Privacy Policy

Privacy Policy

Effective Date: January 19, 2021

Kawell USA Inc. and affiliated companies doing business under the KAWELL brands ("Kawell," "we," "our," or "us") cares about how information about you is used and shared, and we appreciate your trust that we will safeguard and use your information responsibly. This Privacy Policy lets you know what information we collect, how we may share that information, and your choices regarding the sharing of your information.

You are subject to our Terms & Conditions, which govern your access to and use of the Kawell Websites. Click Terms & Conditions for more information.

Privacy Policy Table of Contents
How to Contact Us
Our Privacy Commitment
Acceptance of and Changes to this Privacy Statement Children’s and Minor’s Privacy

Information Collection and Use
Cookies & Clickstream Technology, Including Opting Out Security of Your Personal Information
Disclosure of Personal Information
Updating Your Personal Information
E-mail & Account Registration
California Privacy Notice

How to Contact Us

If you have questions about Kawell’s Privacy Policy, contact us by:

Phone: 888-576-5237
Email: privacy@kawellusa.com

Mail: Kawell USA, Inc., Privacy Director, 3045 S. Archibald Avenue, Ste. 104, Ontario, CA 91761

***Note: For California Consumer Privacy Act (CCPA) inquiries and submissions, please access our Privacy Portal.

Our Privacy Commitment

We value the relationship we have with our customers and prospective customers, and are committed to protecting the confidentiality, accuracy and integrity of your Personal Information, meaning information about you that is not publicly available. We understand the importance of keeping your information secure.

Acceptance of and Changes to this Privacy Statement

This Privacy Policy applies to Personal Information collected from and about existing and prospective customers, whether collected at a retail location (a "Store") or from the Kawell website and webpages, mobile site and/or app (the "Sites").

As Kawell continues to improve the services, products and the features we provide, this policy is subject to change. We reserve the right to amend this policy at any time by posting the amended policy on our site and updating the Effective Date at the top of this page.

By using the Kawell site and services, you signify your acceptance of this Privacy Statement. If you do not agree with any policy described in this Privacy Statement, your sole option is to discontinue use of the Sites. Your continued use of any portion of the site following notification or posting of such changes constitutes your acceptance of those changes. If you have questions or concerns about our specific policies, please send an e-mail to privacy@kawellusa.com.

Children’s and Minor’s Privacy

We do not knowingly collect personal information from minors under the age of 21. If you have reason to believe that a person under the age of 21 has provided Personal Information to us, please contact us as provided in the Contact Us section below with sufficient detail to enable us to delete that information from our databases.

Information Collection and Use

We collect, use and disclose your Personal Information (including individuals associated with you, all of whom are referred to as "you" in this Privacy Policy) in its normal course of business for the following purposes:

Providing you with products and services;

Fulfilling orders places on our Sites;

Determining your location so we know the closest Store to you is;

Establishing and maintaining communications with you;

Where you have requested information from us or one of our partners, assisting in the response to your request for information;

Responding to your inquiries about purchases, accounts and other services;

Marketing our, and our affiliates and partner’s or third-party’s goods and services to you;

Processing transactions through service providers;

Meeting legal, security, processing and regulatory requirements;

Protecting against fraud, suspicious or other illegal activities; and

Compiling statistics for analysis of our sites and our business.

We obtain your Personal Information from a number of possible sources:

Directly from you. For example, during account registration from forms you complete, subscriptions you purchase or comments you provide on our Sites.

Indirectly from you. For example, from observing your actions on our Sites.

From third parties. For example, third party social networking providers and advertising companies, our affiliates and service providers who provide services or information to us. For example, we get updated addresses from the National Change of Address (NCOA) service to ensure we have the correct contact information for our customers.

From publicly available sources. For example, online database searches.

Cookies & Clickstream Technology, Including Opting Out

As you navigate the Site, we may also collect information about you through the use of common information-gathering tools, such as cookies and web beacons (collectively "Website Navigational Information"). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol ("IP") address, and the actions you take on the Site (such as the web pages viewed and the links clicked).

COOKIES

Like many companies, we use cookies on our Sites. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user.

There are different kinds of cookies with different functions:

Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.

Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.

First-party cookies: the function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between Kawell USA’s servers and your computer’s operating system. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.

Third-party cookies: the function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s or device’s hard drive. These cookies are usually Persistent cookies.

