Privacy Policy – Wi Spa USA

Wi Spa and wispausa.com Notice of Privacy Practices

This Notice of Privacy Practices (‘Notice’) was updated in March 2023.

This Notice applies to Personal Information collected, processed, or stored by and between Wi Spa and wispaisa.com.

Your access to and use of our services means you agree to the terms in this Notice.

This Notice may be updated from time to time. Wi Spa will notify you of any changes by posting an updated Notice on this page. We encourage you to refer to this Notice periodically so that you understand our current privacy practices.

If you have any questions about this Notice, please contact our Customer Service department:

By email at info@wispausa.com
By phone at (213) 487-2700
By mail at:

Wi Spa

2700 Wilshire Blvd.

Los Angeles, CA 90057

Why We Collect and Use Information

We at Wi Spa understand that you entrust your data to us. We value that trust.

Your Personal Information will be retained only as long as necessary to carry out the purposes outlined in this Notice. Personal Information will be retained and disposed of in accordance with Wi Spa Data Retention Policy and Schedule.

We may combine information collected from different sources. Below is a summary of the primary ways we collect and use information:

Primary Reasons for Data Collection	Uses
Product and Service Fulfillment (Fulfillment)	Fulfill, manage, and communicate with you about transactions. Establish and service your profile on our websites or mobile apps. Provide customer service and alert you to product or shipping information. Provide personal services.
Marketing, Promotions and Advertising (Advertising)	Deliver information about products, services, and promotions. Provide interactive features on website. Identify product and shopping preferences using the information we collect from you and about you. Administer contests, sweepstakes, promotions, surveys, and focus groups.
Internal Operations (Operations)	Improve the effectiveness of our websites, store, merchandise assortment, and customer service. Conduct business analysis, such as analytics, projections, and identifying areas for operational improvement.
Fraud Prevention, Security and Compliance (Security)	Protect our assets and prevent fraudulent transactions. Validate credentials and authenticate customers when logging into your online profileor transacting in-store. Protect the security and integrity of our services and our data. Assist law enforcement and respond to legal/regulatory inquiries.
Credit Card and Banking (Credit)	Process your payments and address your order inquiries and requests. Offer you additional products or services that may be of interest

Safeguarding Information

Wi Spa and wispausa.com have implemented procedural, technical, and administrative measures to safeguard the information we collect and use. For your protection, we designed our technology-enabled services to accept orders only from the secured web.

No security safeguards or standards are guaranteed to provide 100% security. You should always use appropriate self-protection measures and practice safe browsing on all websites.

Categories of Information We Collect and How We Collect It

Wi Spa collects certain information from you and about you. Information is collected directly from you, or through other means.

We may collect or use the information made available to us through third-party platforms, online databases, and directories, or other means. We specify that data sourced from these third parties must be legitimately obtained. Note that this information may be governed by the privacy statement of the third party.

Categories of Information We Collect and How We Collect It	Categories of Sources from which Personal Information is Collected	Business or	Commercial	Purposes	for Data	Collection
.	,	Fulfillment	Advertising	Operations	Security	Credit
Sensitive Personal Information Driver’s license number, account log-in, password, debit/credit card number, geolocation, ethnic origin Sensitive Personal Information below is denoted with an asterisk (*).	Information you provide Placing an order, taking advantage of other programs online or in-store (i.e., MyClient/Clienteling).	X	X	X	X	X
Identifiers real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number*	Information You Provide Creating a profile, placing an order, creating a registry, signing up for events, or taking advantage of other programs online or in-store (i.e., MyClient/Clienteling), or contacting us through the “Live Chat” feature on our website. Information We Collect Through Data Collection Technologies When you visit our websites, use our mobile apps, shop in our stores, or interact with our wireless services or other technologies. This information is either automatically collected or is customer-initiated. Information From Other Sources We may provide and receive information about you, with or from our service providers and vendors.	X	X	X	X	X
Commercial Information products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Information You Provide Placing an order, creating a registry, signing up for events, or taking advantage of other programs online or in-store. Information From Other Sources We may provide and receive information about you, with or from our service providers and vendors.	X	X	X	X	.
Biometric Information* voice recordings, facial recognition	Information You Provide Calling, chatting, emailing, or otherwise contacting our customer service team. Information We Collect Through Data Collection Technologies Fraud and security activities when visiting our stores or placing online orders.	X	X	X	X	X
Internet or Other Electronic Network Activity Information browsing history, search history, information regarding a customer’s interaction with an Internet website application, or advertisement	Information We Collect Through Data Collection Technologies When you visit our websites, shop in our stores, or interact with our wireless services or other technologies, tagging Wi Spa on your social platforms, or interacting with our social platforms. This information is either automatically collected or customer-initiated.	X	X	X	X	.
Geolocation	Information We Collect Through Data Collection Technologies When shopping on our website we collect geolocation data such as IP address.	X	X	X	X	.
Precise Geolocation*	Information We Collect Through Data Collection Technologies We collect location data when your device is set to provide location information or when you have notified the store that you have arrived to pick up your curbside order.	X	.	X	.	.

