The COOL HOUR (“us,” “we,” “our,” or “Company”) have created the following Privacy Policy for when you visit our Website: www.thecoolhour.com (the “Website”). This Privacy Policy describes, among other things, the types of information collected about you when you visit the Website, how your information may be used and when it may be disclosed, how you can control the use of and disclosure of your information, how your information is protected, and how you may access and update your information.

This Privacy Policy is governed by our Terms and Conditions of Use, which is also available on our Website. By using our Website and the services therein, you consent to the terms of our current Privacy Policy and Terms and Conditions of Use. We reserve the right to change the Privacy Policy at any time. For more information, please refer to the paragraph entitled “Changes to this Privacy Policy” detailed below. If you believe we have not adhered to this Privacy Policy or if you have any other questions regarding this Privacy Policy, please contact us at the address and number listed below in the paragraph entitled “Questions.”

I. SCOPE OF THE PRIVACY POLICY
This Privacy Policy applies to all Information that you provide to us and that we maintain electronically, whether you provide the information through our Website, or through other means. This Privacy Policy does not apply to any Information that you may provide to third parties; for example, other websites linked to our Website. If you access our Website from a third party website, you may be required to also read and accept the terms and conditions and privacy policy of that website. We are not responsible for the privacy practices of those websites, and you should contact such third parties directly to determine their respective privacy policies.

II. INFORMATION WE COLLECT
To operate our Website and provide you with access to certain products and services, we may collect the following types of information which are described in more detail below: (A) information you provide to us, (B) information we automatically collect, and (C) information We receive from third parties. All of the information listed in (A)-(C) above, are detailed below, and hereinafter referred to as “Information.”
This Privacy Policy places no restriction on the use of Information we automatically collect from your visit, or de-identified or aggregated information.

A. Information You Provide To Us:

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information or other details to help you with your experience. This information consists of the following:

Personally Identifiable Information. We collect certain information that identifies you as an individual (collectively, “Personally Identifiable Information”). The Personally Identifiable Information we collect may include the following:

• Your name
• Your phone number
• Your email address

Anonymous Information. Our website also collects, processes, and/or uses information that does not identify You or Your devices, including Personally Identifiable Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information”). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information.

Treatment of Combined Information. If we combine Non-Personally Identifiable Information or Anonymous Information with Personally Identifiable Information, we treat the resulting combination as Personally Identifiable Information.

Additionally, in order to use our Website services, you may interact with third party service providers with whom we contract (“Third Party Service Providers”):

i. rewardStyle, Inc.: rewardStyle, Inc. redirects visitors to our Website to a third party website through the rewardStyle feature. This is a different third party website, and provides links to other sits as well, and we are not responsible for their website or services. Thus, you must review and agree to rewardStyle’s Privacy Policy (https://www.rewardstyle.com/about/privacy-policy/). rewardStyle is how we deliver services to you and so you must agree to its Privacy Policy to use our Website.

ii. Skimlinks: Skimlinks redirects visitors to our Website to a third party website. This is a different third party website and we are not responsible for their website or services. Thus, you must review and agree to Skimlink’s Privacy Policy (https://skimlinks.com/privacy-policies/) and Terms and Conditions (https://skimlinks.com/terms-of-service/. Skimlinks is how we deliver services to you and so you must agree to its Privacy Policy and Terms and Conditions to use our Website.

iii. Rakuten/LinkShare: Rakuten/LinkShare redirects visitors to our Website to a third party website. This is a different third party website and we are not responsible for their website or services. Thus, you must review and agree to Rakuten/LinkShare’s Privacy Policy (https://rakutenadvertising.com/legal-notices/website-privacy-policy/) and Legal Notices (https://rakutenadvertising.com/legal-notices/. Rakuten/LinkShare is how we deliver services to you and so you must agree to its Privacy Policy and Terms and Conditions to use our Website.