We do use third-party cookies on our Sites, as well as third party provided web beacons (please see the section on Web Beacons below). These cookies are used by us and our marketing partners to better

understand your preferences and to tailor and improve your experience on the site based on our impressions of your interests.

More specifically, our Sites use Google Analytics and Adobe Site Catalyst, which are web analytic tools provided by Google, Inc. and Adobe Inc., respectively. These services use cookies to help our Sites analyze how users use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by these vendors on servers in the United States. These vendors will use this information for the purpose of evaluating your use of the Sites, compiling reports on Site activity, and providing other services relating to Site activity and internet usage for the Website. These vendors may also transfer this information to third parties where required to do so by law, or where such third parties process the information for the vendors for purposes of providing those services. These vendors will not associate your IP address with any other data held by them. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, if you do block the use of cookies, you will not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google and Adobe in the manner and for the purposes set out above.

Along with the above noted uses, we use cookies for the following purposes: :

Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as logging into your account and using a shopping cart, cannot be provided. You can set your browser to block or alert you about these cookies, but then some parts of the site will not work. These cookies do not store any personally identifiable information.

Functional Cookies: These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal or customized features. For instance, the Site needs to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. The information these cookies collect is usually anonymized. They may be set by us or by third party providers whose services we have added to our pages. They do not gather any information about you that could be used for advertising or remember where you have been on the Internet.

Performance & Analytics Cookies: These cookies collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. These cookies do not collect information that identifies a person, as all information these cookies collect is aggregated and anonymous.

Marketing & Advertising Cookies: We do not "sell" your personal information as the word "sell" is commonly understood; in other words, we are do not give your personal information to third parties in exchange for money. However, our Sites do use cookies that may be used by third parties to build a profile of your interests and show you relevant advertisements on other sites. These cookies may also be used to enable you to share pages and content that you find interesting on our Site through third party social networking and other websites. The cookies do not store directly personal information, but are based on uniquely identifying your browser and Internet device. If you do not allow these cookies, you will experience less targeted advertising and may not be able to share pages or content you find interesting through third party social networking sites.

Please Note: We embed videos or insert links to videos from YouTube on our website(s). As a result, when you visit a page with content embedded from or linked to YouTube, you may be presented with cookies from YouTube. If you opt out of advertising and marketing cookies here, YouTube may still utilize cookies for those embedded videos and links. You can control YouTube cookies by visiting https://policies.google.com/technologies/cookies.

For information on all of these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org.

OPTING OUT OF COOKIES

There are various ways for you to manage cookies and other technologies.

Browser Settings

Through your browser settings, you can disable cookies (and other tracking tools) or request to be prompted before accepting cookies from the Sites and other websites you visit. These cookies may also permit you to delete cookies you already have. Please consult your web browser’s ‘Help’ documentation or visit aboutcookies.org. for more information about how to turn cookies on and off for your browser. If you use different browsers and computers, you will need to adjust the appropriate cookie settings for each browser and computer. Certain parts of the Site may function differently and you may not be able to use some portions of our Site if you choose to disable cookies entirely.

Third-Party Extensions

There are several browser extensions that allow you to manage cookies and personalize your browsing experience. Since these extensions are made by third party providers, We do not control these features and cannot provide technical support for these products.

Targeted Advertising Cookies

You may opt out of receiving advertising cookies from companies who are members of the Network Advertising Initiative (NAI) or who subscribe to the Digital Advertising Alliance’s (DAA’s) Self-Regulatory Principles for Online Behavioral Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page to opt out directly from providers who participate in those programs.

WEB BEACONS

The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from Kawell USA. Web beacons are transparent electronic images that can recognize certain types of information on your computer, such as cookies, when you view a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our customers to provide you with information about Kawell USA and our services. We will conduct this review on an anonymous basis.

IP ADDRESSES

When you visit our Sites, We collect your Internet Protocol ("IP") addresses to track and aggregate non-Personal Information. For example, Kawell USA uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address. In addition, Kawell USA uses your IP address to get an approximate location so we

can find a store closest to you. We do this for both your convenience, as well as for legal compliance reasons.

DO-NOT-TRACK

The major internet browsers have attempted to implement the draft "Do Not Track" ("DNT") standard of the World Wide Web Consortium ("W3C") in their latest releases. As this standard has not been finalized, Kawell USA Sites are not compatible with DNT.

