PRIVACY POLICY

1. INFORMATION WE COLLECT

Depending on how you interact with Soothie, we may collect the following categories of information.

Information You Provide Directly

We may collect:

• First and last name
• Email address
• Billing or mailing address, including city, state or province, ZIP or postal code, and country
• Account and login information
• Information submitted through our contact forms, including the content of your message
• Information you provide when purchasing or accessing a course, membership, digital product, event, consultation, or other Service
• Communications you send to us
• Marketing and email preferences
• Information you voluntarily submit or post within Soothie Circle

We do not currently collect telephone numbers through our Website for marketing purposes.

Payment Information

When you purchase a product or Service, payments may be processed by third-party payment processors such as Stripe.

We generally do not directly receive or store your complete credit or debit card number. Payment processors may collect payment card information, billing information, transaction information, and other information necessary to process your purchase.

Soothie Circle and Information About Children

Soothie Circle is an adult community designed for parents and caregivers.

Members may voluntarily discuss their experiences caring for a child with eczema and may provide information concerning their child, such as:

• Age
• Eczema symptoms and skin concerns
• Allergies or sensitivities
• Medications or treatments
• Diagnoses
• Triggers
• Care routines
• Other health-related information relevant to the discussion

Because this information may concern a child and may include health-related information, we encourage members to share only what is reasonably necessary to participate in the community and to avoid posting identifying information about a child.

Please do not post a child's full name, home address, school, contact information, government identification information, or other information that could unnecessarily identify or locate the child.

Information posted within community areas may be visible to other members of that community. You should therefore carefully consider what information you choose to disclose.

Soothie does not require members to provide information about their child's health in order to browse the Website.

2. INFORMATION COLLECTED AUTOMATICALLY

When you visit or use our Website or Services, we and our service providers may automatically collect certain information, including:

• IP address
• Browser type
• Device type and identifiers
• Operating system
• Pages viewed
• Links clicked
• Referring and exit pages
• Approximate geographic location derived from an IP address
• Date and time of visits
• Website interactions
• Course or account activity
• Cookie and similar technology identifiers
• Advertising and conversion information

We may collect this information through cookies, pixels, tags, software development kits, and similar technologies.

3. COOKIES, ANALYTICS AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to operate the Website, remember preferences, understand how visitors use our Services, measure performance, and support our advertising.

These technologies may include services provided by:

• Google Analytics
• Google Ads
• Meta
• Pinterest
• TikTok
• Kajabi
• Other analytics, advertising, and technology providers we may use from time to time

These providers may collect information about your device, browsing activity, interactions with our Website, purchases, and other online activity.

Some advertising technologies may allow us to measure advertising effectiveness, create audiences, show advertisements to previous Website visitors, or deliver advertisements that may be more relevant to users.

Where required by applicable law, we will request consent before using non-essential cookies or similar tracking technologies.

You may also be able to manage certain cookie preferences through the cookie controls made available on our Website and through your browser settings.

4. ANALYTICS

We may use Google Analytics and similar analytics services to better understand Website traffic and usage.

These services may collect information such as your IP address, browser and device information, pages visited, interactions with the Website, and other usage information.

Google's use of information is governed by its own privacy practices.

5. ADVERTISING AND REMARKETING

We may use advertising and remarketing services provided by companies including:

• Google
• Meta, including Facebook and Instagram
• Pinterest
• TikTok

These services may use cookies, pixels, or similar technologies to recognize your browser or device, measure conversions, create advertising audiences, and show advertisements based on interactions with our Website or other websites and services.

For example, if you visit Soothie and later use another website or social media platform, you may see an advertisement for Soothie.

Depending on applicable law, certain disclosures of personal information to advertising partners for cross-context behavioral or targeted advertising may be considered a “sale,” “sharing,” or “targeted advertising,” even when no money is exchanged for the information.

Please see the California Privacy Rights section below for additional information.

6. EMAIL COMMUNICATIONS

If you subscribe to our email list, request information, download a resource, create an account, purchase a product, or otherwise provide your email address, we may send you transactional, educational, administrative, and, where permitted, marketing communications.

Our email and course communications may be provided through Kajabi.

You may unsubscribe from marketing emails at any time by using the unsubscribe link contained in our marketing emails.

Even if you opt out of marketing emails, we may continue sending non-promotional communications when necessary, such as purchase confirmations, account information, security notices, or communications relating to Services you have purchased.

