Last Modified: 05/21/2025

Vencire Media Ltd, a Delaware Corporation (the “Company,” “We,” or “Us”),

thanks you for being part of our community. We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. We strive to use information to provide the best possible service while respecting the confidentiality of information we are entrusted with. This Privacy Policy describes the types of information that we may collect from you or that you may provide when you visit our Website and our practices for collecting, using, maintaining, transmitting, protecting, and disclosing that information.

a. This Privacy Policy also applies to all information we collect:

(i) in email, text, and other electronic messages between you and the Company or through links to the Website;

(ii) through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website;

(iii) through social media pages controlled by us or that we interact with;

(iv) when you interact with our advertising and applications, including sweepstakes, contests, or other online promotions on our Website or on third-party websites and services if those applications or advertising include links to this Privacy Policy;

(v) when you complete a survey or questionnaire; participate in a focus group or other consumer or market research project;

(vi) when you post a product review; send us any feedback, questions, comments, suggestions, or ideas;

(vii) when you visit one of our brick-and-mortar stores; and

(viii) when you shop online.

b. All of the above points of contact are herein collectively referred to as

“Platforms.”

c. This Privacy Policy shall not apply to information collected by:

(i) us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); and/or

(ii) any third party (including our affiliates and subsidiaries), including information collected through any application or content that may link to or be accessible from or on the Website.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES

AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL

TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, IT IS

YOUR CHOICE NOT TO USE OUR WEBSITE. BY ACCESSING OR USING THIS

WEBSITE, YOU AGREE TO THIS PRIVACY POLICY AND AGREE TO ALL OF THE

TERMS AND CONDITIONS SET FORTH HEREIN. THIS PRIVACY POLICY MAY

CHANGE FROM TIME TO TIME (SEE CHANGES TO OUR PRIVACY POLICY), IN

OUR DISCRETION. YOUR CONTINUED USE OF THIS WEBSITE AFTER WE

MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES, SO

PLEASE CHECK THE POLICY PERIODICALLY FOR UPDATES.

1. This privacy policy explains:

a. Websites Covered by This Privacy Policy

d. Changes to Our Privacy Policy

e. Contact Information

f. Types of Information We Collect

g. How We Use Your Information and Who We May Share It With

h. Third-Party Links & Content

i. Security and Data Location

j. WHAT ARE YOUR PRIVACY RIGHTS?

2. Websites Covered by This Privacy Policy.

a. Our Website may from time-to-time link to third-party websites for your

convenience and to provide easy access to additional useful information. Should you select such

a link you will leave the Website. We do not control those sites nor their privacy practices,

which may differ from our practices and policies. Any personal data you choose to provide to or

that is collected by such third parties is not in any way covered by this Privacy Policy. We

recommend that you read over such website’s privacy policy before providing any personal

information. A link to another website from Us does not constitute an endorsement or

representation about the value, quality, or usefulness of anything found on that third-party

website.

b. Our Service runs on Third-Party Service Providers. These Third-Party Service

Providers adopt and post their own privacy policies. However, the use of your Personally

Identifiable Information by such parties is governed by the privacy policies of such parties and is

not subject to our control.

c. Throughout this policy, when we refer to "Websites," we mean all Company

affiliated or controlled websites (such as fundraising websites, promotional websites, or websites

utilized for consumer and/or marketing research) and any other microsites or mobile websites we

operate or use Social Media Pages are the official social media pages we operate on

Facebook, Twitter, Instagram, LinkedIn, and other social media platforms. This privacy policy

This applies to all our Platforms (or pages or tabs within our Platforms) that feature brands owned by the Company and to our communications with you via texts and emails that may refer to these brands. If you have any questions about these definitions or anything else in this privacy policy, email us at michael@vencire.com .

d. PLEASE BE AWARE THAT IF YOU ELECT TO HAVE US SHARE YOUR INFORMATION WITH THIRD PARTIES, SUCH AS OUR INFRASTRUCTURE AND OTHER THIRD-PARTY PROVIDERS, THOSE ELECTIONS TO HAVE YOUR INFORMATION SHARED WILL SUPERSEDE ANYTHING TO THE CONTRARY IN THIS PRIVACY POLICY.

