privacy policy


Welcome to the Soothe website, operated by TM38 LTD, (“Soothe” “we,” “us” or “our”) and
located at (“Site”). We respect the privacy rights of our users and are
committed to protecting the information collected. This Privacy Policy addresses Soothe’s
practices regarding information collected from visitors of the Site and only addresses
information collected directly through or from the Site – it does not address or govern any
information-gathering, use, or dissemination practices related to information collected from a
visitor (sometimes referred to as ;) other than directly through or from the Site, such as from telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media.

This Privacy Policy is incorporated into Soothe’s Terms and Conditions for the Site, which must
be reviewed and accepted by you.
The Site is not intended for children under the age of 18. It does not knowingly collect personal
information online from visitors in this age group.
If you have any questions concerning this Privacy Policy, please contact us at the contact
information listed below.

1. Collection of Personal Information from Site Visitors. Except as specifically set forth
herein, Soothe may collect: (a) the email addresses of users that communicate with Soothe via
email; and (b) information knowingly provided by the user through the Site, though, for example, direct correspondence by email, form submission, and/or product orders. Soothe may also use Internet cookies and other identifiers or methods of web analysis (such as Google Analytics) to gather, store, and track certain information related to your visit to and activity on the Site. If you would like a list of the cookies that we use, please contact us. If you are uncomfortable with the idea of your information being used in this way, most computer systems and web browsers offer privacy settings and options, such as disabling cookies or opting for “Do Not Track” features. Soothe does not override these settings or options and encourages you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products or benefits on the Site, you may be required to provide Soothe with certain information, including some types of personally identifying information such as your email, your address, and your phone number. If you do not wish to provide such information through the Site or if you opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products or benefits of the Site.

2. Use of Personal Information Collected. By providing personally identifiable information to
us, we are better able to match your interests. Soothe may use your personally identifiable
information to process and fulfill orders, send emails to confirm your order status and shipment, to communicate with you and to send you information by email, postal mail, or other means about our products, services, contests, and promotions. In general, we use personal information collected on the Site for the specific purpose for which it was volunteered; to help develop better products, and/or market, sell, or provide products and services; for market research purposes or to provide you with marketing information that Soothe believes would be of particular interest; and to comply with any legal or regulatory requirements, process or provisions. In order to better serve you, we may combine information you provide to us on the Site with information from third parties, including demographic or public information.

3. Disclosure of Personal Information to Third Parties. We may share information
collected through the Site with our subsidiaries, affiliated companies, and like-minded business
partners for the purpose of providing you with the products and services you seek from the Site. We may also share your mailing address and shopping history with retailers and other service providers. From time to time, Soothe may disclose the data collected through the Site, including personally identifiable information, to other persons or entities whom we believe trustworthy. In such cases we might rent, exchange, share and/or cross-reference information, including contact information about you that will enable such persons or entities to contact you regarding products and services that may be of interest to you. Additionally, in order to provide you with a better customer experience, we may share information with service providers, subcontractors, and business partners who have been retained to perform functions on our behalf or to provide services to us.

These services include:
a) Order fulfillment, warehousing, and delivery;
b) Advertising, marketing, surveys, and promotions, including partnerships and teaming
efforts with other companies whose products or services we think you might enjoy;
c) Information technology and office services, including software and website development,
website hosting, management and evaluation, and data processing, exchange, and
d) Payment processing services, fraud protection, and credit risk reduction; and
e) Legal, accounting, audit and other professional service providers.

While Soothe may undertake efforts to see that any third party to which Soothe discloses
personal information is under an obligation to use that personal information solely for the
purposes for which the information was disclosed, such third parties are independent third
parties over which Soothe exercises no control. Soothe is not responsible for, and will not be
liable for, the conduct, actions, omissions, or information handling or dissemination practices of
third parties. We note that certain third-party service providers, such as payment gateways and
other payment transaction processors, have their own privacy policies in respect to the
information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the
manner in which your personal information will be handled by these providers. In particular,
remember that certain providers may be located in or have facilities that are located a different
jurisdiction than either you or us. If you elect to proceed with a transaction that involves the
services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave our store’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service. Soothe may also disclose the data collected through the Site, including personally identifiable information, to another party with which Soothe enters or reasonably may enter into a corporate transaction, such as a merger, consolidation, acquisition, or asset purchase. In the event that Soothe or its assets is acquired by another company, or due to any merger, reorganization or liquidation, customer information may be one of the transferred assets. Your personal information will remain subject to any pre-existing privacy policy unless you consent otherwise. We reserve the right to disclose information about you to a third party pursuant to a subpoena, court order, or other form of legal process, or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process.

