Your privacy is important to us. Please read this Privacy Notice carefully to learn how we collect, use, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.
Bath Makeover by Shugarman’s Inc. dba Shugarman’s Bath (“Shugarman’s”) is the controller of your Personal Data as described in this Privacy Notice, unless specified otherwise. This Privacy Notice applies to the collection and processing of Personal Data collected by us when you visit our branded websites that link to this Privacy Notice; use our online products and services as an authorized user where we act as a controller of your Personal Data; visit our branded social media pages; visit our facilities; communicate with us (including emails, phone calls, texts or fax); or register for, attend or take part in our events, webinars, trade shows or contests.
Collection of Personal Data
We collect three types of Personal Data from you:
- Information You Provide: We collect and record any information that you provide to us directly, including any personal identifiers, professional or employment-related information, financial account information, commercial information, visual information, or internet activity information that you provide to us through this website or other medium.
- Information We Collect Automatically: We automatically collect and store information about your use of this website and our services. To do so, we may use cookie technology and other online identifiers to track your IP address, web browser, geolocation, or your activity on this site. For more information about cookies and other tracking technologies, please see our Cookie Policy.
- Other Information We Collect: We may combine data from other sources with Personal Data we collect from you. These other sources may be from third parties or from publicly available sources. This may include information related to your employment, education, commercial interactions, and internet activity.
In some cases, the collection and processing (see Section 2 below) of Personal Data is required for you to receive certain products or services. Personal Data does not include information that is anonymized or aggregated such that you cannot be identified from it. If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so and have obtained any necessary consent for the information to be used in accordance with this Privacy Notice. If you believe that your Personal Data has been provided to us improperly or want to exercise your rights relating to your Personal Data, please contact us by using the information in Contact Us section below.
Types of Personal Data We Collect
We may collect the following types of Personal Data about you:
- identifiers (e.g., name, address, phone number, IP address);
- demographic information;
- internet or other online activity information;
- geolocation data (e.g., computer/device location);
- sensitive personal information, including the following:
- Account log-in information.
- Precise geolocation.
- inferences drawn from any of the above.
Sources from which we collect your Personal Data.
We collect the categories of Personal Data listed above from the following types of sources: directly from consumers, data analytics companies, ad networks, social networks, internet service providers, service providers that help us to run our business, and data resellers such as data management platforms. We also collect Personal Data automatically via cookies, web beacons, and other tracking technologies when you use our website and online services.
Processing Your Personal Data
Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on other legal bases to collect and process your Personal Data. We process your Personal Data for the following purposes:
- Providing our services, products, and website access: We process your Personal Data relating to your access of our services, products, and other digital properties (e.g., IP address, internet activity, account information, etc.) to ensure both you and we meet our obligations under the applicable contract, terms of use, or service agreement and to project future demand as well as improve our websites and services; absent a contractual relationship, we process your Personal Data to further our legitimate interest in operating and improving our websites and services.
- Internal business purposes: We process your Personal Data to operate, maintain, and improve our services, products, and website, including customizing the content; maintaining internal business records, such as accounting, managing user accounts, document management and similar activities; enforcing our policies and rules; monitoring service usage, management reporting; auditing; and IT security and administration to meet our obligations to you to perform our contract with you, or, if no contract applies, to the extent it is necessary for our legitimate interest in operating our business in a secure and efficient manner.
- Internal research and product improvement purposes: We process your Personal Data to verify and maintain the quality or safety of our products or services; improve our products or services; design new products and services; evaluate the effectiveness of our advertising or marketing efforts; and debug and repair errors with our systems, networks, and equipment.
- Securing our facilities, websites, and services: We process your Personal Data (e.g., name, IP address, account information, internet activity) as part of our efforts to maintain, monitor and secure our facilities, websites, services, and products. This may include aggregating data, verifying accounts, investigating suspicious activity, and enforcing our terms and policies to the extent necessary to further our legitimate interest in maintaining a safe and secure website, products and services and in protecting our rights and the rights of others.