iv. Mailchimp: Mailchimp is a third party website we use for our newsletter (see more about our Newsletter below). In order to receive our newsletter, you must register your email address with our third party provider MailChimp. The registration for our newsletter is handled through a so-called double opt-in procedure, which means you will receive an e-mail after your registration, in which you will be asked to confirm your registration once again. Mailchimp is a different third party website and we are not responsible for their website or services. Thus, you must review and agree to Mailchimp’s Privacy Policy (https://mailchimp.com/legal/privacy/) and Terms and Conditions (https://mailchimp.com/legal/terms/) in signing up for our newsletter through Mailchimp. Our emails offer opt-out procedures and you may opt out at any time by using the Opt-Out or Unsubscribe option at the bottom of our email communications, or by contacting us at [email protected]

v. Auth0: Auth0 is a third party website we use for managing user accounts. To register for an account, you must review and agree to the Autho0 privacy policy https://auth0.com/privacy and terms of use https://auth0.com/web-terms

B. Information We Automatically Collect:

We also collect information about you from your visit to our Website including:

• IP address;
• Your geographic location;
• Date and time of your visit;
• Domain server;
• Type of computer, web browsers, search engine used, operating system, or platform you use or web browser;
• Data identifying the web pages you visited prior to and after visiting our Website; and/or
• Your movement and activity within the Website, which is aggregated with other information.

We collect data through cookies, other tracking technologies, and by using third party analytics. We may permit advertisers or other third parties to collect information from our Website. For example, a third party may place a cookie or similar tracking technology and may send its own cookies to your cookie file. We may also utilize third parties to analyze data collected from the Website. This Privacy Policy covers the use of cookies and other technologies by this Website only.

We use a few different technologies to collect this information:

Cookies. The Website may place small files, called “cookies” onto your computer. Cookies are data files that websites write onto computer hard drives for record keeping purposes when you visit them. The cookie file then identifies you as a unique user. Cookies make your use of these Website more pleasing and efficient by “personalizing” your Website experience and gathering Website statistical data, such as which parts of the Website you have previously visited, what material you downloaded, your Internet provider’s domain name and country, and the addresses of websites you visited immediately before and after our Website. They enable us to tailor the Information you receive and to assist our Partners or other third party organizations with whom we have strategic alliances by identifying you as our customer or Website user. Most web browsers automatically accept cookies, unless you have configured yours not to accept them. You can program your browser not to accept cookies, but if you do, you may not be able to use certain portions of the Website and the Website will not be able to customize certain features according to your preferences.

• Information Provided by Third Parties.Third party companies with whom we collaborate may drop cookies on your device and/or web browser or utilize other tracking technologies. For example, once you click on a link on our Website, you will be redirected by rewardStyle to an Affiliate merchant’s ecommerce site, at which point rewardStyle or the Affiliate merchant will drop a cookie on your browser. Please see the following third party privacy policies for additional information about the technologies they use and how to opt out:
rewardStyle: https://www.rewardstyle.com/about/privacy-policy/
• Skimlinks: https://skimlinks.com/privacy-policies/
• Rakuten/Linkshare: https://rakutenadvertising.com/legal-notices/website-privacy-policy/
• Auth0: https://auth0.com/web-terms

Web Beacons. Small graphic images or web programming code called web beacons (also known as “pixel tags” or “clear GIFs”) may be included on the pages of the Website and in email messages we send you. Web beacons or other similar technologies may be used for several purposes, such as to count visitors to the Website, monitor how you navigate the Website or to count how many particular links posted on the Website were actually viewed.

Mobile Device Identifiers. Certain mobile service providers uniquely identify mobile devices and we, our Partners or our third party service providers may receive such device information if you access the Website through a mobile device. Certain features on the Website may require collection of mobile phone numbers and we may associate that phone number to mobile device identification information. Additionally, some mobile service providers operate systems that pinpoint the physical location of devices that use their services. Depending on the provider, we, our Partners or our third party service providers may receive this Information.

Embedded Scripts. An embedded script is programming code designed to collect Information about your use of the Website, such as the links you click on. The code is temporarily downloaded to your computer from our web server or a third party provider, is active only while you are connected to the Website and is deactivated or deleted once you leave the Website.

“Analytics” are tools we use, such as Google Analytics, to help provide us with information about traffic to our Website. These services use the data collected to track and monitor the use of our Website, which it shares with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.

Click-Throughs. We may send email messages or display links that use a “click-through URL” linked to the website or to another resource. When you click one of these URLs, You pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Non-Personally Identifiable Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.

