Legal notice

PRIVACY POLICY

Last updated: June 11, 2026

At Soohly, we take the protection of your personal data seriously. This Privacy Policy explains what information we collect, how we use it, and your rights.

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1. DATA CONTROLLER

The controller of your personal data is:

Soohly Inc.
[Address in the United States]
State of formation: [State]
Employer Identification Number (EIN): [XX-XXXXXXX]

Contact for any questions regarding data protection:
Email: shop@soohly.com

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2. DATA WE COLLECT

We collect the following data:

Data you provide directly:
- Identification data: first name, last name, email address, phone number
- Shipping and billing address
- Order data: products purchased, amount, payment method (no full card details stored)
- Communication data: messages sent through the contact form or by email
- Newsletter subscription and marketing preferences

Data collected automatically:
- Technical data: IP address, browser type, operating system, device used
- Browsing data: pages visited, time spent, clicks, referring source
- Location data: country and city (based on IP address)
- Cookies and similar tracking technologies (see our Cookie Policy)

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3. PURPOSES OF DATA PROCESSING

Your data is used for the following purposes:

Purpose | Legal basis
--- | ---
Order processing and shipping | Performance of a contract
Customer support and after-sales service | Performance of a contract
Sending marketing communications (email, SMS) | Consent (opt-in)
Improving our products and services | Legitimate interest
Website statistics and analytics | Legitimate interest / Consent
Fraud prevention and site security | Legitimate interest / Legal obligation
Compliance with tax and legal obligations | Legal obligation

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4. DATA RECIPIENTS

Your data may be shared with:

- Our technical service providers (Shopify hosting, email routing, payment processors, shipping carriers)
- Our marketing and analytics providers (with your consent when required)
- Public authorities in the event of a legal obligation or judicial request

We never sell your personal data to third parties for their own marketing purposes.

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5. INTERNATIONAL DATA TRANSFERS

Some of our service providers may be located outside the United States. In this case, we ensure that appropriate safeguards are in place to protect your data, in accordance with applicable laws (Standard Contractual Clauses or equivalent frameworks).

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6. DATA RETENTION

Your data is retained for the periods necessary to fulfill the purposes described above:

- Customer account data: for the duration of the business relationship, then archived for 5 years for legal purposes
- Marketing prospect data: 3 years from the last contact
- Invoicing data: 7 years (U.S. tax and accounting obligations)
- Browsing data (cookies): maximum 13 months

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7. YOUR RIGHTS

In accordance with applicable data protection laws — including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and similar state laws (Virginia CDPA, Colorado CPA, Connecticut CTDPA, Utah UCPA, Texas TDPSA) — you have the following rights over your personal data:

- Right to know / access: obtain confirmation and a copy of the personal data we hold about you
- Right to correct: request correction of inaccurate or incomplete data
- Right to delete: request deletion of your data, subject to legal retention obligations
- Right to opt out of the sale or sharing of personal data (Soohly does not sell your data)
- Right to opt out of targeted advertising and profiling
- Right to non-discrimination: we will not treat you differently for exercising your rights
- Right to withdraw consent: at any time, for processing based on consent
- Right to lodge a complaint with your state attorney general or applicable regulatory authority

To exercise these rights, contact us at shop@soohly.com, providing proof of identity. We will respond within 45 days (extendable once by 45 additional days if necessary, in accordance with CCPA/CPRA).

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8. COOKIES

The Site uses cookies and similar technologies to ensure its proper functioning, improve your experience, analyze traffic and personalize advertising.

Types of cookies used:
- Strictly necessary cookies (site functioning)
- Functional cookies (preferences, cart)
- Analytics cookies (Google Analytics or equivalent)
- Marketing cookies (Meta Pixel, Google Ads, TikTok Pixel, etc.)

You can manage your cookie preferences at any time via the banner displayed on the Site or your browser settings.

For more information, please see our Cookie Policy.

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9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your data:

- SSL/TLS encryption of communications
- Secure storage of data
- Restricted access to authorized personnel only
- Regular security audits
- PCI DSS-compliant payment processing

Despite these measures, no method of transmission over the Internet is 100% secure. We cannot therefore guarantee absolute security of your data.

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10. MINORS

The Site is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors under 13 (COPPA — Children's Online Privacy Protection Act).

If you believe your child has provided us with personal information, please contact us at shop@soohly.com so we can delete it.

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11. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time to reflect changes in our practices or applicable laws.

The applicable version is the one published on the Site on the date of your visit. Last update: June 11, 2026.

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12. CONTACT

For any questions about this Privacy Policy or to exercise your rights:

Email: shop@soohly.com
Postal address: [Address in the United States]

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Soohly is committed to processing your personal data with respect, transparency and security. Your privacy is our priority.