Who We Share Your Information With

Who We Share With	Categories of Information	Business and Commercial Purpose(s)	Disclosed Y/N	Sold/Shared Y/N
Internally with any Wi Spa’s brand, Website, and Info You Post on our Social Media	Identifiers, Commercial Information, and Information you post, such as information you post in our reviews feature or share on your gift registry	Offer products and services that may be of interest or to fulfill our obligations to you	N/A	N/A
Our Service Providers	Identifiers, Commercial, Biometric Information, Internet or Other Electronic Network Activity, Sensitive Personal Information, or any information you post with third parties who facilitate operations and perform services on our behalf	Provide services to Wi Spa so we can provide products and services to you	Y	N
Our Business Partners	Identifiers, Commercial Information, Internet or Other Electronic Network Activity, Sensitive Personal Information	Provide products and services that enhance our offering portfolio to help us serve you better	Y	N
Third Parties for Marketing Purposes	Identifiers, Commercial, Internet or Other Electronic Network Activity Information, or Sensitive Personal Information	For marketing purposes, including third parties whose products or services we believe you may be interested in. For third parties’ own marketing purposes. These third parties may also share your information with others and may include delivery of Interest-based advertising.	Y	Y
Any Successors to All or Part of Our Business	All Categories of Personal Information you have entrusted to Wi Spa	If Wi Spa merges with, acquires or is acquired by another business entity your Personal Information may be shared with the new company. This may include an asset sale, corporate reorganization, or other change of control.	N/A	N/A
Any Compliance or Legislative Organization, as Required	All Categories of Personal Information you have entrusted to Wi Spa	When responding to a court order or subpoena, if a government agency or investigatory body requests information, or when we are investigating potential fraud. We may also share information if you are the winner of sweepstakes or other contests.	Y	Y

Our Use of Information Technologies

The following section describes technologies we use when you interact with us online, shop in our stores, or use our wireless services.

Wi Spa uses cookies, pixels, software development kits (SDKs) and other tracking technologies to deliver, monitor, and improve our websites, mobile-enabled web and display content. Approved third parties may also place cookies on your web or mobile browser when you use our online services.

How Wi Spa Uses Automated Technologies:

Technology	Description of Interaction	Primary	Area	Utilizing	This	Tech
.	.	Fulfillment	Advertising	Operations	Security	Credit
Cookies, Pixels, Tags, and SDKs	We use these technologies to improve our services and provide you with the best possible experience including to: identify you, provide relevant, interest-based advertising, remember your preferences, secure your access, know when content has been shown to you, provide aggregated auditing, research, and reporting for advertisers, understand and improve our online services, identify you across devices, such as smartphones, tablets, computers, or related browsers, and detect and defend against fraud and other risks.	X	X	X	X	.
Website Optimization Services	Wi Spa shares data with Google Analytics and Adobe Analytics to understand and optimize website performance and enhance website usability for our customers. These services are required to maintain data securely and are not permitted to share data collected with parties other than Wi Spa. Google Analytics may associate and group session visits to our websites from various browsers and devices.	.	X	X	.	.

Other information technologies:

Technology	Description of Interaction	Primary	Area	Utilizing	This	Tech
.	.	Fulfillment	Advertising	Operations	Security	Credit
Interest-Based or Online Behavioral Advertising (OBA)	Wi Spa uses third-party advertising companies to serve interest-based advertisements. These companies compile information from various online sources (including mobile-enabled browsers and apps) to match user profiles with ads we believe will be relevant, interesting, and timely	.	X	X	.	.
Social Networks and Tech Advertising Programs	Wi Spa has relationships with several social networks and tech companies. These companies have specific interest-based ads programs that match customers that have shown interest in Wi Spa through our websites or other services with their individual profiles (such as on Facebook) and platforms (such as Facebook and Google). This matching allows us to deliver relevant, interest-based ads on those companies’ networks	.	X	.	.	.
In-Store Wi-Fi Services	Wi Spa locations may offer free Wi-Fi services to customers. Examples of data automatically collected through our Wi-Fi service include information about your device, including a MAC Address, random IP address, and telemetry data (such as signal strength and qualify) related to your use of Wi-Fi service. This data is anonymized and used to provide operational insights such as foot traffic volumes and dwell times. Wi-Fi data is anonymously collected or de-identified unless we receive consent to use Wi-Fi data in a manner that identifies you or your device(s).	X	X	X	X	.
Radio Frequency Identification (RFID)	Radio Frequency Identification (RFID) tags consist of a small chip and antenna that provide a unique identifier for products. RFID s must be scanned by a specific type of reader near the tag to retrieve tag data. RFID is not used to track or monitor any items once you leave our stores.	X	.	X	X	.
Video Cameras	We use cameras in our stores for security purposes, loss prevention, and asset protection. We also use cameras in our stores for operational purposes, such as traffic pattern analysis. Cameras may include technology to capture age range, gender, and dwell time. We will not use cameras to personally identify you, without your consent, except when the identification is for security, anti-theft, or law enforcement purposes	X	.	X	X	.

Managing Your Preferences

This section details how you may exercise your preferences regarding any Personal Information Wi Spa may collect about you or your communication preferences.