Security of Your Personal Information

Whether you are shopping online or in our stores, we use reasonable security measures to protect the confidentiality of personal information under our control and appropriately limit access to it. The Kawell USA Sites use Transport Layer Security (TLS) or equivalent encryption technologies to protect your personal information during data transport, including your name, address and credit card number. However, no security controls are failproof, and We cannot completely ensure or warrant the security of your personal information. We therefore urge you to always use caution when transmitting information over the Internet.

If and when you create an account, you are required to establish a password between 7 and 16 characters with at least one letter and one number. Your password may not contain your first name, last name, or any spaces. You are solely responsible for maintaining the secrecy of your password and account information. We strongly recommend that you do not share this information with others. You have the ability to purchase on our site without creating an account; however, you will need to reenter your personal information each time you use our site in order to make a purchase.

Disclosure of Personal Information

We do not disclose any Personal Information about you to others except as stated in this Privacy Policy, as otherwise permitted by law, or authorized by you. This Privacy Policy does not apply to privacy practices of third parties that we do not own or control, including but not limited to any third party websites, services, applications, online resources to which the Sites may link, embed, reference, or otherwise provide access through the Sites. We are not responsible for the privacy practices or the content of such third party sites. Please contact these third parties directly for information regarding their privacy practices.

SERVICE PROVIDERS

We use third-party service providers to enhance your consumer experience. This may include, for instance, providers who assist us with tech or customer support, operations, web or data hosting, billing, credit card processing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise help us to provide, develop, maintain and improve our services. These companies may use information about your visits to our Sites in order to help process delivery orders, provide personalized recommendations and advertisements about our goods and services on our Sites as well as when you visit other websites. Because service providers we use may be located in the United States, your Personal Information may be processed and stored inside the United States; and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws.

THIRD PARTIES

Some areas in our site may be offered to you in association with affiliated or non-affiliated third parties, such as co-promotional partners, dedicated producers of drinks, or co-sponsors of events you may want to attend. Such co-branded areas may require you to disclose Personal Information to the third party. The co-branded areas will identify the third party; however, the third party’s privacy policy will apply to how they treat your Personal Information. We recommend you review the privacy policy of these third parties. If you elect to register for events or products with these third parties you will be providing your Personal Information to both us, and the third party.

Parts of the Sites use YouTube API Services to provide access to Kawell USA’s YouTube channel. You acknowledge and agree to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms) and Google’s Privacy Policy (http://www.google.com/policies/privacy) when engaging YouTube content and services through the Sites. You may manage your YouTube API data by visiting Google’s security settings page at: https://security.google.com/settings/security/permissions.

SOCIAL MEDIA, REVIEWS, AND USER GENERATED CONTENT

Any personally identifiable information you submit on a social media website, such as Facebook or Twitter, bulletin board, blog, chat room, comment about a product, or any other public forum on our Sites, can be read, collected or used by other users of these forums, and could be used to send you unsolicited messages. We recommend that you do not provide your name, e-mail address or any other personal information in public forums on this Site. Please note that if you choose to do so, it is at your own risk and you accept full responsibility for those posts and any consequences that may arise from posting this information.

BUSINESS TRANSACTIONS

As we continue to develop our businesses, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either Kawell USA itself or substantially all of Kawell USA assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances.

OTHER LEGALLY REQUIRED DISCLOSURES

Kawell USA preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if Kawell USA has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Kawell USA, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.

In this Privacy Policy, the purposes identified above and in "Collection, Use and Disclosure of Personal Information" will be referred to as the "Identified Purposes."

Updating Your Personal Information

Kawell USA wants your personal information to be accurate and complete. We provide several different methods for you to update your personal information. To update your name, address, phone number and/or e-mail information:

Phone: 888-576-5237
Email: privacy@kawellusa.com

Mail: Kawell USA, Inc., Privacy Director, 3045 S. Archibald Avenue, Ste. 104, Ontario, CA 91761

If you send an e-mail or letter request, please be sure to include your current information and the requested changes.

E-mail & Account Registration

During registration on the Sites, we collect an e-mail address to communicate with you about your transaction. We use this e-mail address to contact you if there are any issues and to notify you about the status of your order. If you do not want this retained for future promotional e-mail inclusion, we provide you the ability to opt-out.

