Privacy Policy

1. Introduction

This Privacy Policy (“Policy“) sets out how Unistraw, whose offices are at 600 B Street, San Diego, California, USA (hereinafter “Unistraw”, “we“, “us“, “our“) collects and processes personal information about you when you, among other things, visit our website or access our social media where this Policy is posted (the “Property“). This Policy does not apply to employee or applicant data that we handle in accordance with our Employee Handbook. By continuing to use any of our Property, you consent to your personal information being collected, processed and/or shared in accordance with this Policy.

2. Notice at Collection

2.1 Below is an overview of the categories of Personal Information we may collect. For details about how to exercise rights you may have under various state privacy laws, see Section 9 of this Policy.

Personal Information We Collect	How We Use Your Personal Information (Our Business Purpose)	How Long Do We Retain Your Personal Information?	To Whom May We Share Your Information?
Personal Identifiers	To administer our Property, including troubleshooting. To send you marketing materials and provide you with personalized content and experiences. To administer promotional activity.	Based on the statute of limitations for possible claims and as otherwise needed for use in potential or ongoing litigation.	Professional services consultants. Social Media Networks.
Commercial Information	To engage with you as a potential partner. To provide goods and services purchased. To comply with our legal obligations.	Based on the statute of limitations for possible claims and as otherwise needed for use in potential or ongoing litigation.	Professional services consultants. Government agencies.
Internet Activity Information	To optimize or improve our products, services, operations and Property. To detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity. To improve our websites and services. To perform research and business analytics and identify usage trends. To monitor compliance with our policies, maintain network and information security.	Based on the statute of limitations for possible claims and as otherwise needed for use in potential or ongoing litigation.	Analytics services. Information Technology (“IT”) vendors. Professional services consultants.
Sensitive Personal Information	To comply with our legal obligations. To verify your eligibility to participate in promotions and/or issue related tax statements for winners. To prevent fraud and abuse and to secure our systems, data, resources and facilities from unauthorized access or exploitation. To monitor compliance with our IT policies and maintain network and information security. To provide security and comply with health and safety obligations.	Based on the statute of limitations for possible claims and as otherwise needed for use in potential or ongoing litigation.	Professional services consultants. Auditing and accounting firms.

3. Categories and Sources of Personal Information Collected

3.1. Some of the information we collect about you in connection with your use of our Property may qualify as “Personal Information,” which is any information that itself identifies you or could reasonably be associated with you individually.

3.2. Personal Information. We collect the following categories of Personal Information:

Personal identifiers, such as your name, gender, date of birth, email address, telephone number, delivery address, and billing address.
Commercial Information, such as records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies.
Internet or network activity information, such as IP address, browser type and version; browser plug-in types and versions; operating system and platform; the URL clickstream to, through and from our Property; products and/or content you viewed or searched for within our Property; download errors; length of visits to certain pages and page interaction.
Contests or Promotions, including information necessary for the administration of certain promotional events.
Geolocation Information, such as GPS and WiFi.

3.3. Sensitive Personal Information. We only collect Sensitive Personal Information when we have explicitly informed you of such collection at the time of collection. When we refer to Personal Information in this Privacy Policy, it may include Sensitive Personal Information. Examples of when we collect Sensitive Personal Information include when we need to validate winners of any potential promotions, in connection with your participation in competitions or other events that we sponsor, and in connection with our legal obligations. We may also collect Sensitive Personal Information for advertising purposes. The types of Sensitive Personal Information we collect include:

Social Security Number, other government identification, precise geolocation information, payment information.
Demographic information, such as race or ethnic origin, political opinions, religious or other beliefs, medical or health information.
We may collect your age to comply with laws that restrict activities with certain products and information collection and disclosure of data for minors.

3.4. Also, note that any information you post or disclose via message boards, chats, profile pages, blogs, and other services (including social media services) is publicly available. You should consider this when deciding to disclose any information.

