Privacy Policy

Welcome to Ulla Labs\'s privacy policy. Ulla Labs respects your privacy and is committed to protecting your personal data.

Introduction

This privacy policy tells you how Ulla Labs uses your personal data when you visit our website www.ulla.io, interact with us, and buy our goods and services.

It also tells you about your privacy rights and how the law protects you. Ulla Labs addresses the personal data protection and terms in accordance with the General Data Protection Regulation (EU) 2016/679, which is a European regulation on data protection and privacy (GDPR).

The types of personal data we may collect include

We collect a variety of information about customers and visitors to the Ulla Labs website.

Personal data we collect fall into these categories

• Identity Data includes title, first name, last name.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card details (these data are never stored nor we have the access to full details of your payment card details!!!)
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
• Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Ulla Labs may also ask for “non-Personal information,” i.e., information that, alone, cannot be used to identify or contact you. You may be asked to submit non-Personal information with Personal information or separately. Such information may include IP address, profile information, aggregate user data, preferences, technical session information, browser type, information about your computer, hardware, software, or mobile device, including a device identifier, demographic information including gender, zip code and age, and navigational data including log files, server logs, clickstream data, and other data such as your location, where enabled, and language preference. User IP addresses are recorded for security and monitoring purposes. If you arrived at Ulla Labs website via a link from another webpage, Ulla Labs may receive aggregate or otherwise anonymous statistical information about your visit to the site. Ulla Labs monitors customer traffic patterns and site usage to help develop the design and layout of the site, and to improve the content of website. Ulla Labs may combine this automatically collected and other non-Personal information with Personal information, in which case ULLA LABS will treat the combined information as Personal information under this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you use any of these types of personal data

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

How is your personal data collected?

We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or through chat or social media.

This includes personal data you provide when you:

• order our products;
• sign up to receive the Ulla Labs newsletter;
• make enquiries or request information be sent to you;
• ask for marketing to be sent to you;
• engage with us on social media;
• enter a competition, promotion or survey;
• contact customer services; or
• leave comments or reviews on our products or services.

Automated technologies or interactions. As you interact with us, including via the www.ulla.io website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).

Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:

• Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
• Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
• Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites. We will only use your personal data when the law allows us to.

How we use your personal data?

Ulla Labs may collect Personal information from you in the context of:

• Processing your order for products or services offered by Ulla Labs
• Customer support and technical assistance;
• Contest registration and prize acceptance;
• Providing updates to you regarding your Ulla Labs products;
• Newsletter subscriptions;
• Access to Ulla Labs products or services on social networks or third party services;
• Other uses of the Services where Personal information is requested for use and/or participation.

Except as otherwise stated in this Privacy Policy, Ulla Labs does not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. Ulla Labs shares Personal Information with vendors who are performing services for the Company, such as the servers for email communications who are provided access to user’s email address for purposes of sending emails from us.

In general, the Personal Information you provide to Ulla Labs is used to help communicate with you. For example, Ulla Labs uses Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.

In general, Ulla Labs uses Non-Personal Information to help improve the Service and customize the user experience. Ulla Labs also aggregates Non-Personal Information in order to track trends and analyse use patterns on the Site. This Privacy Policy does not limit in any way Ulla Labs’ use or disclosure of Non-Personal Information and Ulla Labs reserves the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

If you provide Ulla Labs with your credit card information, Ulla Labs uses secure socket layer (“SSL”) technology to encrypt and protect the security of your personal information, including but not limited to your credit card number, when it is sent over the Internet. No method of transmission over the Internet, or method of electronic storage, is 100%% secure, however. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. We are not responsible for the functionality, privacy, or security measures of any other organization

This website uses third-party vendor such as Google AdWords, Facebook, Pinterest and Youtube service to advertise on third party websites to previous visitors to our site. It could mean that we advertise to previous visitors who have not completed a task on our site, for example using the contact form to make an enquiry. Third-party vendors use cookies to serve ads based on someone’s past visits to the http://ulla.io website. Of course, any data collected will be used in accordance with our own privacy policy and privacy policy of the third party vendor. Alternatively, you can opt out of a third-party vendor\'s use of cookies by visiting Settings pages. By using this site, you represent that you are eligible to use this Site and services as Ulla Labs’ Terms of use require.

To provide better content and service, Ulla Labs website www.ulla.io uses the Google Analytics and Hotjar web analytics service. Hotjar web analytics records mouse actions and scrolling movement, as well as basic interactions with website forms. Hotjar does not track your browsing habits across other third-party websites and all information about you which reaches Hotjar contains no personal data about you. Please see their privacy policy.

Payment information

Ulla Labs uses third party payment processors Braintree and PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors – Ulla Labs never (ever!) sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page. We only separately the last 4 digits and card type so that we can identify transactions made by a particular card and issue refunds.

For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing. We may carry out direct marketing by email, phone, text or post.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the Newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.

Of course, there are lots of different ways you’ll see adverts for Ulla out and about, and not all of these are based on using personal data. If you see Ulla adverts on websites and in social media, these may not be directed specifically at you, we might just have bid for the space. But here’s some things we may do that may be specifically directed at you

• emails, for example the newsletter;
• text messages, for example with discount codes;

We also work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.