- Responding to contact requests: If you contact us electronically or by phone, we process your Personal Data (e.g., name, account information, government identifiers) to perform our contract with you, or, if no contract applies, to the extent it is necessary for our legitimate interest in responding to your inquiry and communicating with you. As provided by law, we may, with your consent, record and process communications for training, quality assurance, and administration purposes.
- Managing payments: We may process your financial information and other Personal Data (e.g., name, account information, financial history) to verify financial information and to collect or make payments to the extent that doing so is required to fulfill our contract with you.
- Marketing and Advertising: We may process your Personal Data (e.g., name, account information, purchase history, internet activity) to advertise to you, conduct market research, and to provide other personalized content based upon your Personal Data to the extent it is necessary for our legitimate interest in advertising our services or products.
- Complying with legal and safety obligations: We process your Personal Data (e.g., name, account information, payment history, internet history) when cooperating with public and government authorities, protecting our legal rights, conducting audits, and protecting against abuse of our services and products. Any such processing is based on our legitimate interest in protecting our legal rights or, when applicable, complying with a legal obligation to which we are subject.
- In connection with a corporate transaction: We may process your information if we sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change in furtherance of our legitimate interest in operating and transacting the business of the company.
In some cases, we may provide specific services or offerings subject to separate or supplemental privacy policies. In those cases, we will prominently inform you of those policies and provide those policies in an easily accessible format.
Exclusion
This Privacy Policy does not apply to Personal Data that we process about current or former employees, job applicants, and other individuals who interact with us for employment-related purposes.
Protecting Personal Data
We take commercially reasonable precautions to protect the Personal Data in our possession from loss, misuse, unauthorized access, disclosure, alteration, or destruction. While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure or error-free. Personal Data you send to or from the website or via e-mail may not be secure, and we encourage you to contact us about more secure ways to share sensitive information when necessary. Where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them and to log out of any accounts you access after your sessions.
Your Individual Rights
Depending on our relationship with you and where you may reside, you may have certain rights relating to your Personal Data based on applicable local data protection laws, including from California state privacy laws. These rights may include the right to:
- Request and receive copies of your Personal Data that we hold;
- Request additional information about how we process your Personal Data;
- Correct inaccurate or incomplete Personal Data (taking into account our use of it);
- Request deletion of your Personal Data;
- Restrict or object to our processing of your Personal Data, including restricting the sale or sharing of your data or its use for cross-context behavioral marketing. Where we process Personal Data for direct marketing purposes (either by us or third parties) or for cross-context behavioral marketing, you may not have to provide a specific reason for such objection;
- Require us (if possible) to transfer your Personal Data to another controller (i.e., data portability);
- Limit the use or disclosure of your sensitive Personal Data;
- Restrict certain disclosures of your Personal Data to third parties;
- Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
- Withdraw your consent to the processing of your Personal Data (to the extent we base processing on consent and not on another lawful basis).
We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights. You may exercise these rights, to the extent applicable, by making the request via our website at https://shugarmansbath.com/ or by sending us an email at yourteam@shugarmansbath.com or writing to us at Shugarman’s Bath 1154 Morena Blvd, San Diego, CA 92110.
If you are not happy with how Shugarman’s handles your Personal Data and we cannot provide you with a satisfactory resolution to your request, you also have the right to lodge a complaint with a supervisory body for data protection in California. If you wish to pursue any of these rights, please contact us using the details set out at the end of this Notice below.
Disclosing Personal Data to Third Parties
We share Personal Data with third parties in a manner consistent with our Terms of Use/Agreement with you. We may provide your Personal Data to the categories of recipients described below:
- Third party service providers or other entities that perform services on our behalf, help us provide you with our products and services, and that otherwise support our relationship with you (such as shipping or direct mailing organizations). These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the Personal Data in accordance with this Privacy Notice and as permitted by applicable data protection laws.
- Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
- Law enforcement, government agencies, or other regulators to comply with law or legal requirements, to enforce our agreements, and to protect our rights and the property or safety of Shugarman’s, our users, or third parties.
- Business partners that may use Personal Data for their own purposes such as:
- Advertisers, ad platforms and networks, and social media platforms;
- Third parties whose cookies and tracking touls we use as described in our Cookie Policy
- Commercial data partners to whom we make information available for their own marketing purposes; and
3rd party partners who work with us or provide distribution pathways, sales channels, and/or promotional opportunities including co-branded products and services. Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where our business partners use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those business partners for details on their practices.
- Transactional parties if we, or some or all of our assets, acquire or are acquired by another entity, including through a sale or in connection with a bankruptcy.
- Your employer or coworkers if you receive our products or services in connection with your employment.
- The public, or others with access to our Services and Services, such as when you have an opportunity to make comments, post information, or otherwise share your Personal Data in public areas of our products, services, or website.
- Entities to which you have consented to the disclosure.
We may also share Personal Data that has been deidentified or aggregated with third parties for any purpose.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Promotional and Marketing Policy
We may ask you to consent to being contacted by us for promotional and marketing purposes. However, you may opt-out of receiving promotional or marketing emails at any time by notifying us as a reply to any unwanted e-mail, by using the unsubscribe function in our newsletter, by contacting us at yourteam@shugarmansbath.com, or by writing to us at Shugarman’s Bath, 1154 Morena Blvd, San Diego, CA 92110. Requests to unsubscribe from Shugarman’s emails may take 30 business days to process.
Third-Party Websites
The website may contain links to other third-party sites. When you click on one of these links, you are visiting a website operated by someone other than us and the operator of that website may have a different privacy policy. We are not responsible for their individual privacy practices, so we encourage you to investigate the privacy policies of such third-party operators.
Children
Our website is not intended for children under 18 years of age. No one under age 18 may provide any information to us through this website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not access, use, or provide any information on the website or on or through any of its features. If we learn we have collected or received Personal Data from a child under 18 without parental consent, we will delete that information.
California Eraser Law
Any California resident under the age of eighteen (18) who has posted content or information on our digital properties can request removal by contacting us via email at yourteam@shugarmansbath.com or by calling toll free at (619) 332-2220, detailing where the content or information is posted, and attesting that you posted it. We will make reasonable, good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content that we do not control.
No Discrimination
Shugarman’s will not discriminate against any consumer for exercising their rights under any and all applicable laws.
Data Retention
Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in completed and/or terminated contracts or for other legitimate business purposes, such as to provide you with information about our products and services in case of interest. If you would like to know more about the retention periods applicable to your Personal Data, you can contact us at yourteam@shugarmansbath.com.
Changes to this Privacy Policy
We may update this Privacy Policy at our discretion to reflect changes we deem necessary or to satisfy legal requirements. We will post a prominent notice of material changes on our website.
Contact Us
We welcome comments and questions regarding this Privacy Policy. Any such questions should be directed via e-mail to yourteam@shugarmansbath.com. Additionally, you may make your request in writing to Shugarman’s Bath, 1154 Morena Blvd, San Diego, CA 92110.
Cookies and Tracking Technologies Policy
Tracking technologies (e.g., cookies, tags, pixels, fingerprinting, web beacons) are used to store and/or share information about website visitors, their systems, and browsers. Information collected by cookies and tracking technologies varies depending on the technology used and can be of a personal nature (information that directly or indirectly identifies you) and of non-personal nature (information that does not directly or indirectly identify any single individual).
