PRIVACY POLICY

Last Updated: October 24, 2021

By visiting, viewing, accessing, browsing, surfing or using our website www.stacynkirill.com (“Website”) as “we,” “us,” or “our”, collects information about you when you take advantage of our online services or visit or interact with any of our websites, including www.stacynkirill.com, or our text messaging service (collectively, the “Site”). This privacy policy (the “Policy”) describes: (1) the types of information we may collect about you, and your use of the Site; (2) how we may use and share that information; and (3) the choices you may make with respect to your personal information.

BY USING THIS SITE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THE PRIVACY POLICY, PLEASE DO NOT USE THIS SITE OR PROVIDE US WITH YOUR INFORMATION.

Personal Information We Collect

You provide us with your personal information when you communicate with us through the Site, including when you:

• Purchase products on the Site;
• Create or update an account on the Site;
• Subscribe to e-mail newsletters or updates;
• Subscribe to and interact with our text messaging service (the "Messaging Service");
• Submit product reviews;
• Complete, submit, or otherwise participate in surveys or questionnaires; or
• Participate in contests, sweepstakes, and other promotions.

We collect personal information you choose to provide, which may include your name, email address, gender, date of birth, billing and shipping addresses, telephone number, messaging history and content arising out of interactions with the Messing Service, geolocation data, and/or credit card information. We may retain your responses to surveys and questionnaires that you may complete from time to time. We may also retain your personal information collected in connection with the Messaging Service as long as you participate in the Messaging Service and as otherwise provided for in this Policy. We may collect other information from you that is not specifically listed here. We may use such information in accordance with this Policy. Please do not submit information that you do not want us to have.

Information Automatically Collected. Our servers and the third party service providers may automatically record certain information about how you use the Site, such as your Internet Protocol (IP) address, device and browser type, operating system, DNS, the pages or features of the Site that you browsed and the time spent on those pages or features, the frequency with which you use the Site, the links that you click on or use, and other statistics. We collect this information in server logs and by using cookies and similar tracking technologies. See more about our use of cookies below.

Information We Get from Others. We may obtain additional information about you from third party sources, such as service providers, vendors, social media sites, and advertising agencies to provide you with more relevant information about our services.

How We May Use Your Personal Information

To Improve the Site and Communicate with You. We generally use your personal information to serve you, to improve our products, services, and other offerings, and to improve your consumer experience. For example, we use personal information to provide products and services to you, communicate with you about those products and services, and enhance your experience on the Site. Specifically, your personal information may be used to process transactions, respond to questions, maintain online accounts, send you information about products or services that may be of interest to you, analyze and monitor visitor activity on the Site, provide product recommendations and reviews, publish the results of contests, sweepstakes, or other promotions, comply with our legal obligations, and develop a knowledge base regarding users of the Site, including through data analytics.

In Combination with Other Information. In addition, we may combine your personal information with, or match your personal information to, information that we receive from other sources, including from the third party business partners. For example, we may use the third party information to confirm contact information or to better understand your interests by associating demographic information with the information you have provided.

To Send You Marketing Communications. We may use the personal information that you provide us to send you communications inviting you to participate in various programs, like surveys or focus groups. We may also send you promotional communications and other offerings to thank you for your feedback or participation in programs, or to share new product launches or sales events. You may opt out of receiving them as described in the Your Choices section below.

To Improve our Site and Services. We may use statistical information about visitors to our Site to gain a better understanding of the users of our Site, to improve our Site, and to improve our services. We reserve the right to license or sell aggregate, de-identified information about the visitors to our Site, but this information will not contain your personal information or otherwise be individually identifiable.

For Compliance, Fraud Prevention and Safety. We may use your personal information as we believe appropriate to (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our Site for illegal reasons.

How We May Share Your Personal Information

Stacy & Kirll may share your personal information with others for a number of different reasons. We may share your personal information to fulfill your requests, to provide you with information regarding products and services of ours or those of others, to comply with law, and to enforce our rights. We also may share personal information among our affiliated companies, businesses, licensees, distributors, any of our brands, and with our successors and assigns.

Examples of how we may share your personal information include:

With Service Providers, Business Partners, and Vendors: If you purchase goods through our Site, we will have to provide credit card information to our credit card processor for payment purposes. We will also have to provide your name and address to the company that ships our merchandise. Similarly, we may share personal information with designers, manufacturers, distributors, licensees, marketing and advertising partners, and parties that provide services for the Site in accordance with this Policy. We also may retain other companies and individuals to perform services on our behalf, and we may collaborate with other companies and individuals with respect to particular products or services (collectively, “Providers”). Examples of Providers include data analysis firms, credit card processing companies, customer service and support providers, email, web hosting and development companies, and fulfillment companies. Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies. Some Providers also may collect information on our behalf from our Site. These third parties may be provided with access to personal information needed to perform their functions.