Tracking Data, and particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of Ulla. The cookies used for this purpose are often placed on our website by specialist organisations. We also use these cookies to implement retargeting strategies.

Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts (you know, before we risk become annoying). Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

If you want more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Facebook, Pinterest and Google Adwords.

E-mail marketing You may unsubscribe from receiving marketing or other commercial emails from Ulla Labs by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as order confirmation emails or changes in our website or mobile app terms).

Cookies

You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) use for advertising. That is just part of why cookies are used.

Cookies help www.ulla.io work better and provide lots of help in the background to make the process of being a www.ulla.io customer a lot easier. You’d miss a lot of these things if they were gone – like things staying in your cart while you go off and look at other pages.

Other cookies collect information about how visitors use www.ulla.io for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don\'t collect information that identify a visitor. All information these cookies collect is aggregated and used to improve how www.ulla.io works.

There are also cookies that allow www.ulla.io to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

When you use www.ulla.io, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It\'s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Disclosures of your personal data

Ulla Labs is the sole owner of the information collected on this site. Ulla Labs will not sell, share, or rent this information to any outside parties, except as outlined in this policy.

Ulla Labs discloses potentially personally¬ identifying information only to those of employees, contractors and affiliated organizations that (i) need to know this information in order to process it on Ulla Labs’ behalf or to provide services available on websites, and (ii) that have agreed not to disclose it to others. Some of these employees, contractors and affiliated organizations may be located outside of your home country; by using Ulla Labs websites, you consent to the transfer of such information to them.

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

We may share personal data with the following categories third parties:

Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);

• auditors and professional advisers like bankers, lawyers, accountants and insurers; and
• government, regulators and law enforcement.

Ulla Labs may disclose your personal information if required by law to do so or if you violate Ulla Lab’s Terms of Service. Ulla Labs takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially information.

We share personal data with the following specific third parties:

Mailchimp: we share your data with Mailchimp to send our direct marketing campaigns to prospective and current customers. Please visit their privacy policy.

We also share data with third parties connected to advertising, retargeting and analytics. Please see Advertising, marketing and your communications preferences, for more information about who those third parties are.

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Links to Other Websites and Third Party Content

We may provide links to other websites, services, and applications, such as Facebook, that are not operated or controlled by Ulla Labs (the "Third Party Services"). The policies and procedures we described here do not apply to the Third Party services. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content, privacy policies, or practices of those Third Party Services. We encourage you to review and understand the privacy practices of any Third Party Services before providing any information to or through them.

The Services also may include an activity feed, social media buttons and widgets, such as the Facebook "Like" button or the "Share This" button. Your interactions with these features are governed by the privacy policy of the Third Party Service that provides the feature.

International Data Transfers

We may transfer your personal data to countries other than the country in which you initially provided the information for the purposes described in this Privacy Policy. For example, if you are located outside of the Slovenia, we typically transfer your personal data to Slovenia, where Ulla Labs is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.

We may transfer personal data from the European Economic Area (“EEA”) to countries that the European Commission has deemed to adequately safeguard personal information, in which case no additional safeguards are required in order to transfer this information. If we transfer your personal data to other countries, we will either transfer it subject to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules, or with your consent to the transfer, unless we are permitted by law to transfer personal data without such formalities.

Ulla Labs policy for children

Ulla Labs and its services are not directed at persons under the age of 13. We do not knowingly collect any personal information from children under 13. If a child under 13 submits personal information to Ulla Labs and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you are aware of a user under the age of 13 using Ulla Labs, please contact us.

Your Rights And Choices

Accessing, Changing and Deleting your Personal Information. Anytime you may request access to the personal data we maintain about you. If we grant your request, we will provide you with a copy of the personal data we maintain about you in the ordinary course of business, in a commonly used format. You can request to change contact choices, opt-out of our sharing with others, and review, update, correct, or delete your personal information. We will use commercially reasonable efforts to honour your request. Please note that we may be required to keep such in-formation and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.

Right to erasure (Right to be forgotten). This right can be executed when 1) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 2) The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing; 3) The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR; 4)The personal data have been unlawfully processed; 5)The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; 6)The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

Portability of personal data Under certain conditions, you may request that we transfer your personal data to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reason(s) for the rejection.

Cookies. You can typically remove and reject Cookies with your browser settings. Many browsers are set to accept Cookies until you change your settings. If you remove or reject our Cookies, it could affect how our Site works for you.

Some of our business partners that collect information about your activities on our websites and in our mobile apps may be members of organizations or programs that provide you with choices regarding the use of your browsing behaviour for purposes of targeted advertising. For example, you may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

Security

Ulla Labs maintains reasonable administrative, technical and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot guarantee that the measures we maintain will esure the security of the personal data.

How to contact us?

If you have any questions, comments or concerns about this Privacy Policy please contact us at: [email protected].

Changes to this privacy policy

This privacy policy was last updated on 21th of May 2018.

If Ulla Labs’ information practices change at any time in the future, Ulla Labs’ will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

The General Data Protection Regulation is new and the ICO is still issuing new bits of guidance about how businesses should follow it. So, you may see little updates to our privacy policy over the coming months. Be sure to check in and have read every now and then. Thank you.