Our Company collects the following categories of personal information: (1) contact information including your name, email address, and mailing address; (2) authentication information, including the user name and password that you use to register an account on the Service; (3) financial information for payment processing purposes; (4) user content, including survey responses, comments, reviews, questions, and suggestions; (5) personal characteristics including age range, date of birth, gender, marital status, and nationality; (6) personal preferences including product preferences, online preferences, and interests; (7) online behavior information including online activity, preferences, and time spent viewing features; and (8) IP address or mobile network information.

The personal information we collect is required to provide the Service and customer support to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing the Service or support to you. The Company retains personal data for so long as reasonably necessary.

Our information processing activities include conducting our business, customer communications and support, user verification, payment processing, shipping, quality management services, Service maintenance and improvements, and complying with legal requirements. We conduct such processing operations to perform the contract that you have with us, or to take steps at your request before entering into a contract, and for our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. From time to time, we may also ask for your consent to use your information for certain specific reasons. Where we process your information on the legal basis of consent, you may withdraw your consent at any time by contacting us using the information provided below.

We may now or in the future provide customer support via chatbox or email that utilizes artificial intelligence (AI) and natural language processing (NLP) to understand customer questions and automate responses to them, simulating human conversation.

Where applicable, if our Company intends to further process your personal information for a purpose other than that for which the personal information was initially collected, the Company shall, prior to such processing, provide you with any relevant information on such additional purpose, and, to the extent required by applicable law, obtain your consent for this.

The table below explains what we use or process your personal information for, our processing operations, the legal grounds for processing, and the relevant categories of personal information that we process:

We use third party processors to collect payment information, such as a valid credit card number, type, expiration date or other financial information, to process payments for customer transactions. This information is required to be submitted as part of our checkout process. We receive a receipt of payment with payment details, such as the last four digits of the payment card; all payment information is submitted directly to our third-party payment processing companies, Shopify, Braintree, and Stripe (the “Payment Processors”), which use the information to process your payment. The use and storage of that information is governed by the Payment Processors’ applicable terms of service and privacy policy. More details about the Payment Processors can be found in this Policy under the section titled “Disclosure of Personal Information.”

We may share or disclose your personal information for the following limited purposes:

• Our affiliates. In order to provide the Service to you, we may share information with our affiliates. Some of our affiliates, including our parent company, are operated from the United States.

• Sale or Acquisition. Your information may be transferred to another company, within or outside your country of residence, in connection with a merger or in the event that our business is acquired in whole or part by another company.

• Third Parties Providing Services on Our Behalf. We may share information with Service Providers, such as the Payment Processors, who perform services and functions on our behalf to support our interactions with you. These Service Providers may assist with technical operation of our Service, provide analytics, process orders, transactions and payments, or provide customer service. We may also share non-identifying information, such as aggregate statistics or usage information, with third parties.

• Social Media Pages. We operate social media pages on third party networks and have social media icons on our websites. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers.  Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

• Your Consent to Have Your Personal Information Shared. In connection with your use of the Service, you may be asked to opt-in to receive informational or marketing offers, or to otherwise consent to the sharing of your information with a third party, including social networking sites such as Facebook, Instagram, or Twitter. If you agree to have your personal information shared with a third party, your personal information will be disclosed to the third party and will be subject to the privacy policy and business practices of that third party.

• Legal Disclosure. We may transfer and disclose information, including your personal information, usage information and device identifier, (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our agreements, terms of use, or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Service, or the public.

We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity and interactions with our emails, online and mobile advertisements, and to allow us to keep track of analytics and certain statistical information that enables the Company to improve our services and provide you with more relevant content and advertising offered by our Company, or through or linked from our services. You may, however, disallow receiving cookies at any time through your web browser. It is not our intention to use cookies to retrieve information that is unrelated to our Service or your interaction with our Service. 

The Company’s services, including this Service, are not targeted for use by children. The Company does not knowingly request or collect personal information from any child. If you are under eighteen years old, please do not provide your information on our Service. Upon notification that a child has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records. If you believe we might have any information from a child, please contact us at [email protected].