We use the following tracking technologies on our website:
| Type of Technology |
Description |
Purposes |
| Cookies |
It’s a type of data from a website in the form of a text command stored within a web browser to remember information about you, such as language preference and login information, or to carry out the necessary communication transmissions (e.g. HTTP requests) to provide a service or application that you have requested. |
- Delivering security features to enhance protection against cyberattacks or abuse;
- Assisting you in navigation, providing essential functionalities related to our service, application, and website (e.g. displaying pages and visual elements);
- Assisting you in registration to our events, login, and your ability to provide feedback;
- Assisting with our promotional and marketing efforts (including behavioral advertising).
|
| Web Beacons |
It’s a small tag placed on a website resource (e.g., webpage) or in an email to track how the user interacts with the content. This interaction generates a “hit,” counting your interaction with the HTML content. For example, if you click on one of our ads on the website, a web beacon will record that interaction. |
- Acquiring essential insights into the performance of the content;
- Evaluate the effectiveness of our marketing campaigns.
|
| Web Tags or Tracking Pixels |
It’s a type of code (e.g. JavaScript code in a tag manager) or pixel (a small 1×1 transparent image) loaded into the web page to enable website features, like the web design components, or to track user’s behavior across websites and devices. These are commonly associated with social media widgets such as a like button. |
- Loading necessary features in our website, such as fonts, webpage layout, videos, and photos;
- Analysis of user experience on our website;
- Providing a better experience individually to our customers by loading personalized and enhanced content.
|
These technologies typically fall into one of three categories:
- Strictly-necessary technologies. These technologies are required for the operation of our website, our products, and our services, and therefore cannot be turned off. You can set your browser or device to block or alert you about these cookies, but functionality may be impaired.
- Analytical/Performance technologies. When you have permitted, we collect statistical information about how our website and services are used. This includes the collection of information such as your IP address or other identifiers, browser information, and information about the content you view and interact with to record how you use the website, our products, and services. These analytics services help us count users, identify popular offerings, and track the demographics and interests of our users.
- Targeting technologies. When you have permitted, these technologies record your activity on our site or using our services including the pages you have visited and the links you have followed. We may use this information to make our content more relevant to you to measure the effectiveness of our marketing. We may also share this information with third parties for this purpose. These are also optional technologies, although if you do not allow these cookies, you will experience less targeted advertising.
Cookie List
Strictly Necessary Cookies:
These cookies are essential for the operation of the website and cannot be disabled. They primarily handle security, anti-bot protection, and essential consent management.
|
Cookie Name
|
Description
|
Provider/Source
|
|
__cf_bm
|
Used by Cloudflare Bot Management to distinguish human visitors from automated bots. It helps prevent fraud and abuse on the website.
|
Cloudflare
|
|
__hs_cookie_cat_pref
|
Used by HubSpot to record the visitor’s cookie consent preferences (which categories, like analytics or marketing, were accepted or denied).
|
HubSpot
|
|
_cfuvid
|
Used by Cloudflare to apply rate limits and distinguish individual users, even if they share the same IP address, enhancing security against denial-of-service attacks.
|
Cloudflare
|
Functional Cookies:
These cookies enable essential user-facing features, particularly for your live chat system, to provide a smoother and more personalized experience.
Analytics Cookies:
These cookies collect information about how visitors use the website (page views, clicks, session length) to measure and improve performance.
|
Cookie Name
|
Description
|
Provider/Source
|
|
_clck
|
Used by Microsoft Clarity to identify a returning user across visits, helping to keep settings consistent and associate all sessions with the same visitor ID.
|
Microsoft Clarity
|
|
_clsk
|
Used by Microsoft Clarity to group a visitor's actions during a single session (like viewing different pages) into one recording for behavioral analysis (heatmaps and session recordings).
|
Microsoft Clarity
|
|
_ga
|
Primary cookie set by Google Analytics 4 (GA4) or Universal Analytics. Registers a unique ID to identify a user across visits and devices.
|
Google Analytics
|
|
_ga_NYXG70T5H7
|
Specific cookie used by Google Analytics 4 (GA4) to retain session state.