3.5. Sources of Personal Information. We collect most Personal Information directly from you, including when you, among other things, use our Property, create an account with us, subscribe to a newsletter, participate in a promotional contest, respond to a customer survey, email us, post in a public forum, and/or use our chat/message functionality. We also collect Personal Information automatically through the use of various technologies, including through “cookies”, as explained further in Section 5 below. Our other sources of Personal Information include:

Our affiliates,
Publicly available sources, such as public forums and chats,
Partners with whom we offer co-branded services or products, sell or distribute our products, or engage in joint marketing activities,
Social media networks with which you interact, such as when you reference Unistraw or our Services, or grant us permission to access your data on one or more of these services,
Cookies on our Property,
When you contact us by SMS or through email, we may collect Personal Information in the form of audio recordings or electronic records, some of which may not be retained by us but by a third party,
From you when participating in events, filming or winning prizes.

3.6. We acquire this information to update or supplement the Personal Information you provided, or we collected automatically. Note that this includes Personal Information from your social media account when you grant us access to your social media account in connection with, for example, creating an account with us. If you have created an account with us, it is your responsibility to ensure that you submit true, accurate and complete information via your account and keep it up to date. Where permitted by law, we may combine this Personal Information we receive from other sources with Personal Information you give to us or that we collect about you and use it to draw inferences about you as a consumer.

4. How We Use and To Whom We Share Your Personal Information

4.1. How We Use Your Personal Information. We collect and use your Personal Information for the purposes of enabling you to use our Property, enabling us to fulfill orders you make (such as for products, services or newsletters), to send you marketing materials and provide personalized content and experiences. We may also use the Personal Information we collect: (i) to administer our Property, including troubleshooting technical issues; (ii) to optimize or improve our products, services, operations and Property; (iii) as part of our effort to keep our Property safe and secure; (iv) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; (v) to communicate with you about your Account or transactions with us and send you information about features on our Property or changes to our policies; (vi) to provide you with advertising based on your activity on our Property and on other sites and applications; (vii) to make suggestions and recommendations to you and other users of our Property about goods or services that may interest you or them; and (viii) to detect, investigate and prevent activities that may violate our policies or be illegal. Unless we obtain your explicit consent, we do not use Sensitive Personal Information other than to provide the products and services that you have requested.

4.2. To Whom We Share Your Personal Information

4.2.a Our Affiliates. We may share your Personal Information with our affiliates, including our parent company SRS Life Sciences. When we do this, we and SRS Life Sciences act as one business and joint controllers of your Personal Information, meaning that we determine the purposes and terms of data use together. SRS Life Sciences’ use of information is governed by its privacy policy at https://www.srslife.com and will not be more liberal than our Policy.

4.2.b Service Providers. To provide and support our Property, sometimes we use external companies as service providers that work on our behalf to transmit, collect, process and/or store Personal Information for us. We require these service providers to treat the Personal Information we share with them as confidential and to use it only for the purpose of providing the services for which they have been engaged. These service providers fall into the following categories: billing and collection providers, auditing and accounting firms, analytics services, security vendors, IT vendors, and professional services consultants.

4.2.c Third Parties. We share your IP address, Device ID and browser activity with select third party advertising partners to allow them to provide custom advertising to you.

4.2.d Other. We may also share your Personal Information with others: (1) when explicitly requested by you (e.g., with social media networks); (2) when required by a court order or any legal or regulatory requirement; (3) in connection with the sale or transfer of all or a portion of our business or assets; (4) to ensure compliance with, and enforce, our Terms of Use at https://www.unistraw.com; (5) to ensure the safety and security of our users, consumers and others and (6) to protect our rights and property and the rights and property of others.

5. Online Tracking, Analytics and Advertising and User Choice

5.1. Tracking Technology Choices

5.1.a Cookies. A “cookie” is a text file containing small amounts of information that a website can send to your browser, which may then be stored on your computer as a tag that distinguishes your computer but does not name you. Some of our Property uses cookies to better serve you when you return to the Property. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies or you may opt out of our Property using performance and marketing cookies by toggling off such use in our privacy preference center; however, if you do this, some of the features of our Property may not work properly. You may also be able to reject certain cookies served through our Property by opting out on the website of the third party placing the cookie, which you can identify through your browser. Please note, the selection(s) you make in our privacy preference center will only apply to the browser or device in which you made your selection. To opt out of the targeted advertising or sale or sharing related to your email address or account with us, please see the Opt-Out of Targeted Advertising or Sale or Sharing of Personal Information instructions in Section 9.7 below.