3. Changes to Our Privacy Policy.

a. We reserve the right to amend this privacy notice at our discretion and at any

time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an active, up-to-date, and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

b. PLEASE NOTE THAT FOR CALIFORNIA RESIDENTS THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (“CCPA”) AS REVISED BY THE CALIFORNIA PRIVACY RIGHTS ACT (“CPRA”), EFFECTIVE AS OF JANUARY 1, 2023, WILL GOVERN OUR USE AND YOUR RIGHTS WITH REGARD TO YOUR PERSONAL INFORMATION. THIS PRIVACY POLICY HAS BEEN UPDATED TO COMPLY WITH THE CPRA AND ITS ASSOCIATED REGULATIONS.

4. Contact Information.

You have the right to request information with respect to the types of personal information we share with third parties and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. To obtain this information, please email us at michael@vencire.com . Please allow up to thirty (30) days for a response. We value your opinions and suggestions. Please email us with any questions or concerns, or alternately you can write to us at the following address:

Vencire Media Ltd.

8 The Green Suite A

Dover, Delaware 19901

5. Types of Information We Collect.

a. When you access our Website, or access our other Platforms, we collect several types of information from and about users of our Website, depending on the context of your interactions with Us and the Website (“Personal Information”), including information:

(i) by which you may be personally identified, such as: name, e-mail address, telephone number, gender, ZIP code/postal code, or other additional information supplied by you, by which you may be contacted online or offline

(ii) necessary to process your payment if you make purchases, including

payment details such as your payment instrument number (i.e., a credit

card number), and the security code associated with your payment

instrument, collected in connection with an order, a return, a promotion,

contest, or fundraising event. All payment data is stored after tokenizing

your account, or collected in connection with your shopping history with

us, including the items you purchase);

(iii) content you submit to our Platforms, including photos, videos, or reviews.

(iv) aggregated information about people who visit and interact with our Social

Media Pages. means information that regards you but does

not include your personal information or otherwise is specifically

associated with you.

(v) If you call, email, text, or chat with our customer service agents, we may

keep records of those conversations.

b. We collect this information:

(i) directly from you when you provide it to us;

(ii) automatically as you navigate through the site, use our services, or visit a

store. Information collected automatically may include usage details, IP

addresses, information collected through cookies, and video footage or

photographs captured when you are on our premises.

6. Information You Provide to Us.

a. The information we collect on or through our Website may include, but is not

limited to:

(i) information that you provide by filling in forms on our Website. This

includes information provided at the time of registering to use our

Website, goods ordered or returned, material posted, or further services

requested. We may also ask you for information when you enter a contest

or promotion sponsored by us, when you make a donation for an affiliated

fundraising event and when you report a problem with our Website;

(ii) records and copies of your correspondence (including email addresses and

related contact information) if you contact us;

(iii) your responses to surveys that we might ask you to complete for research

purposes;

(iv) details of transactions you carry out through our Website and of the

fulfillment of your orders. You may be required to provide financial

information before placing an order through our Website;

(v) your search queries on the Website;

(vi) information required to process a credit card transaction; and/or

(vii) video recordings and photographic information of you when you visit one

of our stores.

(viii) We may take your personal information and de-identify it so as to make it

non-personally identifiable, either by combining it with information about

other individuals and/or by hashing the information or otherwise removing

characteristics that make the information personally identifiable directly to

you. We will treat de-identified information as non-personal to the fullest

extent allowed by applicable law.

(ix) We may combine the information we collect online with information we

collect in our stores or elsewhere offline.

b. You also may provide information to be published or displayed (hereinafter,

“Posted”) on public areas of the Website or transmitted to other users of the Website or third

parties (collectively, “User Contributions”). Additionally, we cannot control the actions of other

users of the Website with whom you may choose to share your User Contributions. Therefore,

we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized

persons.

7. Information We Collect From Other Sources.

a. We are part of the Vencire Media Corporation and may receive additional information about

you from the other brands in our corporate family.

b. We also obtain information about you from other sources, such as:

(i) marketing partners, including joint marketing/co-branding partners, data

co-ops, data brokers, and marketing, advertising, and analytics companies;

(ii) service providers and vendors, including fraud prevention providers,

mailing list providers, fulfillment partners, and shipping carriers; and

(iii) social media sites or similar third-party services when you like, follow, or

share our content on social media pages, or similar sites.

c. Additionally, if you create or log into your account or interact with us through a

third-party platform, we will have access to certain information from that platform, such as your

profile information, profile picture, user ID associated with your third-party platform account,

and any other information the third-party platform discloses about you, in accordance with the

authorization procedures determined by such platform.

