Privacy Policy

This Julep.com Privacy Policy ("Privacy Policy") governs your use of the Julep.com website (the "Website"), which is owned by AS Beauty LLC (collectively, “Julep”, “we” or “our”). We know how visitors like you value your privacy, and we have created this Privacy Policy to ensure that you understand our policies and procedures, what personal information you must provide if you wish to use certain portions of our Website and, ultimately, just how we use such personal information. This Privacy Policy is a part of and is incorporated into our Julep.com Terms and Conditions of Use. By accessing or using our Website or by otherwise giving us your information, you accept and agree to, without limitation or qualification, the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you must not use our Website or give us any of your information.   

This Privacy Policy was last updated on March 24th, 2020. We may make changes to this Privacy Policy at any time. In the event of any important substantive change(s) to how we use your information, how we protect your information or with whom we share it, we will communicate any such changes by updating this policy.

1. Information Collected By Our Website: This Privacy Policy applies to information that we collect from or about our customers through the methods described in this Privacy Policy. We note that not all of the methods listed below may apply to you. We collect two different types of information from users of our Website: personal information described below; and non-personal information such as information about traffic patterns on our Website.
2. Personal Information: Personal Information includes any information that would allow us to identify you or contact you, such as your name, home or mailing address, geographic location, payment information, user name, passwords, security questions and answers, biometrics, date of birth, age, age range, gender, favorite hobbies, interests, product purchase history, browsing history or other identifying information (collectively, “Personal Information”). This could also include information you give us about someone else (i.e. if you choose to ship a product to a friend or relative). We collect Personal Information in connection with a number of different activities, including, but not limited to creating an account, product purchases, customer service inquiries, contests and promotions and customer feedback. To access certain portions of our Website, we require you to register and select a user name and password. Some personal data is collected during the registration process. If you create an account with us, your payment information may be stored under your account profile. We may also ask for additional information, including personally identifiable and non-personally identifiable information. To review or edit this information go to maven@julep.com.

When you make a purchase on our Website, call our customer service hotline, e-mail us an inquiry or when you enter a contest or other promotion, we may ask you for certain personal information such as your name, address, e-mail address, phone number, personal interests, credit card number, billing information etc., in order to process your order, provide you with information, administer the contest, or send you promotional e-mails. Providing personal information in these instances is solely your choice; you do not need to provide such information, make purchases, or enter such contests to browse our Website.

Your username, password and security questions and answers should always be kept confidential and should never be shared with anyone else. To change your password, go to the Customer Login section of our Website or contact Customer Service at maven@julep.com or by phone at 917-810-4537.

We may also collect information that you voluntarily share with us about your experience using our products, i.e. through comments, suggestions, reviews, customer service surveys or e-mail correspondence. We may also collect content you generate and send to us by e-mail, through our Facebook page, Instagram site, Website or other means. Examples include, but are not limited to, photos, videos or testimonials.

We also may collect any information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party site to share with us or any information that you post publicly. This could include (but is not limited to) basic account information for the third party site, user ID, geographic location (city, state, country), profile picture and list of connections/friends and/or any other information that you allow the third party site to share with us. For further information concerning what information could be shared with us, please visit the third party’s website.

We may collect information from you through one of our inbound text messaging programs. For example, periodically we may allow customers to send us inbound text messages using a short code that we create or advertise in connection with promotions or special offers. These programs may be advertised through one of our Website or corresponding application. If you choose to participate in one of these programs, data about your physical geo-location may be obtained and used for marketing purposes. This policy will only apply if our text messaging program indicates it applies or if it refers you to our Website to review the privacy provisions related to text messages.

On occasion, we may collect information about you from other sources. For example, we may hire a third party data aggregator to provide us with further information about our customers, including from your profile or posting on third party social networking sites. We may also receive additional information by acquiring new companies or from other methods not inconsistent with this Privacy Policy.

We note that we strive to limit the amount of Personal Information we collect and store to that only necessary to deliver the relevant goods and services.

3. How We Use Your Personal Information: We use the information collected on our Website for a variety of purposes, including, but not limited to, running the Website and contacting users, fulfilling orders, account maintenance, customer service, product recommendations and improvements, contests and promotions, communications, Website personalization, third party on-line advertising, Website security and/or internal research.

Our Website may also make available to other registered users information provided by you during registration, such as your screen name. We may use your information to communicate back to you, to update you on products, services and benefits, to personalize our Website for you, to personalize our advertising, marketing, communications, and promotional offers, to contact you for market research or to provide you with marketing information, newsletters, or other information we think would be of particular interest. In addition, if you make a purchase on our Website, we may send you order and shipping confirmation emails. We will always give you the opportunity to opt out of receiving such materials.

You can remove your e-mail address from our e-mail list at any time by following the procedures set forth in the “Opt Out Procedures” section below or by clicking on the "unsubscribe" link in every Julep e-mail.

Information obtained through our Website may be intermingled with and used in conjunction with information obtained through sources other than our Website, including both offline and online sources.