7. HOW WE USE PERSONAL INFORMATION

We may use personal information to:

• Operate and maintain our Website and Services
• Create and manage user accounts
• Provide courses, memberships, digital products, and Soothie Circle
• Process purchases and transactions
• Provide customer service
• Respond to questions and contact-form submissions
• Send administrative and transactional communications
• Send marketing communications where permitted
• Personalize and improve our Services
• Understand Website and course usage
• Conduct analytics
• Measure marketing and advertising effectiveness
• Conduct advertising and remarketing
• Maintain the security and integrity of our Website
• Detect and prevent fraud, misuse, or security incidents
• Enforce our agreements and policies
• Comply with legal obligations
• Establish, exercise, or defend legal claims
• Carry out other purposes disclosed to you when information is collected or with your consent

8. HOW WE DISCLOSE INFORMATION

We may disclose personal information to service providers and other parties that help us operate our business, including providers of:

• Website and course hosting
• Community functionality
• Payment processing
• Email delivery and marketing
• Analytics
• Advertising and remarketing
• Scheduling
• Customer support
• Information technology and security
• Professional services, such as legal and accounting services

These providers may include Kajabi, Stripe, Google, Meta, Pinterest, TikTok, and Calendly, depending on the Services you use and the technologies active on our Website.

We may also disclose information when reasonably necessary to comply with law, respond to lawful governmental requests, protect our rights or the safety of others, investigate fraud or security concerns, or enforce our agreements.

If Soothie is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction, personal information may be disclosed or transferred as part of that transaction.

We may also disclose information at your direction or with your consent.

9. THIRD-PARTY SERVICES

Our Website and Services rely on third-party providers. Their processing of personal information may also be governed by their respective privacy policies.

These may include:

Kajabi — Website, course, account, community, and email infrastructure.

Stripe — Payment processing.

Google — Analytics, advertising, measurement, and related services.

Meta — Facebook and Instagram advertising, analytics, pixels, and related services.

Pinterest — Advertising, measurement, and pixel technologies.

TikTok — Advertising, measurement, and pixel technologies.

Calendly — Appointment and scheduling functionality.

Your interaction with these third parties may be subject to their own terms and privacy practices.

10. SOCIAL MEDIA

Soothie maintains a presence on various social media platforms, including Facebook, Instagram, TikTok, Pinterest, and other platforms.

When you interact with Soothie through social media, such as by following our accounts, commenting, sharing content, sending messages, or engaging with our posts or advertisements, the applicable social media platform may collect and process information about your activity in accordance with its own privacy practices.

Please be aware that information you choose to post or share publicly on social media may be visible to others. We encourage you to review the privacy policies and privacy settings of the social media platforms you use.

11. CHILDREN'S PRIVACY

Soothie's Website, products, courses, memberships, and community are intended for parents, caregivers, and other adults and are not directed to children under 13.

We do not knowingly collect personal information directly from children under 13.

Because Soothie provides education and community resources concerning childhood eczema, adult parents and caregivers may voluntarily provide information about their children, including age and information concerning eczema, symptoms, allergies, medications, diagnoses, treatments, and related experiences.

Such information should be provided only by an adult parent, legal guardian, or caregiver authorized to provide it.

We encourage users not to disclose information that unnecessarily identifies a child.

If you believe a child under 13 has directly provided personal information to us without appropriate parental consent, please contact us at [email protected] so that we can investigate and take appropriate action.

12. HEALTH INFORMATION

Soothie provides educational resources and support for parents and caregivers and is not a healthcare provider or medical practice.

Information concerning eczema, allergies, symptoms, medications, diagnoses, or other health matters that users voluntarily provide to Soothie or within Soothie Circle is used in connection with providing and administering our Services and community.

Information submitted to Soothie should not be considered a substitute for communication with a licensed healthcare professional.

Please use discretion when providing health-related information through community posts, forms, or email.

13. DATA RETENTION

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including providing our Services, maintaining accounts and transaction records, complying with legal and accounting obligations, resolving disputes, enforcing agreements, and protecting our legitimate business interests.

Retention periods may vary depending on the type of information, why it was collected, and applicable legal requirements.

When information is no longer reasonably necessary, we may delete, anonymize, or otherwise dispose of it in accordance with applicable law.

14. DATA SECURITY

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information.

However, no website, electronic transmission, or storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted to or stored by us.

You are responsible for maintaining the confidentiality of your account credentials and should notify us if you believe your account has been compromised.

15. INTERNATIONAL USERS AND GDPR

If you are located in the European Economic Area (“EEA”), United Kingdom, or another jurisdiction providing similar data-protection rights, applicable law may provide you with additional rights.

Legal Bases for Processing

Where GDPR or UK GDPR applies, we process personal data under one or more lawful bases, including:

Contract: Processing necessary to provide products, memberships, courses, accounts, or Services you request.

Consent: Processing based on your consent, including certain marketing communications and non-essential cookies where consent is required.