8. Community Forums and User Submission.

a. Through our communication functionality and interactive features (“Community

Forums”), you may have the opportunity to submit information to us. Any and all information

and content that you submit or post to the Community Forums, including, without limitation,

photos, audio, video, messages, text, files, reviews, or other content you provide us and as further

described in our Terms of Use shall be classified as User Submissions (“User Submissions”).

Your User Submissions may be subject to additional terms as provided in our Terms of Use,

located on our site which we ask that you review as your use of and

submission of information to us is deemed as an acceptance of our Terms of Use. Additionally,

some features, such as user reviews, may be operated by a third party and your postings also may

be subject to the third party’s privacy policy and terms of use.

b. Please note that certain information, such as your name and/or place of residence,

may be publicly displayed on the Website along with your User Submissions. Your use of any

Community Forum is subject to our Terms of Use, including without limitation the “User

Submissions” section. Note that anything you submit through a public-facing Community

Forum may be made public – others will have access to your User Submission and may use it or

share it with third parties. We are not responsible for the actions of third parties, and the use of

your information and other User Submissions by such third parties is not subject to the

protections of this Privacy Policy.

c. Social Networking Features. Functionality on the Website may permit

interactions between the Website and a third-party service such as Facebook or Instagram

(“Social Networking Features”). Examples of Social Networking Features include enabling you

to “Like” or “Share” content from the Website or to “Like” or “Share” our page on a third-party

service; to automatically or selectively show your social media posts on the Website; and to

otherwise connect the Website to a third-party service. If you choose to share content or to

otherwise post information through the Website to a third-party service, or vice versa, that

information may be publicly displayed. Similarly, if you post information on a third-party

service that references us (for example, by using a hashtag associated with us in your post), your

post may be published on the Website or otherwise in accordance with the terms of that third

party. Also, both we and the third party may have access to certain information about you and

your use of the Website and the third-party service. These third-party social networking

companies may collect information about your visit to a Platform through the Social Networking

Features we have integrated into the Platform, and - if you are signed into your account with

such a third-party social networking company – it may collect additional information in

accordance with the terms of your agreement with that company. In addition, we may receive

information about you if other users of a third-party service give us access to their profiles and

you are one of their “Connections” or information about you is otherwise accessible through

your profile or similar page on a social networking or other third-party service. The information

we collect in connection with Social Networking Features is subject to this Privacy Policy. The

information collected and stored by the third party remains subject to the third party’s privacy

practices, including whether the third party continues to share information with us, the types of

information shared, and your choices with regard to what is visible to others on that third-party

service.

d. We may make available on the Platforms a “Send-to-a-Friend,” “Refer a

Friend,” “Wish List” or similar function that permits you to send Platform content directly to a

third party through the Platforms. If you send a friend a communication using such

functionality, the information you provide about your friend (e.g., name and e-mail address) is

used to facilitate the communication and is not used for any other marketing purpose unless we

obtain consent from that person. If you disclose any personal information relating to other

people, you represent that you have the authority to do so and to permit us to use the information

in accordance with this Privacy Policy.

e. All personal information that you provide to us must be true, complete, and

accurate, and you must notify us of any changes to such personal information.

f. Employment Applications. If you apply for a job through the Website, we or our

service provider(s) may ask you to provide self-identifying information (such as veteran status,

gender, and ethnicity) in conjunction with laws and regulations enforced by, as applicable, the

Equal Employment Opportunity Commission and other federal, state, provincial/territorial, and

local regulatory agencies. Providing such self-identifying information is voluntary, but if you do

provide such information, we and/or our service provider may submit that information to the

appropriate government or regulatory agencies to fulfill reporting requirements and use that

information to defend against employment-related complaints.

