Notice of Right to Opt-Out

If you are a California resident, you have the right to opt-out of the sale (as defined under the CCPA) of your personal information to third parties. We and our technology providers use cookies and related technologies to that may be considered a “sale” under the CCPA. If you would like to opt-out of the “sale” of your personal information, you have several options. You may email us at privacy@vazluxe.com. You will not be required to create an account in order to opt-out.

We will then send a message to that address. You must reply from that email address to complete the process. This extra step is to authenticate you and prevent fraud and abuse. If you want multiple email addresses opted-out, you must provide each address to us. This is because we have no reasonable way to use a single address you give us to link to other addresses you may have.

Opting out is not unsubscribe. Opting out of the “sale” of personal information will not prevent you from receiving marketing messages from us. If you wish to unsubscribe from our emails, please follow the unsubscribe link in one of our emails. If you wish to unsubscribe from text messages, please follow the unsubscribe process for the program you opted into.

For more information about how users with disabilities can access this California Notice in an alternative format, please click on the “Accessibility” link in the footer below.

CALIFORNIA PRIVACY NOTICE

Last Updated: June 2022

This California Privacy Notice (“California Notice”) supplements the Privacy Notice and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). LUXURYMRKT, LLC, adopted this California Notice to comply with California privacy laws, including the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA and not defined here have the same meaning when used in this California Notice.

I. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We collect 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 (“Personal Information”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.

Categories of Personal Information

Within the last twelve (12) months, we have collected the following categories of Personal Information:

1. Identifiers, such as name, email address, social media account handle, phone number, account name, birthday (month and year only), IP address, device identifiers, or other similar identifiers.

2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), including signature, billing address, shipping address, credit and/or debit card number and expiration date.

3. Characteristics of protected classifications, such as age and gender.

4. Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, including transaction history and order number.

5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding how our users use, interact with, and navigate the Services (such as website activity, clickstream information, browser information, reference site domain name).

6. Geolocation data, such as through the use of tracking technologies, or when you use our store locator.

7. Audio, electronic, visual, thermal, olfactory, or similar information, such as photos and/or videos you share when leaving a review, photos of products with issues you provide to customer service. If you participate in our market research surveys or studies, we may ask to record or monitor interviews conducted online, by phone, or in-person.

8. Professional or employment-related information (such as in resumes you provide).

9. Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, or behavior (such as purchasing preferences).

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

Use of Personal Information

We collect and process your Personal Information for the following business and commercial purposes:

• Providing, predicting, or performing, including creating, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, and processing payments.

• Marketing our products and services to you, including sending you messages about the products and services we offer, which may include contests, rewards, sweepstakes, loyalty programs, events, and special offers for products and services. These communications may be tailored based on the communications preferences you select when providing us with your information or your activity on the Services, such as an abandoned cart, and will only occur with your prior consent, if such consent is required in accordance with applicable laws.

• Promoting, advertising, and personalizing your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, purchasing history and browsing behavior.

• Conducting or administering surveys and studies for market research purposes, including contacting you about responding to or participating in our surveys or studies.

• Communicating with you by email mail, text message (SMS, MMS), telephone, push notification, and other methods of communication, about products, services, new website features, order status, market research opportunities, and information tailored to your requests, comments, suggestions or inquiries.

• Facilitating your engagement with the Services, including to enable you to post comments and reviews, to engage with other customers, and to post on social media.

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

• Debugging to identify and repair errors that impair existing intended functionality.

• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

• Undertaking internal research for technological development and demonstration.

• Undertaking activities to verify or maintain the quality or safety of the services or devices owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the services or devices owned, manufactured, manufactured for, or controlled by us.

• Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.

• As necessary or appropriate to protect the rights, property, health and safety of our users, store visitors, us, and other third parties.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.