(a) General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include, without limitation, the right to request the correction, modification or deletion of your personal information, the right to opt out of the sale or sharing of your personal information (as applicable) and the right to appeal our response regarding a data subject request. We will do our best to honor your requests subject to any legal and contractual obligations.  If you would like to submit a Data Subject Request, you can contact our Company at [email protected]. If you choose to submit a Data Subject Request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. The Company will not be able to disclose information if it cannot verify that the person making the Data Subject Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. Please specify clearly which information you would like us to provide you with, review, amend, stop processing, or delete. If you would like to opt out of cross-contextual online behavioral advertising, please click on the link “Do Not Sell or Share My Information” on our websites.

(b) Rights Under the General Data Protection Regulation (GDPR). If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to GDPR, your privacy rights include the following:

1. Request to Transparency, Access and Data Portability. Through this Policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time. You may request a copy of your personal data as well as confirmation as to whether or not personal data concerning you is being processed, access to your personal data, and information on the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed, and the period of time the data will be stored. We may charge a reasonable fee to cover the administrative costs of providing you with a copy of your personal data.

2. Request to Rectify or Complete. If you notify us, or we otherwise become aware, that the personal data we hold is inaccurate, we will promptly update it and instruct others not to use it until it is updated. You can ask us to correct or complete our record of your personal data by contacting us at any time. To the extent possible, we will inform anyone who has received your personal data of any corrections.

3. Request for Erasure. You may, in certain limited circumstances where the processing is not necessary in the context of the services we provide to you, ask to have the personal data we directly or indirectly process deleted or removed.  If the request is founded, we will try to do so promptly, and, to the extent possible, will inform anyone who has received your personal data of your request. We will do our best to honor your request subject to the Company’s contractual, tax, accounting and legal obligations.

4. Request for Restriction of Processing. You may request that we limit the way in which we process your personal data where (i) you contest the accuracy of the personal data we have for you, (ii) you believe our processing of your personal data is unlawful (but you oppose the erasure of your personal data and prefer that our processing be restricted instead), (iii) we no longer need your personal data but you require such personal data for the establishment, exercise or defense of legal claims or (iv) you have objected to our processing pending the verification of our legitimate grounds for processing. If the request is founded, we will try to do so promptly, and, to the extent possible, will inform anyone who has received your personal data of your request.

5. Request for Data Portability and Transfer. You may request to receive a copy of your personal data, and have it transferred to another controller, where technically feasible.

6. Objection to Processing. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data, which request we do will our best to honor. We may continue to process your data, for example, if we need your data to establish, exercise or defend legal or contractual claims or obligations. You may also object at any time to your personal data being processed for direct marketing, and we will do our best to remove you from our marketing communications.

7. Withdrawal of Consent to Processing. Where we have relied on your consent as the legal grounds for processing, you may withdraw your consent at any time. Withdrawal does not invalidate the consent-based processing that occurred prior to withdrawal.

8. Automated Individual Decisionmaking. When you use our Services, you will not be subject to a decision based solely on automated profiling which produces legal effects concerning you or significantly affects you. We do, however, engage in automated technologies to customize your user experience on our websites based on your preferences.

You may contact us at any time where you believe that we are in breach of data protection laws or where you wish to make a complaint about our data processing. Furthermore, if you believe that our processing of your personal data is in breach of data protection laws, you have the right to lodge a complaint with the relevant data protection supervisory authority (i.e., in the U.K. or Member State of your habitual residence, place of work or place of the alleged infringement), if you are of the opinion that any of your personal data is processed in a manner constituting an infringement of the U.K. or E.U. GDPR or where you believe that we have not resolved an issue you have raised with us.

(c) California Rights and Disclosures.

“Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed.  If you are a California resident and want such a list, please send us a written request by email to [email protected] with “Privacy – California Shine The Light Rights” in the subject line.  

“Do Not Track” Disclosure: At this time, we do not respond to browser “do not track” or “DNT” signals.

Additionally, the Company may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

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