Other Technologies and Data Sources. We may combine Personally Identifiable Information that you provide to us with other data, including demographic information (such as age, job industry, or job title) for purposes of responding to your inquiries, and for other purposes specified in this Privacy Policy. If information we combine in this manner includes your Personally Identifiable Information, we will treat the combined information as your Personally Identifiable Information for all purposes under this Privacy Policy.

Biometric Data. The website does collect biometric data, including the use of email addresses in combination with a password or security question answer. In addition our service providers may collect such data as described in “Sharing Your Information.” If you submit Personally Identifiable Information (including biometric data) to one of our service providers, the information you submit shall be governed by the service provider’s privacy policy and terms of use, and not by our Privacy Policy, and Terms and Conditions.

You can opt-out of having your activity on the Website made available to Google Analytics by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) for your web browser.

For more information on the privacy practices of Google, please visit: http://www.google.com/intl/en/policies/privacy/

We, or third party companies with whom we collaborate or hire to perform services on our behalf, may use your Information to provide you with information that we believe may be useful to you, such as information about products or services provided by or through us through permissible targeted advertisements. You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1.

Some users engage a Do Not Track (DNT) setting to indicate a preference regarding tracking by advertisers and other parties. We do not respond to “DO NOT TRACK” signals.

C. Information We Receive from Third Parties
We may collect additional Information about you from third party websites, or sources providing publicly available information, to help maintain and support your account. We reserve the right to request any additional information necessary to establish and maintain your account for use of the services and access to the restricted areas.

III. HOW WE USE YOUR INFORMATION
A. Use and Purpose of Processing Your Information
We use and process your information above for things that may include, but are not limited to, the following:

• To respond to your inquiries;
• Provide customer support;
• Improve our Website;
• Resolve any technical problems;
• Enhance the quality and design of the services we provide to you;
• Commission processing, payments and reports;
• Communicate with you, including sending you emails regarding products and services you like;
• Provide targeted advertisements to you;
• Analyze the use of the Website and Information about visitors to our Website to understand and improve our service offerings and, in accordance with our sharing policies, discussed below, to produce anonymous or aggregated data and statistics that might help third parties develop their own products and service offerings;
• Customize the content you see when you visit the Website, including to develop and provide advertising tailored to your interests;
• Comply with our Terms and Conditions of Use (which is available on our Website);
• Comply with any applicable laws and regulations and respond to lawful requests; and/or
• For any other purposes disclosed to you at the time we collect your Information or pursuant to your consent.

B. Lawful Basis For Processing Your Information
We believe the foregoing handling of your Information furthers our legitimate interests in commercial activities that are not overridden by the interest or fundamental rights and freedoms of the individuals at issue. We also may need to use and disclose your information to comply with our legal obligations. For example, we may provide your information to government officials and agencies as required by law, and Partners as part of business operations. For purposes of this Privacy Policy, “Partner” shall mean any person or entity with whom we enter into any kind of business transaction who is under an obligation to us to use reasonable care to keep Information confidential. When required by law, and in some other cases, we process the Information on the ground of consent by the individual.

C. How Long We Keep Your Information
We generally keep Information for so long as it may be relevant to the purposes listed above, consistent with any applicable laws and agreements. To dispose of Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for an additional time.

D. Sharing Your Information
We may share Information, such as aggregate user statistics, with our partners and non-affiliated third parties. We may provide data, including Information about you, with our affiliates, subsidiaries and Partners. We may also share your Information as disclosed at the time you provide your Information, as set forth in the Privacy Policy and in the following circumstances:

Third Party Service Providers. We employ third party service providers to perform certain services on our behalf, including, without limitation: (i) processing your information to provide legal services to you or requests you have made; (ii) providing customer service; (iii) sending e-mails to you; (iv) analyzing, updating and correcting information we receive on the Website; (v) performing business analysis, data processing and/or quality control; (vi) providing marketing assistance, search results and links (including, without limitation, paid listings and links); (vii) hosting our databases; and (viii) providing you with information you requested. Consequently, we may share your Information with these third party service providers if they need it to perform services on our behalf. However, such third party service providers are not authorized by us to use your Information for any other purpose. Please see the following third party privacy policies for additional information:

Legal Compliance. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant or other legal process; (ii) to cooperate in investigations of fraud, intellectual property infringement or any other activity that is illegal or may expose us or you to legal liability; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the Website’s users; (v) to enforce or apply the Website’s Terms and Conditions of Use; and (iv) to verify the identity of the Website’s users.