9. Information We Collect Through Automatic Data Collection Technologies.

a. As you navigate through and interact with our Website, we may use automatic

data collection technologies to collect certain information about your equipment, browsing

actions, and patterns, including:

(i) details of your visits to our Website, including traffic data, location data,

logs, and other communication data, and the resources that you access and

use on the Website; and

(ii) information about your device and internet connection, including your IP

address, operating system, and browser type.

b. The information we collect automatically is only statistical data and does not

include personal information, but we may maintain it or associate it with the personal

information that we collect in other ways or receive from third parties. It helps us to improve our

Website and to deliver a better and more personalized service, including by enabling us to:

(i) estimate our audience size and usage patterns;

(ii) store information about your preferences, allowing us to customize our

Website according to your individual interests;

(iii) speed up your searches;

(iv) recognize you when you return to our Website; and

(v) to protect our Services. We may use your information as part of our

efforts to keep our Website safe and secure (e.g., for fraud monitoring and

prevention).

(vi) to create a better experience for you and provide you with targeted

advertising.

c. The technologies we use for this automatic data collection may include:

(i) Cookies (or browser cookies). A cookie is a small file placed on the hard

drive of your computer. You may refuse to accept browser cookies by

activating the appropriate setting on your browser. However, if you select

this setting, you may be unable to access certain parts of our Website.

Unless you have adjusted your browser setting so that it will refuse

cookies, our system will issue cookies when you direct your browser to

our Website. These technologies are able to store a unique identifier for a

device to allow a certain Internet site to recognize the device whenever the

device is used to visit the site. These technologies may be used for many

purposes by us and our third-party service providers, such as automatically

collecting Usage Information, enabling features, remembering your

preferences, and providing you with targeted advertising elsewhere online.

If you do not want to accept cookies, you can block them by adjusting the

settings on your Internet browser. You can find more information about

cookies and how they work at www.allaboutcookies.org.

(ii) Flash Cookies. Certain features of our Website may use local stored

objects (or Flash cookies) to collect and store information about your

preferences and navigation to, from, and on our Website. Flash cookies

are not managed by the same browser settings as are used for browser

cookies. For information about managing your privacy and security

settings for Flash cookies, see Choices About How We Use and Disclose

Your Information.

(iii) Web Beacons. Pages of our Website may contain small electronic files

known as web beacons (also referred to as clear gifs, pixel tags, and

single-pixel gifs) that permit the Company, for example, to count users

who have visited those pages and for other related website statistics (for

example, recording the popularity of certain website content and verifying

system and server integrity).

(iv) Web Browsers. Certain browsers, or browser add-ons, may provide

additional local data storage mechanisms that are used in a manner similar

to cookies, and some of the content included on our Platforms may make

use of this local storage. If you choose to disable cookies, or to otherwise

restrict local storage, some features of the Platforms may not function

properly, including the shopping cart and ordering processes.

(v) Embedded Scripts. An embedded script is programming code that is

designed to collect information about your interactions with the Platforms,

such as the links you click on. The code is temporarily downloaded onto

your device from our server or a third-party service provider, is active

only while you are connected to a Platform and is deactivated or deleted

thereafter.

(vi) JavaScripts. JavaScripts are code snippets embedded in various parts of

websites and applications that facilitate a variety of operations including

accelerating the refresh speed of certain functionality or monitoring usage

of various online components.

(vii) Entity Tags. Entity Tags are HTTP code mechanisms that allow portions

of websites to be stored or “cached” within your browser and validates

these caches when the website is opened, accelerating website

performance since the web server does not need to send a full response if

the content has not changed.

(viii) HTML5 Local Storage. HTML5 local storage allows data from websites

to be stored or “cached” within your browser to store and retrieve data in

HTML5 pages when the website is revisited.

(ix) Resettable Device Identifiers. Resettable device identifiers (also known as

“advertising identifiers”) are similar to cookies and are found on many

mobile devices and tablets (for example, the “Identifier for Advertisers” or

“IDFA” on Apple iOS devices and the “Google Advertising ID” on

Android devices), and certain streaming media devices. Like cookies,

resettable device identifiers are used to make online advertising more

relevant.

We do not collect personal information automatically, but we may tie this information to

personal information about you that we collect from other sources, or you provide to us.

d. Third-Party Use of Cookies and Other Tracking Technologies.

(i) Some content or applications on the Website are served by third parties,

including, without limitation, advertisers, advertising networks and

servers, content providers, and application providers (each, a “Third-Party

Data Collector”). The Third-Party Data Collector may use cookies alone

or in conjunction with web beacons or other tracking technologies to

collect information about you when you use our Website. The information

a Third-Party Data Collector collects may be associated with your

personal information, or your online activities over time, across external

websites and other online services. A Third-Party Data Collector may use

this information to provide you with interest-based (behavioral)

advertising or other targeted content.