4. Discussions and Community Tools: Our Website may make product reviews, chat rooms, forums, bulletin boards, news groups and other community tools available to registered users and/or visitors. Please remember that any information that is disclosed in these areas becomes public information for other users to view and for Julep to use. Please do not disclose any personally identifiable information in these publicly accessible areas of our Website. Please be considerate and respectful of others while using any chat rooms, forums or message boards to share your opinion.
5. Non-Personal Data: In some cases, we may collect non-personal information. Examples of this type of information include the type of internet browser you are using and version, the type of computer operating system application software, and peripherals you are using, the domain name of the website from which you linked to our Site, the IP address and the website usage (including, but not limited to, the links you click on and the pages you review). We use your information on an aggregated basis to do such things as operate and enhance our Website. This information is collected by using web beacons and cookies and may be collected from computers, tablets, smartphones and other devices, as well as by third party vendors such as Google Analytics. Website usage may be associated with your account or personal contact information. To learn more about Google Analytics, please see the information provided by Google.
6. Cookies: Certain features on our Website utilize cookie technology. A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you've visited. Our Website, online advertisements, and emails use cookies, pixel tags, and other technology to collect information about your interactions, including browser type, pages viewed, links clicked, and other actions. We may use cookies to enhance your experience on our Website, personalize your experience, to determine user traffic patterns and for other purposes. By accessing and using our Website, you consent to our use of cookies.

Most browsers are initially set up to accept cookies; however, you can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to disable your cookies setting or refuse to accept a cookie, you may not be able to access all areas of our Website. To learn more about cookies and how they work, see www.allaboutcookies.org.

7. Opt Out Procedures: You have the option to opt out of receiving information from Julep and our Website. This opt out messaging will appear at the bottom of every email that is sent out. If you no longer wish to take advantage of our Website or receive any form of direct contact from Julep or our Website, whether it is email, discounts, newsletters, or other promotional offers or materials, please contact us.
8. Reviewing or Changing Your Information: In order to ensure that the information we maintain is accurate, Julep gives users the option to change or modify their information previously provided during registration. If you would like to change your information currently in our database please log in and click the "My Account" link on our Website.
9. Sharing of Your Information: Julep may share your personal information: (i) with third parties who are under obligations of confidentiality with Julep or with Julep’s affiliates, subsidiaries or agents, (ii) if Julep is required by law to do so, (iii) in the event of a transfer of ownership of Julep, merger, sale, corporate restructuring, bankruptcy or other similar transaction, or (iv) as otherwise set forth in this Privacy Policy. The following describes some of the ways that your personal information may be disclosed to third parties:

We may share personal information provided with other AS Beauty Brands (i.e. Laura Geller).

We may employ other third parties to perform services or functions on our behalf in order to improve our Website, merchandising, marketing and promotional efforts, communications or other services. Those third parties may include authorized contractors, consultants and other companies working with us (collectively, "agents"). They only have access to personal information needed to perform their functions, and they may not share any personal information with others or use it for any other purpose than providing or improving Julep’s services and offerings.

We may allow third party ad networks to collect and use your information to show you ads that are targeted to reach people (or people similar to people) who have visited our Website or provided us with Personal Information through other means (“Matched Ads”). This includes Julep’s ads on other sites or our Website. In order to do this, we upload a customer list to the third party ad network or incorporate a pixel from the third party ad network on the Website, and the third party ad network matches common factors between our data and their data. At times, these ads may persuade you to come back and revisit the Website for new offers. This type of advertising generally includes an ad network that collects and tracks certain technical information (i.e. your IP address) and Website usage information (i.e. browsing history) on our Websites and other Internet sites. To opt out of receiving Matched Ads, please go to https://www.networkadvertising.org/managing/opt_out.asp. We are not responsible for the third party ad network’s failure to comply with your opt-out requests.

We may also have a need to transfer our customer information (including Personal Information), regardless of where you live, outside of the United States in which we or our agents have offices or facilities. By using the Website or otherwise doing business with us, you are agreeing to allow us to transfer your Personal Information outside of your home country and to process it inside the United States or elsewhere for the purposes stated in this Privacy Policy.

This Privacy Policy applies only to Julep’s Website and does not address the practices of third parties who may collect your personal information. You may visit other websites, through links on our Website, which may collect, use and share your personal information in accordance with their own privacy policies. The information practices of those linked websites are not covered by this Privacy Policy, and we encourage you to be very cautious before you disclose your personal information to others.

Julep may be obligated to cooperate with various law enforcement inquiries. Julep reserves the right to disclose or transfer personal information and non-personal information about you and your activities on our Website in order to comply with a legal requirement or request from law enforcement or other government officials, administrative agencies or third parties as we, in our sole discretion, determine necessary or appropriate for the administration of justice, or in connection with an investigation of fraud, intellectual property infringements or violations of any other law, rule or regulation, our Julep.com Terms and Conditions of Use or other rules or policies of our Website, the rights of third parties, or an investigation of any other activity that may expose us or you to legal liability, or to investigate any suspected conduct which Julep in its sole discretion deems improper.