Sale or Other Transfer. Your Information may be transferred, sold or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt or (iv) are liquidated or otherwise reorganize. You consent to any and all such Conveyances of your Information.

Security Disclaimer: We use industry-standard procedures and safeguards to help protect the confidentiality of your Information. However, you should assume that no data transmitted over the Internet can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private. We do not guarantee that your information will not be misused or disclosed to third parties. We will not have any liability for misuse or disclosure of your Information.

If you believe that your information has been stolen or accessed by an unauthorized person, you are required to notify us so that necessary measures can be taken immediately.

IV. LINKS TO THIRD PARTY WEBSITES
While on the Website or when viewing an e-mail or other content provided by us or the Website, you may encounter links to other websites operated by other parties, such as Facebook, Instagram, Pinterest, Bloglovin’, Tumblr, Google+, Ello, Rss, or Twitter. If you access our Website from a third party website (“Third Party Website”), you are required to also read and accept the terms and conditions and privacy policy of that Third Party Website. We are not responsible for the privacy and security practices of those websites and you should contact such third parties directly to determine their respective privacy policies. Links to any other party’s website or content do not constitute or imply an endorsement or recommendation by us of the linked website or content.

V. HOW WE PROTECT YOUR INFROMATION
We recognize the sensitivity of our users’ Personally Identifiable Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personally Identifiable Information in accordance with applicable law. To that end, your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We use regular Malware Scanning. We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

Our Retention of Data. We retain Personally Identifiable Information for the period of time necessary to fulfill the purposes for which we obtained the Personally Identifiable Information and consistent with applicable law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personally Identifiable Information we process, and (ii) to limit the Personally Identifiable Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.

Accessing and Updating Your Information. If you would like to review, correct, or update the Personally Identifiable Information that you have provided to us, or if you would like to request an electronic copy of this Personally Identifiable Information for purposes of transmitting it to another company (to the extent applicable law provides you with this right to data portability) you may make such requests by contacting us E-mail: [email protected]

Fair Information Practices. The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email:
• Within 7 business days
We will notify the users via in-site notification:
• Within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act. The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions
• Process orders and to send information and updates pertaining to orders.
• Send you additional information related to your product and/or service
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CAN-SPAM, we agree to the following:
• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at the address listed at the bottom of each email and we will promptly remove you from all correspondence.

VI. OUR RIGHT TO CONTACT YOU
We may contact Website visitors who provide us regarding account status, privacy statement, or any other policies or agreements relevant to site visitors. We may contact you by way of text, email, via social media channel (including but not limited to Facebook, Twitter and/or Instagram) webform, or telephone.

VII. CONSENT TO TRANSFER
The Website is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Website, or providing us with any information, you consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. Portions of our site may be supported by a network of computers or cloud-based servers in other jurisdictions. We do not represent that our Website is appropriate or available in any particular jurisdiction.

VIII. UPDATING AND ACCESSING YOUR INFORMATION
To the extent certain data protection laws apply and we hold your Information in our capacity as a data controller as defined under those laws, you may request that we:

• Restrict the way that we process and disclose your Information
• Transfer your Information to a third party
• Revoke your consent for processing of your Information
• Provide you with access to your Information
• Remove your Information if no longer necessary for the purposes collected
• Prevent the processing of your Information for direct-marketing purposes
• Update your Information so it is correct and not out of date
• Object to our processing of your Information
• Your “Right to be Forgotten.” If you are protected by the GDPR with respect to our use of your information, upon proper request, we may take the steps set out in the GDPR to erase your Personally Identifiable Information, including information that may be publicly available via the website. Notwithstanding the above, the Services are not intended for European Union (EU) residents. If you provide us with personal information, you understand that your information may be stored in the United States and other countries that may not or do not provide the same level of protection as the EU. By using and accessing our Services, users who reside or are located in countries outside of the United States agree and consent to the transfer and processing of personal information on servers located outside of the country where they reside, and acknowledge that the protection of such information may be different than required under the laws of their residence or location.
• Do not Track. We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place

You have the following options for modifying or causing to be deleted Personal Information or demographic information previously provided by you to us:
1. E-mail: [email protected]

The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests. You have the right to lodge a complaint with the authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly.