Privileged and Confidential – FRB Draft (5.16.25)

(ii) We do not control the tracking technologies of any Third-Party Data

Collector nor how information collected by any Third-Party Data

Collector may be used. If you have any questions about an advertisement

or other targeted content, you should contact the relevant Third-Party Data

Collector directly.

(iii) We also contract with third party advertising, analytics companies or

other service providers to perform certain services on our behalf, such as

online ads on other websites, hosting the Platforms or Platform features,

delivering packages, processing credit card payments, processing

transactions and fulfilling orders, removing repetitive information from

customer lists, providing customer service, providing website usage

analytics, providing search results and links (including paid listings and

links), providing targeted advertising, sending email, direct mail or other

communications, providing marketing assistance and data analysis or

enhancement, or performing other administrative services. These

companies use cookies or similar technologies to collect information about

your interactions with our Platforms and interactions with other websites.

These advertising companies may use and share the information gathered

to deliver ads more tailored to your interests. We receive aggregate

information from these third parties to understand our advertising

effectiveness. Any information collected by us or by third parties through

the use of cookies or similar technologies may be linked with other

information we collect about you. We may give these service providers

access to your information (or allow them to collect information from or

about you) so that they can carry out the services they are performing for

you or for the Company. These third parties share information they have

collected with us. Your information may also be collected and processed

by third parties, such as the payment providers you select, who will

process your information independently in accordance with their own

privacy notices. Your information may also be shared with us by others,

such as your friends and family, when they use a service on our Platforms;

for example, by sending you an E-Gift Card or shipping an order to your

address. If someone else has provided us with your information, we will

only process your information for the applicable purpose(s) as described

below in this Policy.

10. Information We Collect Through Video Footage.

a. When you visit a store, we may collect video recordings and photographs of you

that we use:

(i) for security;

(ii) to detect and prevent fraud;

(iii) prevent product loss or damage;

(iv) report incidents, and

(v) for operational purposes.

11. Do We Collect Information From Minors?

a. Our Platforms are general audience points of contact and are not directed at

children under the age of thirteen (13). Further, we do not knowingly solicit data from or market

to children under eighteen (18) years of age. By using the Website, you represent that you are at

least eighteen (18) years of age or that you are the parent or guardian of such a minor and

consent to such minor dependent’s use of the Website. If we learn that personal information

from users less than eighteen (18) years of age has been collected, we will deactivate the account

and take reasonable measures to promptly delete such data from our records. If you become

aware of any data we may have collected from children under eighteen (18) years of age, please

contact us at michael@vencire.com .

b. No Right to Opt-In to the Sale for Personal Information for Users under sixteen

(16). Without limiting the foregoing, any user who is under sixteen (16) years of age is not

permitted to opt in to the sale of their Personal Information.

c. Our Platforms are not intended for children under thirteen (13). No one under

thirteen (13) should share any Personal Information with us, including creating an account or

making a purchase. The children's clothing we offer for sale is intended for purchase by adults

only. We do not knowingly collect any personal information from children under thirteen (13).

If we learn that we have collected the personal information of a child under thirteen (13), we will

make reasonable efforts to delete that information from our records. To request deletion of

personal information relating to a child under thirteen (13), please email [EMAIL].

d. California residents under sixteen (16) years of age may have additional rights

regarding the collection and sale of their personal information. Please see Your State Privacy

Rights for more information.

12. What Categories of Personal Information Do We Collect?

a. We have collected the following categories of personal information in the past

twelve (12) months:

(i) Identifiers. Contact details, such as real name, alias, postal address,

telephone or mobile contact number, unique personal identifier, online

identifier, device identifier, date of birth (or partial DOB such as birth day

and month), Internet Protocol address, email address and account name; or

other similar identifiers.

(ii) Personal information. Categories listed in the California Customer

Records statute (Cal. Civ. Code § 1798.80(e)). This may include, your

name, signature, contact information, education, employment,

employment history Social Security number, physical characteristics or

description, address, telephone number, passport number, driver’s license

or state identification card number, insurance policy number, education,

bank account number, credit card number, debit card number, or any other

Privileged and Confidential – FRB Draft (5.16.25)

financial information, medical information, or health insurance

information.