If a user wishes to subscribe to our e-mails, we ask for contact information such as name, preferred store and e-mail address. We may use your personal information for purposes other than sending you promotional materials. For example, we may use your information to send you administrative communications about any account you may have with us or about future changes to this Privacy Policy. If at any time you should wish to unsubscribe, please click on the "unsubscribe" link in any e-mail from us or send an e-mail to privacy@kawellusa.com.

When you register as a member of the Sites or sign up to receive our e- mail offers, we collect information that helps us identify you. The more information you provide, the better we can customize our services and your experience to suit your needs and preferences.

California Resident Privacy Notice

Effective Date: January 19, 2021

This Notice supplements Kawell USA’s Privacy Policy and should be read in conjunction with the general Privacy Policy.

This Notice applies to the collection and use of California residents’ Personal Information by Kawell USA Inc. and any of its affiliates who operate under the KAWELL brands in providing products and services to California residents (altogether referred to in this Notice as " Kawell USA", "we," or "us," or "our,"), where such use or collection may be governed by the California Consumer Privacy Act ("CCPA"), California’s "Shine the Light" Law, California Online Privacy Protection Act (CalOPPA), and other applicable California privacy regulations. This Privacy Notice describes the types of Personal Information we collect about California residents who use any Kawell USA Site or otherwise interact with us, as required by California law.

Please read this Notice carefully because it provides important information and explains your rights. Please visit this web page from time to time, as we may update our notice for changes in the law or our data practices. If you have any questions or concerns, or wish to exercise your privacy rights, we invite you to contact us by any of the methods listed at the bottom of this Notice.

Also, California residents who are job applicants for work in any of our businesses operating in the United States are subject to a different privacy policy regarding the information collected during the application process and any employment. See California Resident Job Applicant Disclosure Notice for more information.

PERSONAL INFORMATION COLLECTION

YOUR RIGHTS RELATED TO PERSONAL INFORMATION HELD BY US

OUR PROCESS FOR ACCESS OR DELETION REQUESTS OUR RESPONSE TO REQUESTS

NON-DISCRIMINATION POLICY FOR EXERCISING YOUR PRIVACY RIGHTS

NOTICE OF FINANCIAL INCENTIVE INFORMATION SECURITY CONTACT US

PERSONAL INFORMATION COLLECTION

1. PERSONAL INFORMATION COLLECTED IN THE PAST 12 MONTHS

It is routine for us to collect, process and store Personal Information about you over the course of your relationship with us. Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.

The following chart describes the categories of Personal Information we may have collected about you in the past 12 months and, for each category, where and why we collected it, and the categories of entities with which we could have shared or sold any such Personal Information.

Category of Personal Information (PI)

Sources from which PI was collected* *Category examples at bottom of Chart

Purpose of collection* *Category examples at bottom of Chart

Identifiers, such as name, alias, delivery address, delivery signature, postal address, phone number, email address, credit card information, bank information, birthday month, age or age range, wedding date, IP address, MAC address, unique personal identifier, online identifier, and other similar identifiers

You
Affiliated Companies Service Providers

Consumer data resellers and renters

Consumer Transactions

Customer Service and Relationship

Management Customer Experience

Marketing and Advertising

Merchandising Analytics

Security and Compliance

Characteristics of protected classifications under California or federal law, such as age (over 40); gender identity or gender expression; marital status; military or veteran status; or disability information

You
Affiliated Companies Service Providers

Consumer data resellers and renters

Consumer Transactions

Customer Service and Relationship Management

Customer Experience

Marketing and Advertising

Merchandising Analytics

Security and Compliance

Commercial information, such as transaction history, purchase history or tendencies, rewards or awards purchases, points and benefit utilization, returns data, product delivery data, product or service ratings, product or service reviews, and email or mail subscriber status.

You

Affiliated Companies Service Providers

Consumer Transactions

Customer Service and Relationship Management

Customer Experience

Marketing and Advertising

Merchandising Performance and Analytics

Security and Compliance

Internet or other similar network activity, such as search history and information about consumer’s interaction with an Internet website, application or advertisement

You
Affiliated Companies Service Providers

Consumer Transactions

Customer Service and Relationship Management

Customer Experience

Marketing and Advertising

Merchandising Performance and Analytics

Security and Compliance

Geolocation Information, such as presence at a retail location, billing information, product delivery information, or “Preferred Store” election on website or application.

