Ocean Ecom Inc. (together with our affiliated companies and subsidiaries – "Ocean", "we", "us" or "our") respects your privacy and we are committed to making our data handling activities fair and transparent.
This Privacy Policy describes how we collect, store, use and disclose information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual ("personal data" or "personal information") who engages or otherwise interacts with us ("you" or "your"). Specifically, this Privacy Policy applies to individuals who (i) use the Ocean application ("Ocean App") for a subscription shopping membership ("User(s)"), (ii) interact with our website (available at: www.shopocean.co), other websites, mobile apps, widgets, APIs, emails, and other online products and services (collectively, including any new features and applications, the "Services"), or participate in our events, webinars and other business and marketing activities that we organize or participate in ("Prospect(s)"), or (iii) act as or work for a service provider or supplier to Ocean, or who are employed by or work for our Brands (defined in below) ("Business Contact(s)").
This Privacy Policy is subject to the Ocean Terms of Use "Terms of Use" (available at: shopocean.co/terms-of-use). Capitalized terms not defined herein shall have the meaning assigned to them by the Terms of Use. To the extent of any conflict between this Privacy Policy and the Terms of Use, this Privacy Policy shall govern to the extent that the conflict concerns how we collect, store, use and disclose personal data or personal information in conjunction with the Ocean App, otherwise the Terms of Use shall control.
This Privacy Policy describes: how & what personal data we collect, how we use it, where and for how long we keep it, and to whom we disclose it. You will also find information about our use of cookies and other tracking technologies, types of communications you might receive from us, our security practices, your rights, our role & responsibilities under applicable laws, and other relevant information.
If you are a User, Prospect or Business Contact, please read this Privacy Policy carefully and make sure that you fully understand and agree to our practices. You are not legally required to provide us with any personal information and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us, please avoid any interaction with us or any use of the Ocean App, or you may submit a request to exercise your rights, as further explained in below. Please keep in mind that limiting our processing may also result in us not being able to provide you the ability to use the Services, or the best user experience when using the Services.
We may obtain the following categories of personal data from the following sources:
User Data: When you use the Ocean App, you may provide us with your personal data. This includes contact details such as your name, email and phone number, as well as optional details you may choose to provide (such as age, gender, birthday and shopping interests). We may collect additional information from you when you use the Ocean App, request information, or contact us for any reason, including via email or through chat.
The Services are intended to be used in connection with third-party services, including e-commerce services and online stores selected to participate in the Ocean App (“Brands”). We may collect your personal data from such third-party services. By installing the Ocean App or creating an Account, you authorize us to access all your purchase and activity history from Brands you interacted with in the past, as well as any future activity with Brands. This information includes purchases (items, their price, etc.), shipping details (shipping address, phone number, etc.), engagement (how often you sign up to loyalty programs, or how often you leave a review), interests (what kind of products you usually buy), and any expressed, presumed or identified needs, preferences, attributes and insights relevant to our engagement. Please note that when you directly engage with such Brands, any aspect of that engagement that is not directly related to the Ocean App is beyond the scope of the and this Privacy Policy, and the terms and privacy policies of such Brands will govern your use of their services. For information about how a Brand collects and uses your information when you visit and make a purchase from their site, review the Brand’s own terms and privacy policy.
Usage Data: When you interact with our Services, we may automatically collect certain technical data about your device (such as your operating system, IP address, device identifier browsing history, etc.). We collect or generate such data either independently or with the help of our Service Providers (as detailed in below), including through the use of "cookies" and other tracking technologies (as further detailed in below).
Prospect Data: We may collect personal information contained in any forms and inquiries that you submit to us, including registrations to mailing lists or events that we host, organize, sponsor or take part in, when you complete our surveys, provide feedback or testimonials, or interact with us in any other way, including through social media channels and instant messaging apps.
Business contact data: If you engage with us in your professional capacity, we may collect your business profile information, including your name, email address, phone number, position, workplace, contractual and financial documents, and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.