(iii) Financial Information. This may include signature, credit card number,

debit card number, and other financial information.

(iv) Protected Classification Characteristics Under California or Federal

Law. The classification characteristics include: date of birth, age, race,

ancestry, ethnicity or national origin, citizenship, religion or creed, marital

status, medical condition, physical or mental disability, sex (including

gender, gender identity, or gender expression), pregnancy or childbirth and

related medical conditions), sexual orientation, veteran or military status,

and genetic information (including familial genetic information).

(v) Commercial information. Commercial information includes transaction

information, purchase history, financial details, payment information,

records of items considered, purchased, and returned; information about

reviews you have written; information about your customer service

contact history (such as when you interact with our customer service team

over the phone or through chat or if you respond to our text messages,

including transcriptions of conversations and IVR recordings);

information about your participation in our loyalty program or other

member programs (such as how many points you have and promotion

codes we send to you); and information about your participation in any

contests, sweepstakes, or promotions.

(vi) Biometric information. This includes genetic, physiological, behavioral,

and biological characteristics, or activity patterns used to extract a

template or other identifier or identifying information, such as,

fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,

gait, or other physical patterns, and sleep, health, or exercise data and

advanced clothes fitting features that are based on body scanning

technology.

(vii) Internet or Other Similar Network Activities. This includes browsing

history, search history, online behavior, interest data, and interactions with

our and other websites, applications, systems, and advertisements. This

category includes: the hardware model, browser, and operating system you

are using; the URL or advertisement that referred you to the Platform you

are visiting; all of the areas within the Platforms that you visit; devices

you have used to access the Platforms; login information (such as your last

login); your time zone; location information based off your IP address;

and mobile network (if applicable).

(viii) Geolocation data. This includes device location, Physical location, or

movements that we can collect through your use of our mobile app or

features on our Website (e.g., store locator).

(ix) Sensory Data. This includes audio, electronic, visual, thermal, olfactory,

or similar information, images and audio, video or call recordings created

in connection with our business activities. We may collect images or

recordings from you when you use certain features of the Platforms, such

as writing product reviews. We may also contact you directly regarding

re-use of a photo or video you have created.

(x) Professional or Employment-Related Information. This includes current

or past employment, employment history, business contact details in order

to provide you our services at a business level, job title, work history, and

professional qualifications if you apply for a job with us.

(xi) Education Information. Non-public education information (per the Family

Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R.

Part 99)): Education records directly related to a student maintained by an

educational institution or party acting on its behalf, such as grades,

transcripts, class lists, student schedules, student identification codes,

student financial information, or student disciplinary records.

(xii) Inferences Drawn From Other Personal Information. Inferences drawn

from any of the collected personal information listed above to create a

profile or summary about, for example, an individual's preferences and

characteristics, psychological trends, predispositions, behavior, attitudes,

intelligence, abilities, and aptitude.

b. Inferred information. To help keep our databases current and to provide you the

most relevant content and experiences, we may infer or generate information based on the

information we collect or combine information provided by you with information from third

party sources, in accordance with applicable law. For example, we may profile user attributes or

create profiles reflecting user behavior. We may also infer, generate, or collect and receive

information from third parties, including partners, and from publicly accessible sources, for

purposes that include to detect, prevent, or otherwise address fraudulent, deceptive, or illegal

activity, misuse of our services and software, security or technical issues, as well as to protect

against harm to the rights, property or safety of our employees, users, children, or the public.

c. Personal information does not include: Publicly available information from

government records, deidentified or aggregated consumer information. Information excluded

from the CCPA’s scope, such as: health or medical information covered by the Health Insurance

Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of

Medical Information Act (CMIA) or clinical trial data; personal information covered by certain

sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-

Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the

Driver’s Privacy Protection Act of 1994. We obtain the categories of personal information listed

above from the following categories of sources: directly from our clients or their agents,

indirectly from our clients or their agents, or directly and indirectly from activity on our Website.

d. We may also collect other personal information outside of the specified categories

in instances where you interact with us in-person, online, or by phone or mail in the context of:

(i) Receiving help through our customer support Platforms;

(ii) Participation in customer surveys or contests; and

(iii) Facilitation in the delivery of our Services and to respond to your

inquiries.

