Website Privacy Policy

Information We Collect About You and How We Collect It

We collect and process your information for purposes based on legitimate business interests, the fulfillment of our agreements with you, compliance with our legal obligations, and/or your consent. We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name and e-mail address, ("Personal Information");
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners and services providers.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided when purchasing our products, or posting material. We may also ask you for information when you report a problem with our Website or service.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• 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, however we do not store or manage any financial information. Our service provider, Shopify, and any other service providers we may use from time to time in our sole discretion, directly collect and process that information at our request. However, our service providers may provide us information as necessary to accept, monitor, and track payments. To learn more about how Shopify uses your data, please visit: https://www.shopify.com/legal/privacy.
• Your search queries on the Website.

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"). Your User Contributions are posted on and transmitted to others at your own risk. 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.

Information We Collect Through Automatic Data Collection Technologies

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:

• Details of your visits to our Website, including traffic data, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include Personal Information, and we may maintain it or associate it with Personal Information 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:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

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

• 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.
• Web Beacons. Pages of our the 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).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website are served by third-parties, including content providers, and application providers. These third parties 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 they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services.

By way of example but not limitation, we use Shopify and may use other third party service providers from time to time in our sole discretion, for analytics and/or sales data. When you visit our Website, these service providers may collect the following data, which will be anonymized and aggregated before reporting back to us:

• Your IP address;
• Demographic information including your age, gender, location, and language preferences;
• Your device or browser information;
• Number of visitors to our Website;
• Pages visited while at the Website and time spent per page;
• Page interaction information, such as scrolling, clicks and browsing methods;
• Websites where visitors have come from and where they go afterwards;
• Page response times and any download errors; and
• Other technical information relating to end user device, such as IP address or browser plug-in.

This analysis is fundamental to the running of our online business and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Website, and to provide a better service and source of information to visitors.

We do not control third parties’ tracking technologies or how they may be used. To find out more about the following service providers and to learn how to opt out, please visit:

• https://www.shopify.com/legal/privacy

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us. To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you. We will do this pursuant to our legitimate interests in promoting our business. If you do not want us to use your information in this way, please unsubscribe from the relevant communication. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Cipolettis LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by The Cipolettis LLC about our Website users is among the assets transferred (“Onward Transfer”).
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use https://thecipolettis.com/pages/website-terms-of-use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Cipolettis LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We do not directly sell you personally-identifiable information to third parties. The only exception to this is in connection with an Onward Transfer, which is described above.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your email address/ contact information used by the Company to promote our own products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at other times when the option is available to you or by sending us an email stating your request to hello@thecipolettis.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a purchase or a subscription for our services or other transactions.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: hello@thecipolettis.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

The Website currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Accessing and Correcting Your Information

You may send us an email at hello@thecipolettis.com to request access to, correct or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

Data Security

We have implemented reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls using SSL technology. We do not manage, store or retain any financial information.

The safety and security of your information also depends on you. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our Website. Any transmission of your information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

EU & Swiss Residents

If you are a resident of a country in the European Economic Area (“EEA”) or Switzerland (“European Resident”), you have additional rights regarding your Personal Information. You can withdraw your consent to our collection or processing of your Personal Information at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. If you have any questions or comments about the processing of your Personal Information, you may contact us at: hello@thecipolettis.com.

You have the following rights over the way we process Personal Information relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:

• for a copy of Personal Information we are processing about you and/or to have inaccuracies corrected;
• to restrict, stop processing, or to delete your Personal Information;
• for a machine-readable copy of your Personal Information, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
• to make a complaint to a data protection regulator. If you are a resident of the EEA, you can find your local regulator’s contact details here: http://ec.europa.eu/justice/data-protection/ bodies/authorities/index_en.htm.

To make a request in relation to any of the aforementioned rights, please send your requests to hello@thecipolettis.com.

International Data Transfers

We are a US Company and our servers are located in North America and the information that we collect directly from you will be stored in these servers. By submitting Personal Information to us, or to a third-party via the Website or our services, you acknowledge that you will be voluntarily transferring your data to the United States, a jurisdiction which may not provide the same privacy framework as other regions. We take steps to ensure that the data we collect under this Privacy Policy is stored and processed in accordance with this Privacy Policy regardless of where the data is located.

There are agreements in place to ensure that Personal Information is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses. We use the European Commission’s standard contractual clauses where appropriate when exporting data to a processor outside of the EU.

If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at hello@thecipolettis.com.

To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/ law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data- third-countries_en

Retention Periods or Criteria

We will hold your Personal Information for as long as is necessary for the relevant purpose for which that Personal Information was obtained unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you would like us to stop using or holding your Personal Information and/or would like to request its deletion, please email us at hello@thecipolettis.com.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' Personal Information, we may post a pop-up link on our Website requiring click-through consent. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: hello@thecipolettis.com