For the purposes of the California Consumer Privacy Act (“CCPA”), specifically in the last 12 months, we have collected the following categories of personal information: Identifiers; Customer Records Information; Commercial Information; Internet or other Electronic Network Activity Information; Geolocation Information; Professional or Employment -Related Information; protected classification characteristics and Inferences drawn from personal information. We do not use or disclose sensitive personal information as defined in the CCPA.
We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services (“Legitimate Interests”).
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate lawful basis for the processing of personal data (in general, or specifically with respect to the types of personal data you expect or elect to submit or have processed via the Services) (“Consent”), your acceptance of our Terms of Use and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this policy. If you wish to revoke such consent, please contact us at privacy@shopocean.co.
Specifically, we collect and use personal data in reliance on the lawful bases noted below (where applicable) and for the following business purposes:
To facilitate, operate, enhance, and provide usage of our Services [performance of a contract; legitimate interest];
To authenticate the identity of our Users, and to allow them to access and use the Ocean App [performance of a contract];
To provide you with assistance and support [performance of a contract; legitimate interest];
To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you (as further described in below) [performance of a contract; legitimate interest; consent];
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity [performance of a contract; legitimate interest; legal obligation];
To gain a better understanding of how you use and interact with the Services, and how we can improve your and others’ user experience and continue improving our products, offerings, and the overall performance of the Services [performance of a contract; consent];
To facilitate and optimize our marketing campaigns, ad management, and sales operations, and to manage and deliver advertisements for the Services more effectively, including on other websites and applications. This includes contextual, behavioral and interests-based advertising based on your and other users’ activities, preferences and other data available to us or to our Service Providers (defined below), and business partners [legitimate interest; consent];
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we may use to provide and improve the Services or for any other business purpose [legitimate interest];
To enforce our agreements, resolve disputes, and protect our rights and interests, our employees, Brands, Service Providers, Users, Prospects, or any member of the general public [legitimate interest];
To comply with court orders and warrants, prevent misuse of the Services, and take any action in any related legal dispute and proceeding [legal obligations; legitimate interest]; and
To comply with applicable laws and regulations [legal obligations; legitimate interest].
We may use your information in additional manners to fulfill any other business or commercial purposes subject to your consent and/or notice. We may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
Data Location. We and our authorized Service Providers maintain, store and process Personal Data in the United States, Israel, European Union, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law. While privacy laws may vary between jurisdictions, we and our Service Providers are committed to protecting personal data in accordance with this Privacy Policy, customary industry standards, and appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction.
Data Retention. We will retain your personal data for as long as it is reasonably necessary in order to establish, maintain and expand our relationship and provide you with the Services; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and applicable laws.
Please note that unless required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us at privacy@shopocean.co.
Removing Ocean; Data Not Deleted. Removing the Ocean App from your personal device does not delete your personal data held with us, please follow the instructions in in order to delete your personal data held with us.
Payment Information. We do not retain your payment information, as it is transferred directly to our relevant payment Service Provider(s). We only retain a token of such payment information (which cannot be used to reidentify that information) and the chosen payment method, as it is required for your continuous payment.
Service Providers. We engage selected third-party companies and individuals to perform services complementary to our own such as hosting and server co-location services, communications, and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, marketing and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and enrichment services, social and advertising networks, content providers, e-mail and communication distribution, voice-mails, call recording systems, support and customer relation management systems (including support ticketing systems, chatbots and related messaging functions), and our legal, compliance and financial advisors (collectively, “Service Providers”). These Service Providers may utilize artificial intelligence, generative artificial intelligence or similar technologies and may have access to your personal data - depending on each of their specific roles and purposes in facilitating and enhancing the Services, and may only use it for such limited purposes as determined in our agreements with them.
Brands. When you interact with the Ocean App, we may disclose relevant information about you, including your personal data and Usage Profile, with Brands in our network.
Protecting Rights and Safety. We may disclose your personal data to others if we believe in good faith that this will help protect our rights, property or personal safety, any of our Users or any members of the general public.
Third-Party Websites and Services. The Services include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services directly, are beyond the scope of the Terms of Use and this Privacy Policy and will therefore be governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services.