Sources of Personal Information

We collect Personal Information from the following categories of sources:

• Directly from you. When you provide it to us directly whether online, by email, phone, or in-person, for example, when you create an account, sign-up to receive emails from us, contact us, or participate in our market research surveys or studies;

• Automatically or indirectly from you. For example, through analytics tools, cookies, pixel tags (such as Google Analytics), or through your interactions with us on social media websites.

• Operating Systems and Platforms. For example, we automatically collect information relating to the device used to access our Services, such as IP address, device identifiers, and browser information.

• Advertising Networks. For example, ad networks (such as Google and Facebook) to serve advertisements across the Internet. These advertisers use cookies, pixel tags, and other tracking technologies to collect information about your online activity and provide online behavioral advertising.

• Social Networks. For example, from the OAuth account (such as Google and Facebook) used to create your account; and from social media networks (such as Facebook and Instagram), including if you contact us for customer service support through our social media pages.

• Data Analytics Providers. For example, through technology and analytics providers (such as Smarter HQ and Action IQ). These providers use cookies, pixel tags, and other tracking technologies to collect information about your online activity to allow us to personalize your online experience, including sending you messages about the products and services we offer.

Sharing of Personal Information

Within the last twelve (12) months, we have shared the following categories of Personal Information for a business purpose with the following categories of third parties:

• Category 1: Advertising Networks, Social Networks, and Data Analytics Providers

• Category 3: Advertising Networks, Social Networks, and Data Analytics Providers

• Category 4: Advertising Networks, Social Networks, and Data Analytics Providers

• Category 5: Advertising Networks, Social Networks, and Data Analytics Providers

Finally, we may also share Personal Information with government agencies or regulators when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, health, or safety, and/or that of our users, visitors and others.

II. YOUR CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to privacy@vazluxe.com, and are free of charge. However, we do not disclose personal information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

The CCPA provides California residents with the following rights:

1. Right to Know: You have the right to request that we disclose certain information to you about the Personal Information we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:

• The categories of Personal Information collected about you;

• The categories of sources from which we collected your Personal Information;

• The categories of Personal Information that we have sold or disclosed about you for a business purpose;

• The categories of third parties to whom your Personal Information was sold or disclosed for a business purpose;

• Our business or commercial purpose for collecting or selling your Personal Information; and

• The specific pieces of Personal Information we have collected about you.

2. Data Portability: You have the right to request a copy of Personal Information we have collected and maintained about you in the past 12 months.

3. Right to Deletion: You have the right to request that we delete the Personal Information we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

• Debug to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

• Comply with a legal obligation.

• Otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

4. Right to Opt-In to Financial Incentives: You have the right to opt-in to financial incentives. You also have the right to opt-out at any time. Please see the “Notice of Financial Incentive(s)” section below for more information about the financial incentive(s) we offer.

5. Right to Opt-Out/In: You have the right to opt-out of the sale of your Personal Information. You also have the right to opt-in to the sale of Personal Information. Please see the “Notice of Right to Opt-Out” section below for more information about your opt-out/in rights.

6. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

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

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Some of our products and services, however, may require your Personal Information. If you choose not to provide your Personal Information that is necessary to provide any aspect of our products or services, you may not be able to use those products or services. In addition, as described in the section captioned “Your Choices” in the Privacy Notice, it is possible to change your browser settings to block the automatic collection of certain information.

III. SUBMITTING A VERIFIED CONSUMER REQUEST

To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by:

• Emailing us at privacy@luxurymrkt.com

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We will need to verify your identity with at least two (2) pieces of information, such as name and email address.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require an email be sent to privacy@vazluxe.com, along with all of the below items:

• To verify your authorization to request on behalf of a California resident, provide one or more of the following: (1) California Secretary of State authorization, (2) written permission from the California resident, or (3) power of attorney.

• Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.