You
Affiliated Companies Service Providers

Consumer Transactions

Customer Service and Relationship Management

Customer Experience

Marketing and Advertising

Merchandising Performance and Analytics

Security and Compliance

Inferences drawn from CCPA personal information for purposes of creating a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, and attitudes.

You
Affiliated Companies Service Providers Consumer data resellers and renters

Consumer Transactions

Customer Service and Relationship Management

Customer Experience

Marketing and Advertising

Merchandising Performance and Analytics

Security and Compliance

Here are examples of the sources from which Personal Information about you may have been collected:

  • You, such as when you visit our Sites, manually enter Personal Information into our Sites’ forms to place a delivery order or join the rewards program, or when you post on-line to a social media account.

  • Affiliated Companies and Service Providers that process information for us, such as tech or customer support, operations, web or data hosting, billing, credit card processing, accounting, security, marketing, or data management, validation, enhancement or hygiene.

  • Consumer data resellers and renters, such as entities that compile Personal Information about prospective or current Kawell USA customers for purposes of updating, verifying or deduplicating Personal Information, or prospecting new potential customers.

Here are examples of the purposes for which we collect your Personal Information:

  • Consumer Transactions, such as processing a purchase, or fulfilling an order.

  • Customer Service and Relationship Management, such as addressing a customer complaint or applying &MORE Rewards points to a transaction.

  • Customer Experience, such as improving website offerings and interface, or providing specialized promotions.

  • Marketing and Advertising, such as providing promotions that are interesting to you based on your purchasing and viewing history.

  • Merchandising, such as determining and improving product assortment based on your purchasing history.

  • Analytics, such as information about Site performance relative to your computer or device.

  • Security and Compliance, such as protecting us and you from fraud on our Sites and in our Stores, and reporting information that may be required by applicable laws that regulate our business in California and elsewhere.

    2. USE AND DISCLOSURE (“SALE”) OF PERSONAL INFORMATION

    We do not “sell” your Personal Information in exchange for money. However, the CCPA views the “sale” of Personal Information more broadly, to include any transfer to another business or third party for valuable consideration. Under this broad definition, we have shared identifiers (as defined above) with entities that compile Personal Information about prospective or current Kawell USA customers who reside in California for purposes of updating, verifying or deduplicating Personal Information, prospecting new potential customers, and improving the types of services and products we offer to you. In addition, the collection of Internet or electronic network activity information (as defined above) through cookies on our Sites for a variety of purposes, including personalized advertising and facilitating your activity on social media, may constitute a “sale” under CCPA. Please refer to our Cookie Policy to better understand your privacy options.

    3. USE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES OR COMMERCIAL PURPOSES.

    In addition to the purposes identified above, we may use or disclose Personal Information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.

  1. Auditing Interactions with Consumers. For example: monitoring traffic to our Sites, counting ad impressions, and auditing legal and regulatory compliance.

  2. Security. For example, maintaining the safety, security, and integrity of our Sites, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.

  3. Debugging/Repair. For example, identifying and repairing errors in our Sites’ functionality.

  4. Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.

  5. Performing Services. For example, creating, maintaining, customizing and securing your account with us, processing your purchases, transactions, and payments, hosting our Sites, fulfilling subscription orders, managing databases, performing analyses, billing, and marketing services such as managing promotions and contests.

  6. InternalResearchforTechDevelopment.Forexample,testing, research, analysis, and product development, including to develop and improve our Sites, products, and Services.

  7. Quality and Safety Maintenance and Verification. For example, improving, upgrading or enhancing our products, Services or Sites, and verifying the quality or safety of our Sites or Services.

  8. Other Commercial Purposes. For example, as described to you when collecting your Personal Information such as for promotions or contests, or to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred.

4. DISCLOSING PERSONAL INFORMATION TO OTHER PARTIES

In addition to the entities described in the section titled “Use and Disclosure (“Sale”) of Personal Information,” we may disclose your Personal Information to the following categories of other parties for a business purpose or commercial purpose, as those terms are defined in the CCPA:

  1. Our affiliates, employees and authorized agents

  2. Service providers for our businesses

  3. Third parties to whom you or your agents authorize us to disclose

    your Personal Information in connection with products or services

    we provide to you

  4. Government regulators or law enforcement, where required

  5. Our legal advisors and other parties when required by law or

    pursuant to legal process

  6. Toanyentityinvolvedinthepurchaseorsaleofourbusinesses

  7. In order to provide advertisements and content that are more

    relevant to you, we and our advertising and content providers may collect Personal Information when you use our Sites (such as the IP address of your device, the identifier on your mobile device, or cookies stored on your device), and may share the information we collect with third parties. Please see our Cookie Policy for more information.

