Wink Silk Privacy Policy

1. Introduction & Scope

Effective Date: September 16, 2026

We started Wink Silk believing customers deserve a plain, honest accounting of what happens to their information, not vague reassurance. Wink Silk ("Wink Silk," "we," "us," or "our") respects your privacy and is committed to protecting it. This Privacy Policy describes the categories of personal information we collect, how we use and share it, and the rights you have regarding it, when you:

• Visit or interact with winksilk.com (the "Site")
• Create an account or join Wink Privé
• Make a purchase
• Sign up for email or SMS communications
• Interact with our advertising on third-party platforms such as Meta (Facebook/Instagram), Pinterest, TikTok, or Google

By using the Site, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the Site.

2. Information We Collect

We collect the following categories of personal information:

Category	Examples	Source
Identifiers	Name, email, mailing address, phone number, account username	Provided directly by you
Commercial information	Order history, products viewed, cart contents, payment method type (not full card numbers)	Your interactions with the Site and Shopify checkout
Internet/network activity	Pages visited, links clicked, browsing behavior, referring URLs, device identifiers	Automatically via cookies and pixels
Geolocation data	Approximate location derived from IP address	Automatically
Inferences	Preferences and interests inferred from browsing and purchase behavior, used for personalization and ad targeting	Derived from the above
Audio/visual (if applicable)	Photos or videos you voluntarily submit (e.g., reviews, UGC)	Provided directly by you

We do not knowingly collect Social Security numbers, government ID numbers, or financial account numbers directly. Payment processing is handled by Shopify's PCI-compliant payment infrastructure, and we do not store full payment card numbers.

3. How We Use Your Information

We use the personal information we collect to:

• Process and fulfill orders, including payment processing, shipping, and customer service
• Send transactional communications (order confirmations, shipping updates)
• Send marketing communications via email and SMS, including the Wink Privé program, where you have opted in
• Personalize your experience on the Site, including product recommendations
• Measure and improve the performance of our advertising across Meta, Pinterest, TikTok, and Google
• Analyze Site traffic and usage patterns to improve our products and user experience
• Detect, investigate, and prevent fraudulent transactions and other illegal activity
• Comply with legal obligations and enforce our Terms of Service

4. How We Share Your Information

We share personal information with the following categories of third parties to operate our business and deliver the services described in this Policy. Under the California Consumer Privacy Act (CCPA), sharing personal information with advertising partners for cross-context behavioral advertising may be considered a "sale" or "share" of personal information, even though no money changes hands. The table below identifies each recipient, the information shared, and the purpose.

Recipient	Information Shared	Purpose	Considered a "Sale/Share" under CCPA?
Shopify Inc.	Order data, payment information, customer account details	E-commerce platform hosting, checkout, payment processing, order fulfillment	No (service provider)
Klaviyo	Email address, phone number, purchase history, on-site browsing behavior	Email and SMS marketing, personalization, abandoned cart messaging	May be considered a share
Meta (Facebook/Instagram)	Hashed email/phone (Advanced Matching), device identifiers, page views, purchase events	Ad targeting, ad performance measurement, lookalike audience creation	Yes
Pinterest	Hashed email/phone, device identifiers, page views, purchase events	Ad targeting, ad performance measurement	Yes
TikTok	Hashed email/phone (Advanced Matching), device identifiers, page views, purchase and checkout events (via Pixel and Events API)	Ad targeting, ad performance measurement, audience creation	Yes
Google (Google Ads, Google Analytics/GA4)	Device identifiers, page views, purchase events, approximate location	Ad targeting, ad performance measurement, Site analytics	Yes

We do not sell personal information for direct monetary payment. However, because our use of advertising pixels, cookies, and the TikTok Events API/Advanced Matching may meet the CCPA's broader definition of "sale" or "share," we disclose these practices here and provide the opt-out mechanism described in Section 6 below.

We may also disclose personal information: (a) to comply with a legal obligation, court order, or government request; (b) to protect our rights, property, or safety, or that of our customers; or (c) in connection with a merger, acquisition, or sale of company assets.

5. Cookies & Tracking Technologies

We and our third-party partners use cookies, pixels, web beacons, and similar tracking technologies to:

• Remember your preferences and cart contents
• Understand how visitors use our Site
• Measure the effectiveness of our marketing campaigns, including UTM-tagged links from our email, SMS, and paid social campaigns
• Serve and measure targeted advertising on Meta, Pinterest, TikTok, and Google

Specific technologies in use include the Meta Pixel, Pinterest Tag, TikTok Pixel and Events API, Google Ads tag, Google Analytics (GA4), and the Klaviyo tracking snippet.

You can control cookies through your browser settings, which allow you to refuse or delete cookies. Note that blocking cookies may affect Site functionality, such as the ability to complete a purchase. We also honor the Global Privacy Control (GPC) signal as described in Section 7 below.

6. Your Privacy Rights

If you are a California resident, the CCPA (as amended by the CPRA) gives you the following rights:

• Right to Know: request disclosure of the categories and specific pieces of personal information we have collected about you, and the categories of sources, purposes, and third parties involved
• Right to Delete: request deletion of personal information we have collected from you, subject to certain exceptions
• Right to Correct: request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: direct us not to sell or share your personal information, as described in Section 7 below
• Right to Limit Use of Sensitive Personal Information: where applicable
• Right to Non-Discrimination: we will not deny goods or services, charge different prices, or provide a different level of service because you exercised any of these rights

Residents of other states with comprehensive privacy laws (including but not limited to Virginia, Colorado, Connecticut, Utah, and others as they take effect) have similar rights, which we honor in accordance with applicable law.

To exercise any of these rights, contact us using the information in Section 10. We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.

7. Do Not Sell or Share My Personal Information

You have the right to opt out of the "sale" or "sharing" of your personal information, as those terms are defined under the CCPA, at any time.

To opt out:

1. Click "Do Not Sell or Share My Personal Information" in the footer of our Site, or
2. Enable the Global Privacy Control (GPC) signal in your browser, which we will automatically detect and honor as a valid opt-out request, or
3. Email us at [INSERT PRIVACY EMAIL] with the subject line "Do Not Sell or Share My Information"

Opting out will disable cross-context behavioral advertising cookies and pixels (Meta, Pinterest, TikTok, Google Ads) on future visits, but will not affect information already shared prior to your request, nor will it disable analytics or functionality strictly necessary to operate the Site.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including satisfying legal, accounting, or reporting requirements. Order and transaction records are generally retained for the period required by tax and commercial law. Marketing contact information is retained until you unsubscribe or request deletion.

9. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. This includes relying on Shopify's PCI-DSS compliant infrastructure for payment processing, and endpoint security software from CyberCrucible installed on the internal systems we use to operate Wink Silk. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

10. Children's Privacy

Our Site is not directed to children under 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16 without parental consent, we will delete that information as quickly as possible.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will post the updated policy on this page with a revised effective date. Material changes affecting how we handle previously collected information will be communicated via email or a prominent Site notice.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

Wink Silk Email: privacy@winksilk.com 

Mailing Address: 620 Newport Center Drive, Suite 1100. Newport Beach, CA. 92660.