• To verify the identity of the California resident for whom the request is being made, provide the information set forth above for verification of the consumer request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

We will acknowledge receipt of the request within ten (10) business days of its receipt. We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

IV. SALE OF PERSONAL INFORMATION

We do not sell your Personal Information to third parties for money. However, the CCPA defines “sale” broadly, and that definition could include information that we have shared with certain technology providers that provide certain services to us, including delivering advertisements that we believe may be of interest to you. In the past twelve (12) months, we have sold the following categories of Personal Information to the following categories of third parties:

• Category 1: Advertising Networks, Social Networks, and Data Analytics Providers

• Category 3: Advertising Networks, Social Networks, and Data Analytics Providers

• Category 4: Advertising Networks, Social Networks, and Data Analytics Providers

• Category 5: Advertising Networks, Social Networks, and Data Analytics Providers

We “sell” (as defined under the CCPA) your Personal Information for the following business or commercial purposes:

• Marketing our products and services to you, including sending you messages about the products and services we offer, which may include contests, rewards, sweepstakes, loyalty programs, events, and special offers for products and services.

• Promoting, advertising, and personalizing your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, purchasing history and browsing behavior.

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors and verifying positioning and quality of ad impressions.

We do not and will not knowingly sell the Personal Information of minors under the age of 16 without affirmative authorization.

Notice of Right to Opt-Out

Please see our “Notice of Right to Opt-Out” on our “Do Not Sell My Personal Information” page for more information about your opt-out/in rights.

Do Not Track

We use analytics systems and providers and participate in ad networks that process Personal Information about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

Note, however, that you may find information about how to opt out of and/or block or reject certain tracking technologies in our Cookies Notice.

V. NOTICE OF FINANCIAL INCENTIVE(S)

From time to time, we may offer a financial incentive and/or price or service difference to our customers related to the collection of Personal Information. This Notice of Financial Incentive(s) explains the financial incentives or price or service differences that we may offer, so that you can make an informed decision on whether you would like to participate.

Promotional Messages

Users who sign up for our emails or text messages may receive a discount code on their next purchase. You can opt-in to receive this code by providing your email address and/or phone number. You have the right to withdraw your consent to participate at any time and can do so by clicking on the “Unsubscribe” link at the bottom of our marketing communications, or by texting “STOP” to our text messages. Please see our Terms & Conditions for additional information and terms that apply to our text message program.

Generally, we do not assign monetary or other value to Personal Information. However, in the event we are required by law to assign such value in the context of financial incentives or price or service differences that we offer, we have valued the Personal Information collected and used as being equal to the value of the discount code or financial incentive offered, and the calculation of the value is based upon a reasonable and good-faith estimate often involving the consideration of (i) the categories of Personal Information collected (e.g., email address and phone number), (ii) the value of the discount offered, and (iii) the value of the total purchase (excluding taxes and fees). The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

Market Research

From time to time, we may conduct or administer surveys and studies for market research purposes, and we may offer a financial incentive, such as a gift card, for responding to and participating in our surveys and studies. You always have the option to participate, and you can opt-out and stop participating at any time by and can do so by clicking on the “Unsubscribe” link at the bottom of our marketing communications. We may ask respondents for certain demographic information (e.g., age, gender), as well as information about shopping preferences and behavior.

Generally, we do not assign monetary or other value to Personal Information. However, in the event we are required by law to assign such value in the context of financial incentives or price or service differences that we offer, we have valued the Personal Information collected and used as being reasonably related to the value of the financial incentive offered, and the calculation of the value is based upon a reasonable and good-faith estimate often involving the consideration of (i) the categories of Personal Information collected (e.g., age, gender, shopping preferences and behavior), (ii) the value of the incentive offered, and (iii) the budget and expenses related to the market research project. The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

VI. MODIFICATIONS AND UPDATES TO THIS CALIFORNIA NOTICE

This California Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this California Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised California Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this California Notice, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised California Notice will constitute your acknowledgement of the amended California Notice.

VII. ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this California Notice and/or how we process Personal Information, please contact us at: privacy@vazluxe.com