13. How We Use Your Information.

a. General Use.

(i) The information We collect about you or that you provide to us, including

any personal information, is used to comprehensively understand your

needs and interests, and permit Us to deliver a more consistent and

personalized experience. For example, We may use your information:

(A) To present our Website and its contents to you;

(B) To provide you with information, products, or services that you

request from us;

(C) To provide you with notices about your account, including

expiration and renewal notices;

(D) To carry out our obligations and enforce our rights arising from

any contracts entered into between you and us, including for

billing and collection;

(E) To notify you about changes to our Website or any products or

services we offer or provide though it;

(F) To allow you to participate in interactive features on our Website;

(G) To provide personalized promotional offers and select content to

be communicated to you; 

(H) To detect, prevent and remediate fraud or other potentially

prohibited or illegal activities; and/or

(I) For any other purposes with your consent.

(ii) We may also use your information to contact you about our own and third-

parties’ goods and services that may be of interest to you. If you do not

want us to use your information in this way, please adjust your user

preferences in your account profile. For more information, see Choices

About How We Use and Disclose Your Information.

b. SMS Marketing.

(i) We may collect your telephone numbers in accordance with the practices

set forth in this Privacy Policy, for example, during purchases or when you

sign up to receive promotional messages. You can opt into receiving SMS

messages by opting in on a purchase order check out page, or by email.

(ii) We may use your phone number to provide you with personalized updates,

promotional offers, exclusive discounts, and updates. These text messages

may relate to our product, services, promotions, discounts, or any other

updates that we believe may interest you.

(iii) SMS messaging charges may be applied by your carrier.

c. We may use the information we collect for the following business purposes:

(i) Understanding You. Analyzing your activity with us (including your

interactions with our store, Platforms, affiliated websites, fundraisers,

promotions, surveys and focus groups, and emails or other forms of

communication) and monitoring the effectiveness of our advertising and

communications.

(ii) Personalization. Using your preferences and other collected information

to personalize our relationship with you, including presenting customized

communication, advertising, and experiences on our Platforms (e.g.,

personalized size and fit recommendations), Emails, and ads on Social

Media. We may also use the information we have collected from you to

enable us to display advertisements to our advertisers’ target audiences.

Even though we do not disclose your personal information for these

purposes without your consent, if you click on or otherwise interact with

an advertisement, the advertiser may assume that you meet its target

criteria.

(iii) Product Rating and Reviews. Post product reviews that you have

submitted.

(iv) Communications. Communicating with you, including responding to your

requests and asking for feedback through surveys or other messages.

(v) Promotions. Running contests, sweepstakes, or other promotions.

(vi) Fundraising. Managing your registration for our events, including

communication with you about your ticket and attendance; recording

attendance; processing donations, and improving fundraising participants'

experience.

(vii) Hiring. Recruiting and hiring our associates.

(viii) Your Experience. Serving content on our Platforms, developing our

products and services, better understanding your needs and preferences,

and constantly improving your experience.

d. Credit Cards/Electronic Payments. Credit card and electronic payment

information is used solely for payment processing and fraud prevention efforts. Credit card

information, and other sensitive personal information required to process a credit decision, is not

used for any other purposes by us or our financial services providers, and will not be retained any

longer than necessary to provide your services.

14. With Whom We Share Your Data and How It is Used.

a. Consent. We may process your data if you have given us specific consent to use

your personal information for a specific purpose.

b. Legitimate Interests. We may process your data when it is reasonably necessary

to achieve our legitimate business interests.

c. Performance of a Contract. Where we have entered into a contract with you, we

may process your personal information to fulfill the terms of our contract.

d. Legal Obligations. We may disclose your information where we are legally

required to do so in order to comply with applicable law, governmental requests, a judicial

proceeding, court order, or legal process, such as in response to a court order or a subpoena

(including in response to public authorities to meet national security or law enforcement

requirements).

e. Vital Interests. We may disclose your information where we believe it is

necessary to investigate, prevent, or take action regarding potential violations of our policies,

suspected fraud, situations involving potential threats to the safety of any person and illegal

activities, or as evidence in litigation in which we are involved.

f. More specifically, we may need to process your data or share your personal

information in the following situations:

(i) Business Transfers. We may share or transfer your information in

connection with, or during negotiations of, any merger, sale of company

assets, financing, or acquisition of all or a portion of our business to

another company.