10. Security: Providing a secure site is essential for your peace of mind and trust in Julep. We have installed encryption software conforming to the Secure Socket Layers (SSL) protocol to safeguard all of the information you send to us. All information is stored on our servers in a secure location. It is important for you to protect against unauthorized access to your password and to your computer. If your password is compromised, please notify Customer Service at once.
11. Protection for Children: Our Website is not intended for users under the age of 18. Furthermore, we have no intention of collecting Personal Information from children (i.e., individuals under the age of 13). Where appropriate, we take reasonable measures to inform children not to submit such information to our Website or in response to advertisements.
12. Privacy Precaution Warning: Please note that no data transmission over the Internet is 100% secure. As a result, we cannot guarantee the security of the information that you transmit via our online services. However, you can play a role in keeping your Personal Information safe. For example, you should choose an account password that is unique, difficult to guess and confidential. If you use a shared computer, never choose to have the computer save or remember your password and make sure to log out when you are finished using the Website.
13. Your Consent: By using our Website and providing your personal information to us, you also authorize the export of your personal information to the USA, as well as its storage and use as specified herein. Our headquarters is located in the state of New York, in the USA at 42 West 39th Street, 9th Floor, New York, NY 10018. This Privacy Policy and our legal obligations are subject to the laws of New York and the USA, regardless of the location of any user. Any claims or complaints must be filed in the USA in the State of New York.
14. Third Party Sites/Features: Our website may provide links to or features from other third party sites that we do not own or control. If you click on these links or use the features, you do so at your own risk. We are not responsible for the content or practices of any third party site or feature.
15. Contact Us: You can contact us at the following:

            42 West 39^th Street, 9^th Floor, New York, New York 10018

            Telephone No.: 917-810-4537

            E-mail: maven@julepcom

16. California Privacy Rights and The California Consumer Privacy Act

If you are a resident of California, the following sections are intended to provide certain information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”). These sections apply to personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Personal information does not include publicly-available information and certain other information that is regulated by other applicable laws.

You have the Right to Know and to request that we disclose certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of personal information we have collected about you
• The categories of sources from which we have collected your personal information
• Our business or commercial purpose(s) for collecting your personal information
• The categories of third parties with whom we have shared your personal information
• The specific pieces of personal information we have collected about you

We do not sell any Personal Information to third parties.

You have the right at any time to request that we delete your personal information. However, in some cases we may not be able to delete all or some of your personal information as required or permitted by applicable laws. Or we may need to delay a deletion, for instance, to process transactions you authorize such as a purchase of our products.

We do not sell, rent, or otherwise share your data to any third-party for a business or commercial purpose under any circumstances. However, we are required to let you know that you have the right to opt-out of the sale of your personal information if we ever notify you that we engage in such activity.

We will not discriminate against you for exercising your rights under the CCPA.

To submit a request to exercise any of your rights provided in this notice, please email maven@julep.com, or submit your request by phone by calling us at 917-810-4537. We will evaluate the request and take action where required to do so. Depending on the nature of your request, we may have to verify your identity when you contact us. We do this by asking you to provide us with certain pieces of personal information which we will match with information we have in our possession to verify your identity.

We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provides written proof that he/she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please contact us at maven@julep.com, or submit your request by phone by calling us at 917-810-4537. We are not able to respond to more than one “Right to Know” request from a consumer in any 12-month period.

Depending on your specific personal interaction with Us or by using this website, we may have collected the following categories of personal information from consumers in the last twelve (12) months: identifiers (e.g. real name, address, email address); characteristics of protected classification under California or Federal law; commercial information (e.g. products purchased, obtained, or considered, or other purchasing or consuming histories); internet or other electronic network activity (e.g. browsing history, search history, or a consumer’s interaction with a website); geolocation data; audio, visual, and similar information; professional or employment related information; inferences drawn from any of the information above to create a profile about a consumer (reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and attitudes); or any other category of information consistent with this Privacy Policy.

Our sources for this information include: information we receive directly from you; information we may have licensed data from third-party data providers; information received from our third-party advertising partners; information received through third party social networks (such as Facebook); or any other sources consistent with this Privacy Policy.

Our business purposes for collecting this information include: to fulfill our contractual obligations with you; to improve our website and our services; to send you updates about our company; to send targeted marketing campaigns; or any other purpose consistent with this Privacy Policy.

As discussed above, we do not sell, rent, or otherwise share your data to any third-party for a business or commercial purpose under any circumstances. However, we may share your data with third-party vendors or service providers engaged by us to help provide the services permitted by the Privacy Policy. Each third-party vendor or service provider is obligated to only use your personal information to provide the contracted services and for no other purpose. Further, each third-party vendor or service provider must contractually agree to robust privacy and security obligation prior to engagement, including the secure deletion of your data upon the termination of our agreement.

17. California “Do Not Track” Notice: We do not currently recognize and process “do not track” signals from different web browsers. For more information on “do not track” please visit https://allaboutdnt.com/.

18. California Shine the Light: California law permits California residents to request notice of how their personal information is shared with third parties for direct marketing purposes. If you are a California resident and would like a copy of this notice, please contact us at maven@julep.com.