Request Type	Guidance
Update Accounts and Online Profiles	If you are a registered user of wispausa.com, you can update your information in My Account.
Unsubscribe from Direct Mail Communications	Call Customer Service at (213) 487-2700
Unsubscribe from Specific Email Communications	To update your preferences or categories of promotional or marketing emails you receive from Wi Spa at a specific email address, you may: Use the unsubscribe link in the footer of any email sent by wispausa. com. It may take up to 30 business days to process your request.

California Residents

California Shine the Light Law: If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes during the preceding calendar year. To make a request please submit an inquiry to the following address: Wi Spa Customer Service, 2700 Wilshire Blvd., Los Angeles, CA 90057. In your request, please specify that you want a “Your Wi Spa’s California Shine the Light Notice.” Please allow 30 days for a response.

If you are a minor under 18 and have a profile on wispausa.com, you may ask us to remove reviews or other content that you posted on the site by writing to info@wispausa.com. We will begin to process your request within 30 days. Please note that processing your request does not ensure the complete or comprehensive removal of the content that you posted.

California Privacy Rights Act: You have the right to request information about how Wi Spa collects, processes, and shares your Personal Information. There may be situations where Wi Spa cannot grant a request, for example, to complete a transaction to you or comply with the law. These options do not apply to publicly available information from government records nor to deidentified or aggregated information.

Customer Right	Detailed Description
Right to Deletion	You may request deletion of applicable Personal Information Wi Spa has collected about you. Upon verification of your request, Wi Spa will notify third parties to whom Wi Spa has shared your Personal Information to delete your information as well.
Right to Correct Inaccurate Personal Information	You have the right to correct inaccurate Personal Information collected by Wi Spa. If you are a registered user of wispausa.com, you can correct your information in the My Profile section of My Account. Alternatively, use one of the contact methods outlined above
Right to Know / Access What Personal Information is Collected	You have the right to know Personal Information Wi Spa has collected about you during the previous 12 months, including: Categories of Personal Information we collected about you Categories of sources from which we collected the Personal Information Business or commercial purpose(s) for collecting your Personal Information Specific pieces of Personal Information we collected
Right to Know What Personal Information is Sold or Shared	You have the right to know Personal Information Wi Spa has sold or shared about you during the previous 12 months, including: Business or commercial purpose(s) for selling your Personal Information Categories of third parties with whom we share the Personal Information Categories of Personal Information we have sold and categories of third parties to whom the information was sold Categories of Personal Information we disclosed about you for a business purpose
Right to Opt Out of Sale or Sharing	You have the right to opt out of the sale or sharing of any Personal Information Wi Spa has collected about you.
Right to Opt Out of Automated Decision Making	You have the right to opt out of automated decision making, including profiling, against any information Wi Spa has collected about you.
Right to Limit Use and Disclosure of Sensitive Personal Information	You have the right to opt out of the disclosure of Sensitive Personal Information to a third party if Wi Spa uses that information for any purpose other than the designated purpose defined in legislation.
Right to No Retaliation	Wi Spa will never discriminate nor retaliate against you if you choose to exercise any of these privacy rights.

To exercise your customer rights, you may submit your request through the following methods:

Email to info@wispausa.com
By phone at (213) 487-2700

Authorized Agents. If you would like to enter a request on behalf of a California resident, please submit the request via email. Upon submission, you will be required to provide documentation showing proof of written permission from the customer authorizing you to submit a request on their behalf. We reserve the right to require customers to confirm their requests and/or identity.

Do Not Sell or Share My Personal Information Requests

You may submit your request through the following methods:

Email to info@wispausa.com
By phone at (213) 487-2700

Upon submission of the request, you will be asked to provide your first name, last name, and email address. You will receive a verification email that will ask you to provide some additional information, such as an address, state, zip code, and phone number. We will use the information provided to match the identifying information we have to verify your identity before processing the request.

We will not discriminate against you for exercising your rights under CCPA (California Consumer Privacy Act).

Children’s Privacy

Wispausa.com is not intended for children. Wi Spa does not knowingly sell or share the personal information of minors under the age of 16.

If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact Us. If we become aware that we have collected personal data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Additional Disclosures

Information About Children Under 13:

The Children’s Online Privacy Protection Act imposes requirements on websites that collect Personal Information about children under 13 years old (for example – name, address, email address etc.). Our current policy is not to collect any Personal Information on any person under 13 years old online. For this reason, our sweepstakes and other promotions conducted online are restricted to entrants who are at least 13 years old.
If this policy changes, we will revise this portion of our Notice of Privacy Practices and will comply with the requirements of the Children’s Online Privacy Protection Act, which includes providing notice and choice to each child’s parent or guardian before collecting any Personal Information.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided above, and include the email address associated with your account.

Be aware that Your request does not guarantee the complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Ownership of Customer Data

If Wi Spa or any of its subsidiaries is sold to or otherwise acquired by a third party, all Wi Spa’s data assets will become the property of the acquiring party. Such a party will be subject to any consent(s), opt-outs, or other customer conditions on data. A change in data ownership may or may not include a notice on the primary online sites of Wi Spa, LLC or the affected subsidiary sites.