|
Google Analytics 4
|
|
_gat_UA-154758590-1
|
Used by Google Analytics to throttle the request rate, limiting the collection of data on high-traffic sites.
|
Google Analytics
|
|
_gid
|
Used by Google Analytics to store and update a unique value for each page visited, distinguishing users for the purposes of collecting usage statistics.
|
Google Analytics
|
|
calltrk_landing
|
Used by CallRail (call tracking) to capture the URL of the first page a visitor lands on, attributing phone calls to the correct marketing source.
|
CallRail
|
|
calltrk_referrer
|
Used by CallRail to store the URL of the referring site (e.g., Google Search, another website) that brought the visitor to the site.
|
CallRail
|
|
calltrk_session_id
|
Used by CallRail to store a unique identifier for a user's browser session to link their web activity with any phone calls they make.
|
CallRail
|
|
ANONCHK, CLID, MR, MUID, SM, SRM_B
|
These cookies are associated with Microsoft Advertising (Bing Ads) and are used for tracking, unique user identification, and managing ad relevance and syncs across different services.
|
Microsoft
|
Targeting Cookies:
These cookies are set by advertising partners and social media platforms to build a profile of your interests and show you relevant ads on other sites.
|
Cookie Name
|
Description
|
Provider/Source
|
|
__141_cid, __141_exp
|
Associated with advertising platforms for campaign tracking and frequency capping.
|
Beachfront Media
|
|
_fbp
|
Used by Meta (Facebook) Pixel to store and track visits across websites. It helps deliver a series of advertisement products, such as real-time bidding from third-party advertisers.
|
Meta Platforms (Facebook)
|
|
_gcl_au
|
Used by Google AdSense or Google Ads to measure the effectiveness of advertising campaigns across websites using their services.
|
Google Advertising
|
|
_tt_enable_cookie, _ttp
|
Used by the TikTok Pixel to measure and improve the performance of advertising campaigns and to personalize the user's experience (including ads) on TikTok.
|
TikTok
|
|
uuid2
|
Used by AppNexus (now Xandr) to record information that helps differentiate between devices and browsers for ad delivery, performance assessment, and payment attribution.
|
Xandr (AppNexus)
|
|
XANDR_PANID
|
Used by Xandr (a major advertising platform) for tracking user behavior, optimizing ad experience, and enabling marketing functionality.
|
Xandr
|
|
TAPAD, TapAd_3WAY_SYNCS, TapAd_DID, TapAd_TS
|
Used by Tapad, Inc., a technology company that builds a "cross-device graph" to connect digital identifiers across a user’s multiple devices (phone, tablet, computer) for targeted advertising and measurement.
|
Tapad, Inc.
|
|
test_cookie
|
Used by Google DoubleClick (Google's ad-serving platform) to check if the user's browser supports cookies.
|
Google DoubleClick
|
|
audit, audit_p, cee, did, didts, EE, i, nnls, PugT, pxrc, rlas3, SCM, SCM675, SCMt, suid, suid_legacy, t, t_gid, t_pt_gid, tluid, tluidp, uid_syncd, uid_syncd_secure
|
These are various identifiers and synchronizing cookies used by numerous Demand-Side Platforms (DSPs) and Supply-Side Platforms (SSPs) in programmatic advertising (e.g., Index Exchange, Adform, The Trade Desk). They are essential for ad exchanges to match users, serve personalized ads, and track conversions.
|
Programmatic Ad Networks
|
|
intentIQ, intentIQCDate, IQver
|
Associated with IntentIQ, a digital identity resolution service that helps advertisers and publishers recognize users across devices for ad targeting and measurement.
|
IntentIQ
|
|
fullthrottlelims_t2, khaos, khaos_p
|
Associated with specific third-party data providers or marketing platforms, for audience segmentation and personalized content delivery.
|
Third-Party Data/Marketing
|
SMS Privacy Policy
Shugarman’s Bath is committed to protecting your privacy. This Privacy Policy (the “Policy”) governs how we treat the Personal Data that we collect and receive from you in connection with your use of the SMS Service (“Service”). This Policy is incorporated into the SMS Terms of Service stated below.
