/or data protection offer. To the extent those laws apply, our answers are as follows: 

Controller StimuSIL is considered the “data controller” of the Personal Information that we handle under this Privacy Notice. 
Legal Basis

Legitimate Interest. In most cases, we handle Personal Information on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: 

  • Providing Services pursuant to our contract with our customers;
  • Processing billing and payments;
  • Marketing our Services;
  • Protecting our customers, personnel, and property; and
  • Analyzing and improving our business. 

Legal Compliance. We need to use and disclose Personal Information in certain ways to comply with our legal obligations, such as complying with trade control laws and legal and business recordkeeping requirements. 

To Honor Our Contractual Commitments to an Individual. We need to process some Personal Information to meet our contractual obligations to the individual to whom the Personal Information pertains.

Consent. Where required by law, and in some other cases, we handle Personal Information on the basis of implied or express consent. For instance, we will obtain and rely on your consent to send you newsletters or for the use of certain cookies
Legal Rights

Right to Access & Portability: You have the right to request that we provide access to and/or a copy of the Personal Information we hold about you (including, in some cases, in an easily accessible format along with information explaining how that data is used). You may also request that we transfer your Personal Information to a third party.

Right to Correction: You have the right to request that we update Personal Information about you that is out-of-date or incorrect.

Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your Personal Information.

Right to Deletion: In certain circumstances, you have the right to request the deletion of your Personal Information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of our business. 

Right to Object: If we process your Personal Information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will stop processing your Personal Information unless we have a compelling legitimate ground to continue processing or where it is legally necessary. 

Right to Withdraw Consent: Where we rely on consent, you can withdraw your consent to our processing by using various means we offer, such as an email unsubscribe link. This is without prejudice to your right to permanently delete your Personal Information. 

We will consider all requests and provide our response within the time period stated by applicable law. Please be aware that certain information may be exempt from such requests in some circumstances. Before responding to your request, we may require that you provide us with additional information to confirm your identity. 

You have the right to lodge a complaint with the appropriate supervisory authority if you believe our processing of your Personal Information violates applicable law.
Safeguards

Personal Information we collect may be stored and processed for the purposes set out in this Privacy Notice in the United States where we are based or in any country where we have operations or engage vendors or service providers. These countries may have different data protection and government surveillance laws than your country.

Some of these countries have received a European Commission adequacy decision. For other countries, we take organizational, contractual, and legal measures, such as entering into written agreements with the relevant third party, to ensure your Personal Information is adequately protected and processed exclusively for the purposes set forth above. In most cases, our legal reason for processing and transferring your Personal Information is to fulfill a contract with you or to provide the services or assistance you have requested. For additional information regarding these transfers, please contact us at privacy@stimusil.com
Electronic Direct Marketing

StimuSIL may send you electronic direct marketing subject to national law, if you have not declined such messages. If you do not wish to receive such messages any longer, you can opt-out at any time by following the instructions in those messages or by contacting us at privacy@stimusil.com
Contact Information for Controller/DPO

For personal information we process under this Privacy Notice:
2810 Church Street, PMB 78535, Wilmington, DE 19802, USA

 

Children’s Privacy 

Our Services are intended for adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us Personal Information without your consent, please email us using the contact information below. 

Links to Other Websites and Third-Party Content

We may provide links to third-party websites, services, and applications that are not operated or controlled by StimuSIL. This Privacy Notice does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any Personal Information to or through them.

Data Transfer

Personal Information we collect may be stored and processed for the purposes set out in this Privacy Notice in the United States or in any country where we have operations or where we engage vendors or service providers. These countries may not have the same data protection laws as the country in which you originally provided the data. By using our Services or submitting your Personal Information to us, you agree to such transfers.

Data Retention

We only keep your Personal Information for so long as reasonably necessary for the purposes described in this Privacy Notice, as required by law, or as necessary to resolve disputes and enforce our rights and agreements. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Security

StimuSIL uses generally accepted administrative, physical, and technical safeguards we believe are appropriate to protect the confidentiality, integrity, and availability of your Personal Information. Although we make reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the internet and storing information electronically. StimuSIL cannot and does not guarantee absolute security. 

Changes to Our Privacy Notice 

We may change this Privacy Notice from time to time to reflect changes in our practices or in the law. If we make changes to this notice, we will post the updated Privacy Notice on our website and indicate when it was last revised. You are advised to review this notice periodically to stay informed of our practices. If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Services after the revised Privacy Notice has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Notice, to the extent permitted by law. 

Contacting Us

If you have any questions about our Privacy Notice or how we protect your Personal Information, please contact us at privacy@stimusil.com or you may write to us at 2810 Church Street, PMB 78535, Wilmington, DE 19802, USA.