5.1.b Web Beacons. Web beacons are small pieces of data that are embedded in images on the pages of websites. Web beacons may involve the transmission of Personal Information directly to us, to another party on our behalf or to another party in accordance with its privacy policy. We may use Web beacons to bring together Personal Information we collect about you. We may use tools provided by other companies to make the advertising we show you on our Property more relevant and interesting to you. For this purpose, we use cookies, web beacons or similar technologies to collect information about your browsing behavior and deliver Interest-Based Ads to you.

5.2. Analytics and Interest-Based Advertising Choices. We use or allow trusted third parties and service providers to use tracking technologies (e.g., cookies, web beacons or similar technologies) to collect information about your browsing activities, which may include Personal Information, so that online advertisers can serve you advertising that better reflects your interests (“Interest-Based Ads”) and so we can better understand how people use our Property. You may receive advertisements based on Personal Information obtained from your activities across websites not affiliated with us. You can learn more about ad serving companies and the options available to limit their collection and use of your Personal Information by visiting the websites for the Network Advertising Initiative at https://optout.networkadvertising.org/?c=1 and you can opt out of receiving advertisements based on Personal Information obtained from your activities across websites not affiliated with us via the Digital Advertising Alliance at https://optout.aboutads.info/?c=2&lang=EN. You can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device. Opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of Interest-Based Ads from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you opt-out, you may still see ads, but they will not be personalized based on your online activity. If you delete your cookies, you may also delete your opt-out preferences.

5.3. Promotional Communications. As noted above, we and selected third parties with whom we share your Personal Information, may use your Personal Information for direct marketing purposes, including to provide updates, newsletters, events or other communications (like direct messaging on supported channels of communication such as e.g. SMS/MMS, Direct Messages on Social, Email etc.) that we think may interest you.
Where required by law, your prior consent will be obtained before we send direct marketing. In any event, we offer you the option to unsubscribe from electronic marketing materials.
If you do not wish us to share your Personal Information with third parties for their marketing purposes at all, please contact us at our website at https://www.unistraw.com.

6. Data Security and Retention

6.1. We apply reasonable security measures to protect Personal Information that is under our control from unauthorized or illegal access, use, disclosure, modification or destruction. We offer no guarantees or warranties related to such protection and are not responsible for any such unauthorized activity. We will notify you in compliance with applicable law regarding data breach. Where you have a password that enables you to access our Property, you are responsible for keeping this password secure and confidential.

6.2. We retain Personal Information for as long as is reasonably necessary for the purposes described herein. The criteria used to determine the applicable retention period for your Personal Information includes the length of time we have an ongoing relationship with you and provide services to you, and whether there is a legal obligation to which we are subject that requires us to retain your Personal Information.

7. Links to Other Websites

7.1. Where we provide links to other websites or services, we do so for information purposes only. The other websites and services are outside our control and are not covered by this Policy. If you access other websites or services using the links provided, the operators of these websites and services may collect information from you and use that information in accordance with their privacy policy, which may differ from ours. By accessing an external website or link from our Property, you hereby release us from any and all liability for your use of such website or link.

7.2. On some pages of our Property, third parties that provide content, services, applications or plug-ins may track your use of such content, services, applications and plug-ins, or they may customize such content, services, applications and plug-ins for you consistent with their privacy policies, which may differ from ours.

8. Use of Property by Minors

The features, programs, promotions and other aspects of our Property requiring the submission of Personal Information are not intended for children. We do not knowingly collect Personal Information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed Personal Information to us, please contact us at https://www.unistraw.com. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s Personal Information as well as prohibit the use of that information.