If you ask us to delete your information, we will do so within a reasonable period of time, but not longer than one month from the date the request is received. Note, certain Information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests and to satisfy our legal and security obligations. In addition, you should be aware that it is not always possible to completely remove or delete all your information from our databases without some residual data because of backups and other reasons. See also section regarding our retention of your Information.
In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted through the Website. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

IX. OPT-OUT POLICY
We may send you e-mail regarding various products and services which we believe may be of interest to you. If you do not want to receive such e-mails, we provide customers with the opportunity to opt-out of receiving communications from us. If you no longer wish to receive specific communications or services, you have the following options:

1. You can send an e-mail: [email protected]

Instructions for opting out of any e-mail newsletter you receive are included with each e-mail.

X. NOTICE TO CALIFORNIA RESIDENTS
Shine the Light. California Civil Code Section 1798.83, also known as the “Shine the Light” law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personally Identifiable Information to third parties for direct marketing purposes. The Shine the Light law further requires us to allow California residents to opt out of certain disclosures of Personally Identifiable Information to third parties for their direct marketing purposes. If you are a California resident and would like a copy of such notice, please submit a written request to the address below.
Personal Information We Collect. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). The CCPA sets forth certain categories of information under Cal. Civil Code §1798.140 (o)(1) and we have listed all of those categories below. For each category, we have provided information as to whether or not we have collected Personal Information under those categories within the last twelve (12) months:
Identifiers. We collect Personal Information of Users of our website, which fall within the category of Identifiers and which include Personal Information such as: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal information categories listed in Cal. Civ. Code § 1798.80(e) (the California Customer Records Statute). We collect personal information such as account profiles, bank account number, credit card number, debit card number, or any other financial information, as provided by you.
Commercial Information. This includes information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Included in this category is:
• Information we receive from you in your use of the website in order to use our Company’s Service.
• Information about Company’s Service including:
• information about your use of Company’s Service (including account related information such as payment information, purchase history);
• customer services information; and
• customer relationship management and marketing information.
Biometric Information. We collect biometric information such as username in connection with a password as part of your account.
Internet or other electronic network activity information. We collect internet and other electronic network activity information such as browsing history, search history, interactions with our website, email applications, and advertisements.
Audio, electronic, visual, thermal, olfactory, or similar information. We do not collect sensory information such as audio, electronic, visual, thermal, olfactory or other similar Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Professional or employment related information. We do not collect professional or employment related information with regard to job applications, employment records, professional association memberships and other job-related Personal Information.
Inferences drawn from other Personal Information. We collect information that may be considered a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Categories of Sources. We collect this personal information from the following categories of sources:
• Consumers (information received directly from you);
• Service providers;
• Affiliates
Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes include, without limitation:
• Our commercial purposes, including marketing, advertising, and enabling commercial transactions.
• Our business purposes as identified in the CCPA, which include:
o Auditing related to our interactions with you;
o Legal compliance;
o Detecting and protecting against security incidents, fraud, and illegal activity;
o Debugging;
o Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
o Internal research for technological improvement;
o Internal operations;
o Activities to maintain and improve our services; and
o Other one-time uses.
California Residents’ Privacy Rights and Choices. If you are consumer as defined in the CCPA, i.e., a resident of California as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in relation to your Personal Information under the CCPA. Under the CCPA, you have the following rights:
Right to Request Information Collected and Shared for a Business Purpose. If we collect Personal Information about you that is disclosed for a business purpose, you have the right to request that we disclose to you:
• The categories of Personal Information that we have collected about you
• The categories of sources from which the Personal Information about you is collected.
• The business or commercial purpose for collecting or selling Personal Information.
• The categories of Personal Information we disclosed about you for a business purpose.
Right Not to Be Discriminated Against. you have the right to not be discriminated against by a business because you exercised any of the consumer’s rights under the CCPA.
Right to Request Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions, as outlined below (Verification and Record-Keeping).
Right to Request Access and Data Portability. Upon receipt of a verifiable request from you to access your Personal Information we shall promptly take steps to disclose and deliver, free of charge to you, the Personal Information in accordance with Cal. Civil Code §1798.100 (d). The Personal Information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit this information to another entity without hindrance. We may provide Personal Information to you, but we are not required to provide Personal Information to you more than twice in a 12-month period.
Verification and Record-keeping.
If you are a California resident, we will process your request to exercise your Rights in accordance with California Laws. When a request is made, we may first take steps to sufficiently verify your identity to protect your privacy and security. Once we confirm your identity and verify your consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise our right to free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided it.
A record concerning the requests may be maintained pursuant to our legal obligations. Further, we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.
If you wish to opt-out of having your Personal Information shared or request what Personal Information has been shared with third parties, you have the following options:
1. You can send an e-mail: [email protected]