Subsidiaries and Affiliated Companies. We disclose personal data internally within our group companies for the purposes described in this Privacy Policy. In addition, should we or any of our affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of its assets or shares, your personal data may be disclosed (to the extent necessary and customary) to the parties involved in such an event. If we believe that such event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or a prominent notice via the Ocean App.
Legal Compliance. In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Additional Disclosure. We may disclose your personal data in additional manners, pursuant to your request or explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, disclose or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
For the purposes of the CCPA, specifically in the last 12 months, we have disclosed the following categories of personal information to the parties listed above: Identifiers; Customer Records Information; Commercial Information; Internet or other Electronic Network Activity Information; Geolocation Information; Professional or Employment -Related Information; protected classification characteristics and Inferences drawn from personal information. We do not use or disclose sensitive personal information as defined in the CCPA.
Cookies. We utilize third-party software development kits (SDKs), cookies, pixels and similar technologies (collectively - “Cookies”) in order for us to provide the Services, to ensure its proper functions, to analyze our performance and marketing activities, and to personalize your experience. Cookies are packets of information sent to and from your web browser each time it accesses the server that sent the Cookie and may store personal information, such as IP address and Unique Device Identifiers, previously indicated by you. Some Cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types to facilitate the use of the Services (for example: we use Cookies to remember your log-in details and make it easier for you to access the Services). We may also use HTML5 local storage or other techniques for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your Cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling Cookies may complicate or even prevent you from using the Services.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out Cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking. If you have any comments or questions regarding our use of Cookies, you can contact us at privacy@shopocean.co.
We engage in service and promotional communications, through the means available to us – including e-mail, phone, SMS, chat (including the chatbot feature available on the Ocean App), and notifications.
Service Communications and Notifications. We may contact you with important information regarding the Services. For example, we may send you notifications of order summaries and shipping updates, inform you of changes or updates to the Services, billing issues, etc.
Promotional Communications and Notifications. We may send you messages and notifications about new features, offerings, special opportunities, and any other information we think you will find valuable. Furthermore, we may send you promotions and marketing materials about our other services and products.
You can control your communications and notifications preferences by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions contained in the promotional communications you receive, by changing the notification settings within the Ocean App or by emailing us at privacy@shopocean.co. Please note that you will not be able to opt out of receiving certain service communications that are integral to your use.
We and our Service Providers implement systems, applications and procedures to secure and protect your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, however, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.
If you wish to exercise your rights under applicable laws (including the CCPA), please contact us by e-mail at privacy@shopocean.co. Kindly be advised that exercising such rights might adversely affect your use of the Ocean App.
Such rights may include (each to the extent available to you under the laws that apply to you): (i) the right to know or request access to specific pieces of personal data collected; (ii) categories of data collected and sources from whom it was collected; (iii) the purposes of collecting it and categories of third parties to whom we have disclosed it; (iv) the right to request rectification or erasure of your personal data held with us; (v) the right to restrict the processing of such data and to object to its processing; (vi) the right to opt out of the sale or sharing of your data for targeted advertising; (vii) to port such data; (viii) or the right to equal services and prices (e.g., freedom from discrimination).
You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. When you (or an authorized agent on your behalf) ask us to exercise any of your rights under this Privacy Policy or applicable law, we may ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure of personal data relating to other individuals, and ask you to provide further information to better understand the nature and scope of data that you wish to access or have deleted etc. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, or proof of request fulfillment), in accordance with above. We may redact from the data which we will make available to you, any personal data related to others.
Certain data protection laws and regulations typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). To the extent that such laws and regulations apply to the Services, we are the “data controller” (or “business”) of our Users’, Prospects’ and Business Contacts’ data, and assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.
Updates and amendments. We may update and amend this Privacy Policy from time to time by posting an amended version on the Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.
External links. While the Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to the Services.
Use by Minors. Our Services are not designed to be accessed and/or used by underage children. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person who is underage according to the law applicable to them is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us at privacy@co. For the purpose of CCPA, we don’t have actual knowledge that we “sell” or “share” the personal information of individuals under 16 years of age.
Questions, Concerns or Complaints. If you have any comments or questions regarding this Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by us in connection with the Ocean App, you can contact us at privacy@shopocean.co.
Last updated: January 2025