By using the Service, you agree to the terms of this Policy. Shugarman’s Bath reserves the right, in its sole discretion, to modify or change this Policy at any time with or without prior notice to you. The date of the last update will be posted at the top of this Policy for your convenience. This Policy, and any changes, are effective as soon as posted. Your continued use of the Service following the posting of any changes to the Policy constitutes your full acceptance of those changes.
“Personal Data” is information that individually identifies you, such as your mobile phone number or user/screen name, as well as any Personal Data that you choose to include in messages you send through the Service.
What Personal Data is Collected About You
Through the use of the Service, Shugarman’s Bath will receive the following information: your mobile phone number when you send a text message to us, the text of messages that you send to other users of the Service, any user or screen name that you select in connection with the Service, as well as any comments or feedback regarding the Service that you send to us.
How Shugarman’s Bath Uses Personal Data About You
We use Personal Data to (a) provide you with the Service, (b) process and respond to inquiries; (c) improve the Service; (d) if necessary, contact you with important announcements or messages; and (e) conduct research.
Each message that you send through the Service (either to us or to other users of the Service) is stored on our servers. We retain these messages on our servers. Shugarman’s Bath utilizes servers and services owned by third parties.
Disclosure of Your Information
We will not rent or sell your Personal Data to other companies or individuals, unless we have your consent. We may use or disclose such information in any of the following limited circumstances:
- We have your consent.
- We need to enforce our SMS Terms of Service.
- We provide such information to trusted businesses or persons for the sole purpose of processing Personal Data on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Policy and appropriate confidentiality and security measures. If the third party fails to comply with our terms, Shugarman’s Bath is not accountable in any way for any liability or reimbursement.
- We provide such information to third parties who have entered into non-disclosure agreements with us.
- We provide such information to a company controlled by, or under common control with, Shugarman’s Bath for any purpose permitted by this Policy.
- We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights, or the legal rights of others, or defend against legal claims.
- We believe it is necessary to share Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Shugarman’s Bath’s SMS Terms of Service, or as otherwise required by law.
- We transfer Personal Data about you if Shugarman’s Bath is, or its assets are, acquired by or merged with another company.
- We may share aggregated information with others without further notice. An example of this would be the number of people who used the Service in a given month or the total number of texts sent in a given week.
Security
Shugarman’s Bath takes precautions to ensure the security of your Personal Data. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Data despite our efforts. You should note that in using the Service, your information will travel through third party infrastructures which are not under our control (such as a third party SMS delivery platform or your carrier network).
We cannot protect, nor does this Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information to other users.
Opting in
A mobile user might opt-in by:
- Entering a phone number online;
- Sending an Mobile Originating (MO) message containing an advertising keyword;
- Filling out a paper form that includes their phone number;
- Filing out a digital form following the connection with a QR Code; or
- Signing up at a point-of-sale location.
Opting out
Shugarman’s Bath’s gives you the ability to opt out of the Service for any reason. You can opt out by texting “STOP” or “QUIT” to 619-605-0087.
We reserve the right to send you certain communications relating to the Service, such as announcements and administrative messages, without offering you the opportunity to opt-out of receiving them.
Children
The Service is not intended for children under 18, and Shugarman’s Bath does not knowingly collect information from children under the age of 18. By using the Service, you are representing that you are at least 18 years old. No one under the age of 18 should submit any Personal Data. If we learn we have collected or received Personal Data from a child under 18 without parental consent, we will delete that information.
Intended Audience
Shugarman’s Bath requires that users of this service be limited to U.S. residents only.
Questions or concerns?
If you have any additional questions regarding this Policy, please feel free to contact us any time by texting “HELP” to 619-605-0087.