For all requests, put the statement “Your California Privacy Rights” in the subject matter of your request.

XI. CHILDREN’S INFORMATION
The Website is intended only for users over the age of eighteen (18). If we become aware that a user is under 13 (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such information. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of thirteen (13).

XII. CONSENT
By using the Website you consent to the collection and use of your Information as set forth in this Privacy Policy. If you withdraw consent, you agree that despite withdrawal we may continue to use your Information previously provided to us to the extent that we are legally or contractually obligated to do so and to the extent necessary to enforce any contractual obligations you may have to us. You also understand that in withdrawing consent, we may no longer be able to provide you with services previously available with consent.

XIII. COMPLAINTS AND DISPUTE RESOLUTION
If you have any suggestions on how we can improve our Services or complaints you would like us to address, please contact us as set forth in Contact Us. If You are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.

If you are protected by the GDPR with respect to our use of your information, you may lodge a complaint with a data protection authority for your country or region. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

This Privacy Policy shall be governed by, and construed in accordance with, the laws of the State of California without regard to principles of conflicts of laws.

Any dispute, claim or controversy among the parties arising out of or relating to this Policy, except for any provisions relating to a consumer’s rights under the CCPA shall be finally settled by arbitration in Los Angeles, California in accordance with the Consumer Arbitration Rules of the American Arbitration Association then in effect and such resolution shall be final and binding upon the parties.

THE PARTIES AGREE TO WAIVE ANY RIGHT TO TRIAL BY JURY IN ANY CIVIL ACTION ARISING OUT OF OR RELATING TO THIS POLICY. THE PARTIES AGREE TO ARBITRATE SOLELY ON AN INDIVIDUAL BASIS AND THAT THIS POLICY DOES NOT PERMIT CLASS ARBITRATION OR ANY CLAIMS BROUGHT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS OR REPRESENTATIVE ARBITRATION PROCEEDING. THE VALIDITY, EFFECT, AND ENFORCEABILITY OF THE FOREGOING WAIVER OF CLASS ACTION LAWSUIT AND CLASS-WIDE ARBITRATION, IF CHALLENGED, ARE TO BE DETERMINED SOLELY AND EXCLUSIVELY BY THE STATE COURTS LOCATED IN LOS ANGELES COUNTY, CALIFORNIA, OR, IF BROUGHT IN A FEDERAL DISTRICT COURT, THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA.

The parties hereto hereby submit to the exclusive jurisdiction of the courts sitting in Los Angeles, California and agree that venue is proper therein (and waive any objection to such venue) for the purpose of compelling arbitration and enforcing any arbitration award entered pursuant hereto.

Without waiving the right to appeal such decision, should any portion of this section be stricken from this Policy or deemed otherwise invalid or unenforceable, then this entire section (other than this sentence) shall be stricken from this agreement and inapplicable, and any and all disputes shall proceed in the state courts located in Los Angeles California, or, if brought in a federal district court, United States District Court for the Southern District of California and be decided by a judge, sitting without a jury, according to applicable court rules and procedures, and not as a class action lawsuit.

XIV. CHANGES TO THIS PRIVACY POLICY
We reserve the right to change, modify or amend this Privacy Policy at any time to reflect changes in our products and service offerings. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes. Any revised Privacy Policy will only apply prospectively to Information collected or modified after the Effective Date of the revised policy. It is your responsibility to periodically check and review our Privacy Policy for changes.

XIII. QUESTIONS
If you have any questions about this Privacy Policy, please send us an email at [email protected]

Last Updated on: 1/28/22

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