YOUR RIGHTS RELATED TO PERSONAL INFORMATION HELD BY US

You have the right to:

  • request that we disclose what categories of your Personal Information we collect, use, disclose or sell;

  • request the specific pieces of personal information that we have collected about you;

  • opt out of the “sale” of their personal information; and

  • ask us to delete Personal Information we have collected about you.

    You may only make a verifiable consumer request for disclosure or deletion twice within a 12-month period.

    Also, under California’s “Shine The Light” law (California Civil Code Section 1798.83), California residents may annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. However, no information is shared with third parties for their own marketing purposes except where expressly authorized by you.

    OUR PROCESS FOR ACCESS OR DELETION REQUESTS

    In order for us to determine whether we may have information about you, we need to verify your identity, meaning that we need to confirm that you are a person about whom we have collected information. Verification of identity will require email address validation and will also involve comparing the information you submitted in your Request to the data in our system.

    The level of information necessary to process your Request will depend on the nature of your Request. If you request specific pieces of your Personal Information, we will ask you to provide us, under the penalties of perjury, with at least three pieces of Personal Information that we will compare to data in our systems. If we are unable to verify your identity to a reasonably high degree of certainty, we will not be able to process your request and will notify you to explain the basis of the denial. However, even if we cannot provide you with specific pieces of information, we will try to provide you with categories of Personal Information, where possible if the information you have provided meets a reasonable degree of certainty.

If you request categories of your Personal Information, we will ask you to provide us, under the penalties of perjury, with at least two pieces of Personal Information that we will compare to data in our systems. If we are unable to verify your identity to a reasonable degree of certainty, we will not be able to respond to the request and will notify you to explain the basis of our denial.

If you request that we delete your Personal Information, we will ask you to provide us, under the penalties of perjury, with at least two pieces of Personal Information that we will compare to data in our systems. If we are unable to verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm to you posed by unauthorized deletion, we will notify you of our inability to respond to your request and why.

You may designate an agent to submit requests on your behalf. If you do so, your agent must submit written proof of permission to act on your behalf, and will be required to submit information on your behalf to verify your identity as described above.

If you have asked to opt-out of the sale of your Personal Information ("Do Not Sell My Information"), we will act on your Request as soon as reasonably possible and notify third parties, if applicable, as required by the CCPA. We reserve the right to refuse to process an opt-out request based on a reasonable, good-faith, and documented belief that an opt-out request is fraudulent.

OUR RESPONSE TO REQUESTS

We will acknowledge receipt of your Request within 10 days of receipt of your request. We provide a substantive response to your Request as soon as possible, generally within 45 days from when we receive your

Request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your Request is going to take us longer than normal to fulfill, we will notify you.

We usually act on Requests and provide information free of charge, but we reserve our right to charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests. When this occurs, we will explain why.

NON-DISCRIMINATION POLICY FOR EXERCISING YOUR PRIVACY RIGHTS

We will not discriminate against you for exercising any of your privacy rights. In particular, we will not:

  • Deny you goods or services

  • Charge you different prices for goods or services, whether through

    denying benefits or imposing penalties

  • Provide you with a different level or quality of goods or services

  • Threaten you with any of the above

    NOTICE OF FINANCIAL INCENTIVE

    We may make various offers and financial incentives to our customers. The terms of any such offer or financial incentive will be presented to you at the time you receive our offer.

INFORMATION SECURITY

We aim to protect Personal Information by implementing and maintaining reasonable security, such as by using reasonable organizational, technological and physical safeguards appropriate to the sensitivity of the Personal Information we hold. We take commercially reasonable measures to safeguard your Personal Information, but we cannot guarantee its absolute security.

CONTACT US

If you would like to exercise your California privacy rights, you may also call us toll free at (888) 576-5237 or via privacy@kawellusa.com.

If you have questions on the processing of your Personal Information, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us at: Kawell USA, Inc., Privacy Director, 3045 S. Archibald Avenue, Ste. 104, Ontario, CA 91761.

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