Legitimate Interests: Processing reasonably necessary for legitimate business interests, such as operating and improving our Services, customer support, security, fraud prevention, and certain analytics or marketing activities where permitted by law.

Legal Obligations: Processing necessary to comply with applicable legal requirements.

Your Rights

Subject to applicable law and exceptions, you may have the right to:

• Access personal data we hold about you
• Correct inaccurate personal data
• Request deletion of personal data
• Restrict certain processing
• Object to certain processing
• Receive certain personal data in a portable format
• Withdraw consent where processing is based on consent
• Object to direct marketing
• Lodge a complaint with your applicable data-protection authority

Withdrawing consent does not affect the lawfulness of processing conducted before withdrawal.

International Transfers

Soothie is based in the United States. If you access our Services from outside the United States, your personal information may be transferred to, stored in, or processed in the United States or other countries where we or our service providers operate.

Where required, appropriate safeguards will be used for international transfers of personal data.

16. CALIFORNIA PRIVACY RIGHTS — CCPA/CPRA

This section applies to California residents to the extent Soothie is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

Depending on how you interact with Soothie, we may collect categories of personal information including:

• Identifiers, such as name, email address, postal address, IP address, and online identifiers
• Customer records information
• Commercial information, such as products or Services purchased
• Internet or other electronic network activity
• Approximate geolocation information
• Inferences that may be generated from online activity
• Account and authentication information
• Communications and content you submit
• Other information you voluntarily provide

Adult users may also voluntarily provide health-related information concerning their children through Soothie Circle.

We collect these categories from users directly, automatically through their interaction with our Website and Services, and from service providers and advertising or analytics partners.

We use these categories for the purposes described elsewhere in this Privacy Policy.

Sale and Sharing of Personal Information

Soothie does not sell personal information for money.

However, we may use advertising and analytics technologies provided by companies such as Google, Meta, Pinterest, and TikTok. Certain disclosures of identifiers and internet or electronic network activity to advertising partners for cross-context behavioral advertising may constitute “sharing” under California law.

Where applicable, California residents have the right to opt out of the sale or sharing of their personal information.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

California Rights

Subject to applicable law and exceptions, you may have the right to:

• Know the categories and specific pieces of personal information we collect
• Know the categories of sources from which information is collected
• Know our purposes for collecting, using, selling, or sharing information
• Know the categories of third parties to whom information is disclosed
• Request deletion of certain personal information
• Request correction of inaccurate personal information
• Opt out of the sale or sharing of personal information
• Limit certain uses or disclosures of sensitive personal information, where applicable
• Receive equal service and not be discriminated against for exercising privacy rights

You may submit a privacy request by emailing [email protected]

We may need to verify your identity before completing certain requests. An authorized agent may submit a request on your behalf where permitted by California law, subject to appropriate verification.

Global Privacy Control

Where required by applicable law, we will recognize and process applicable browser-based opt-out preference signals, such as the Global Privacy Control (“GPC”), as requests to opt out of the sale or sharing of personal information for the browser or device sending the signal.

17. CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CalOPPA)

In accordance with applicable California law, users may visit our Website without creating an account, although certain features require registration or the provision of personal information.

Our Privacy Policy is made available through a link on our Website.

We may update this Privacy Policy periodically. When we make changes, we will update the “Last Updated” date displayed at the beginning of this Policy.

Do Not Track

Some browsers provide a “Do Not Track” (“DNT”) setting. Because there is not currently a universally accepted standard for responding to DNT signals, our Website may not respond to traditional DNT signals.

This is separate from legally recognized opt-out preference signals such as Global Privacy Control, which we will honor where required by applicable law.

18. YOUR PRIVACY CHOICES

Depending on your location and applicable law, you may have choices regarding how your information is processed.

You may:

• Unsubscribe from marketing emails through the unsubscribe link in an email
• Adjust cookie preferences through available Website controls
• Adjust browser cookie settings
• Exercise applicable privacy rights by contacting us
• Opt out of certain advertising-related sharing where required by applicable law

Some cookies are necessary for the Website, account, checkout, or other Services to function and therefore may not be disabled through all privacy controls.

19. THIRD-PARTY LINKS

Our Website may contain links to third-party websites, social networks, or services.

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policy of any third-party website or service you use.

20. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our Services, technology, legal requirements, or business practices.

When we update this Policy, we will revise the “Last Updated” date at the top of the page. If required by applicable law, we may provide additional notice regarding material changes.

21. CONTACT US

If you have questions about this Privacy Policy, our privacy practices, or would like to exercise an applicable privacy right, please contact:

Soothie Co. LLC

Boca Raton, FL

United States

Email: [email protected]

Website: soothieco.com