4. Interest Based Advertising
As described above, we work with a variety of third party business partners, including our
Network, advertisers, advertising networks, and advertising and analytics companies that use
various technologies to collect data about your use of the Site, which may include location data. Soothe and our third party business partners may use the aforementioned technologies to:

i. track how you use the Site, how you arrived at the Site, and what you do after
you leave the Site;
ii. record and link your devices, including your personal computer and mobile
device (this is called cross-device linking); and
iii. provide you with advertisements relevant to your interests, taking into account
your use of the Site and the other websites and online services that you use. Note that
these advertisements may be delivered to you on the Site, on third party websites and
applications, and on a computer or device other than the device from which the
information was collected.

This is called “Interest-Based Advertising” or “Online Behavioral Advertising.” While we work
with our third party business partners to improve your experiences with the Site, we do not
control their business practices. This Privacy Policy describes various methods of preventing passive collection and use of your information by our third party business partners. To learn more about Interest Based Advertising and your options with respect to these practices, please visit,,, and

If you wish to opt-out of participating in Interest Based Advertising, you can use some or all of
the following methods:
1. Visit (for web-based advertising), and (for mobile advertising);

2. For mobile advertising, use your phone operating system’s opt-out setting. For
instructions on how to “Limit Ad Tracking” on iOS, please visit For instructions on how to opt out of
interest-based ads on Android, please visit;

3. Enable the “Do Not Track” feature on your web browser. For instructions on how
to do so, please visit; and

4. In accordance with industry self-regulatory principles, you should see an active link in or around Soothe advertisements that are delivered on other sites using information collected on our Site, and in or around third-party advertisements that are delivered on our Site using Interest Based Advertising programs. Clicking on this link will provide information about the companies and data practices that were used to deliver the ad and will also describe how you may opt-out of these advertising programs. If you use more than one device, you should renew your opt-out choices on each such device.

5. Links to Other Sites. The Site may also contain links to third party websites, for the
convenience of users in locating information, products, or services that may be of interest. If you access a third party website from a link on this Site, any information you disclose on that
website is not subject to this Privacy Policy. It is possible that these links themselves may be
used by third parties or others to collect personal or other information about you. Soothe is not
responsible for the privacy practices of third parties or for the content of their websites. Soothe
does not control third parties’ use of cookies, collection of information, or how they manage
such information. It is your sole obligation to review and understand the privacy practices and
policies of all third parties, including those who operate websites accessible through the Site.

6. Security Measures and Communications. The confidentiality of any communication or
material transmitted to or from Soothe via the Site or via email cannot be, and is not,
guaranteed. You acknowledge that the technical processing and transmission of the Site’s
content may be transferred unencrypted and involve: (a) transmissions over various networks;
and (b) changes to conform and adapt to technical requirements of connecting networks or
devices. Accordingly, Soothe is not responsible for the security of information transmitted via the Internet.

7. Access to and Ability to Correct Personal Information; Opt-Out Right. Upon your
request, Soothe will provide you with a summary of any personal information retained by Soothe that has been voluntarily provided by you to Soothe through email, contact forms, or other online avenues. You may modify, correct, change or update your personal information by
contacting us at or mailing us at: Soothe 2230 Frankford avenue, Floor1. Philadelphia, PA. 19125. Except as necessary to obtain the services or information requested, you may opt out of having your personal information, which has been voluntarily provided by you to Soothe through email, contact forms, or other online avenues, prospectively retained by Soothe or used by Soothe for secondary purposes, by contacting Ivory Ella. This provision does not apply to collection of the type of web browser used to visit the Site or to information provided or collected that does not meet the description hereunder.

8. California Residents. California Civil Code Section 1798.83 (also known as the “Shine The
Light” law) permits users who are California residents to request and obtain (once a year; free of charge) information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us.

9. Right to Change Privacy Policy. Soothe reserves the right at any time to modify, alter or
update this Privacy Policy. Your use of the Site following any changes means that you agree to
follow and be bound by the Privacy Policy as changed. Any change to this Privacy Policy shall
be effective as to any visitor who has visited the Site before the change was made. It is the
obligation of users visiting the Site before the change to learn of changes to the Privacy Policy
since their last visit.

10. QUESTIONS AND CONTACT INFORMATION. If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at or mailing us at:

[Re: Privacy Compliance Officer]
2230 Frankford Avenue, Philadelphia
Pennsylvania, 19125