(ii) Vendors, Consultants and Other Third-Party Service Providers. We

partner with third parties to assist with many aspects of our e-commerce

business, including fulfilling orders, advertising, analyzing your interests

and activity on our Platforms, and helping us communicate with

customers. We may share your data with third-party vendors, service

providers, contractors or agents who perform services for us or on our

behalf and require access to such information to do that work. Examples

include: payment processing, data analysis, email delivery, hosting

services, customer service, and marketing efforts. We may allow selected

third parties to use tracking technology on the Website, which will enable

them to collect data on our behalf about how you interact with our

Website over time. This information may be used to, among other things,

analyze and track data, determine the popularity of certain content, pages,

or features, and better understand online activity. Unless described in this

notice, we do not share, sell, rent, or trade any of your information with

third parties for their promotional purposes. We may also receive

information collected by these third parties and combine it with the

information we have collected. Some of these third parties may be located

outside the United States. Your information may also be collected and

processed by third parties, such as the payment providers you select, who

will process your information independently in accordance with their own

privacy notices.

(iii) Marketing Providers. We partner with third parties to assist with the

advertising and marketing of our business. We may share with them the

types of information described in How We Use Your Information. We

may also receive information collected by these third parties and combine

it with the information we have collected.

(iv) Other Third Parties. We will disclose information about you, including to

government bodies or law enforcement agencies, when we believe it to be

necessary for compliance with the law or to protect the users of our

Websites and Apps, our Websites and Apps, or the public.

15. Deidentified and Aggregated Data. We may create aggregated, de-identified, or

anonymized data from the personal information we collect, including by removing information

that makes the data personally identifiable to a particular user. We may use such aggregated, de-

identified, or anonymized data and disclose it to third parties for our lawful business purposes,

including to analyze, build, and improve the Services and promote our business, provided that

we will not disclose such data in a manner that could identify you.

16. Third-Party Links & Content.

a. The Website may link to or incorporate websites, advertising or content hosted

and served by third parties over which we have no control, and which are governed by the

privacy policies and business practices of those third parties. We are not responsible for the

privacy practices or business practices of any third party.

b. We may work with network advertisers, ad agencies, analytics service providers,

and other vendors to serve our advertisements on our Website and third-party websites, apps, and

elsewhere online and to provide us with information regarding use of and traffic on the Website

(including without limitation the pages viewed and the actions users take when visiting the

Website) and the effectiveness of our advertisements. For example, if you click on a specific

advertisement for a specific third party, our service provider(s) may be able to tell us the

advertisement you clicked on and where you were viewing the advertisement. The

advertisements you see may be served by us or one or more third parties, who may use

information about your activities on the Website, and other websites and services you visit across

the various devices you use, to provide you targeted content and advertising. Our service

providers may collect certain information about your visits to and activity on the Website and

other websites and services and may use this information to target advertising to you.

c. Third parties may set and access their own tracking technologies on your device

(including without limitation cookies and web beacons) and may otherwise collect or have

access to information about you (such as Usage Information and device identifier). Some of

these parties may collect personal information over time when you visit the Website or other

online websites and services. Cookies and web beacons, including without limitation those set

by third-party network advertisers, may be used to (among other things): target advertisements,

prevent you from seeing the same advertisements too many times, and conduct research

regarding the usefulness of certain advertisements to you. We may share certain information

such as device identifiers, Usage Information, hashed information, records of transactions you

conduct on our Platforms or offline, and other types of de-identified information with third-party

advertising companies, analytics providers, and other vendors for advertising and analytics

purposes. In addition, we and our third-party service providers may use this information to

perform matching with third-party cookies in order to provide targeted online marketing.

d. We use a variety of service providers to perform advertising and analytics

services, and some of these companies may be members of the Network Advertising Initiative

(“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit

optout.networkadvertising.org, which provides information regarding targeted advertising and

the opt-out procedures of NAI members. You may also want to visit optout.aboutads.info,

which provides information regarding targeted advertising and offers an opt-out for DAA-

participating companies. If you are a California resident, please see our California Privacy

Rights Notice annexed hereto as Exhibit A, regarding additional rights you have, including how

to exercise your rights.

e. We use Google Analytics, which uses cookies and similar technologies to collect