9. Additional State Privacy Rights

9.1. The laws in certain states provide the residents of those states with rights to receive disclosures regarding the collection, use and sharing of Personal Information, as well as rights to know, access, correct, delete and/or opt out of certain disclosures of Personal Information. To the extent that we collect Personal Information that is subject to such laws, that information, our practices and your rights are described below. Note that certain information we collect may be exempt from such state laws because it is considered public information (because it is made available by a government entity) or covered by a federal privacy rule.

9.2. You have a right to receive information regarding the categories of Personal Information we collect, sell, disclose or otherwise share. You also have the right to receive information regarding the sources of Personal Information we collect, the purposes for which we collected it and the third parties and service providers with whom we shared it as well as the retention period or criteria for determining retention of such data. That information is provided to you in Sections 2 and 3 of this Policy.

9.3. You have the right to request access to specific pieces of Personal Information collected about you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request. Note that we may not be permitted to give you access to certain specific pieces of sensitive information (such as a driver license or social security number), or records that contain the personal information of a third party.

9.4. You have the right to request in certain circumstances that we delete any Personal Information that we or third parties on our behalf have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request and maintain a record of your request, and in some cases, we are required or permitted by law to retain all or some of your Personal Information for specific purposes. If we do, we will explain that to you in our response.

9.5. You have the right to request in certain circumstances that we correct any inaccurate Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.

9.6. We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, we may offer a one-time discount if consumers sign up for our email marketing list. The value of the data provided to us is based on the value of the discount provided to you. Participation in these incentives is voluntary and you may opt-out of the data sharing at any time.

9.7. We do not sell information as the term “sell” is traditionally understood. To the extent we sell, as the term “sell” is defined under applicable law, or share your Personal Information for cross-contextual behavioural advertising, you have the right to opt-out of any sale or sharing of Personal Information by us to third parties. You may exercise this right by advising us “Do Not Sell or Share My Personal Information” on the contact page. Please note that under applicable law your right to opt out does not apply to our selling or sharing of data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use any Personal Information we share only for that function. Additionally, certain browsers may allow you to opt-out of sales or sharing on all websites accessed through that browser. Where required by law, we will honor browser-based opt-out settings and we treat those requests in the same manner that we treat requests submitted through our contact pages.

9.8.As we describe in Section 3.3, we collect and use Sensitive Personal information when that information is needed to verify promotion winners and evaluate participants in our competitions, and otherwise as described to you at the time of collection, in the event that we run such promotions and competitions. We may also collect Sensitive Personal Information for advertising purposes. You may have the right to limit our use of your Sensitive Personal Information to only what is strictly necessary for us to provide our services to you and for the limited purposes otherwise allowed by applicable law. You may exercise this right by contacting us through our website at https://www.unistraw.com.

9.10.You have the right to request information regarding third parties to whom the company has disclosed certain categories of Personal Information during the preceding year for the third parties’ direct marketing purposes.

9.11. How to Exercise Your Rights. You may submit a request to exercise your rights described above by contacting us through our website at https://www.unistraw.com.

Applicable state law requires us to verify your identity before providing a substantive response to your request to exercise some of your rights described above. Generally, we will verify your identity by asking you to (a) provide us with your email to ensure your email is verified, and (b) confirm the right you wish to request under this Policy. In appropriate circumstances, we may ask you for additional information to verify your identity. Once your identity is verified, we will work to process your request in a timely manner in accordance with applicable law. If we cannot verify your identity, we may not be able to process your request.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so, and we will need to verify your identity directly.

9.12. Appeals. You have a right to appeal decisions concerning your ability to exercise your consumer rights. Please contact us at https://www.unistraw.com to request an appeal concerning decisions on your consumer request.

10. Updates

A notice will be posted on our Property for 30 days whenever there are material changes to this Policy. By continuing to use our Property you confirm your acceptance of the updated Policy.

11. Contact Us

If you have a question, concern or complaint about this Policy or our handling of your Personal Information, you can contact us through this website at https://www.unistraw.com.