To Comply with Law or to Protect Our Rights: We may disclose your personal information as required by law, when we believe disclosure is necessary to comply with a regulatory requirement, judicial proceeding, court order, or legal process served on us, or to protect the safety, rights, or property of our customers, the public.

To Members of the Corporate Family: Stacy & Kirill may disclose your personal information to our brands, subsidiaries and affiliates, and their agents and employees.

In Connection with Business Transfers: If we license, sell, or transfer a company business unit (such as a product line or one or more affiliated companies) to a third party, or enter into discussions regarding such a transaction, we may share your personal information with that party in accordance with this Policy.

Cookies and Other Tools That May Collect Information About You

In addition to personal information you may provide directly to us, Stacy & Kirill and its business partners may collect and store information about you and your use of the Site through cookies, tracking pixels, and other technologies (collectively, the “Tools”). Cookies are small text files that are stored by your browser on your computer’s hard drive or on your device.

We collect, use, and modify this information to better understand, customize, and improve your experience with the Site and other websites, services, and offerings, as well as to manage our advertising. For example, we use web analytics services that leverage these Tools to help us understand how visitors engage with and navigate our Site, e.g., how and when pages on the Site are visited and by how many visitors. We are also able to offer our visitors a more customized and relevant experience on the Site by delivering, through the use of these Tools, content and functionality based on your preferences and interests. If you have provided us with personal information, e.g., through a registration or a request for certain materials, we may associate that personal information with information gathered through the Tools. This allows us to offer increased personalization and functionality.

We may from time to time contract with third-party vendors to work on our behalf to provide ads to our customers via the Internet or to send direct mail or catalogs to customers whom we think may be interested in our products or services. In order to do so, these third parties may collect information concerning visitors to the Site using JavaScript software code and other Tools. Our vendors may then connect the information that they collect from our Site using these Tools to other sources of information, which may include your name and mailing address, for the purpose of sending you direct mail promotions.

Do Not Track Disclosures

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they do not track the user. At this time, we ignore these signals. We do not change our practices, described elsewhere in this Policy, in response to DNT browser settings or signals. In particular, even if you have turned on DNT, we and others will continue to collect information about you and your activity through the use of cookies, tracking pixels, and other Tools. For information about DNT, visit www.allaboutdnt.org.

Your Choices

Opting Out of Communications and Updating Your Preferences. To access, update or modify your personal information, choose not to receive marketing or other promotional communications from us, including direct mail or catalogues, or otherwise change your choices about how we use your personal information, please: (1) update your account details online; (2) follow the unsubscribe instructions located at the end of any marketing communication from us; (3) contact us using the contact information provided at the end of this Policy. Please be sure to include in any email or postal mail your full name, email address, postal address, and any message. Please note that such requests may take up to thirty (30) days to become effective.

Please contact us if you have any questions or concerns about your personal information or require assistance in managing your choices.

Consequences of Not Providing Personal Information. You are not required to provide all personal information identified in this Policy to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.

Security

No security program is impenetrable, and criminals have proven adept at circumventing widely adopted security safeguards, so we cannot always guarantee the security of personal information. There are inherent risks in shopping online.

Any user or third party accessing our Site or services is responsible for its own use of the Site and the services. We are not responsible for any third party’s actions or its security controls with respect to information that third parties may collect or process via the website, services, or otherwise.

Be Aware of “Phishing.” “Phishing” is a scam designed to steal your personal information. If you receive an email that looks like it is us asking you for your personal information, do not reply to it. We will not request your password, user name, credit card information, or other personal information through email.

Other Websites

The Site may contain links to websites of third parties that: (1) are not affiliated with us; (2) are outside our control; or (3) are not covered by this Policy, including without limitation sites operated by our distributors and/or licensees in foreign countries which may not guarantee the same level of protection of personal information (“Third-Party Websites”). Links provided to Third-Party Websites on the Site are provided to you only as a convenience, and the inclusion of any link does not imply reliability or endorsement by us of the content of any such Third-Party Websites. We are not responsible for the privacy practices of Third-Party Websites, which may collect and use information from you in a manner different than how we do so; accordingly, once you leave the Wolverine platform, the use of such Third-Party Websites is entirely at your own risk. For relevant information, you should review the privacy statements or policies of any Third-Party Websites before using them. Other parties may collect information about your online activities over time and across different websites when you use our Site or services.

Children

We do not intend to or knowingly collect identifiable personal information from children who are under 13 years of age. If you are a parent who believes that we have collected information about a child under age 13, please contact us using the contact information provided below with your child's name and address, and we will delete the information we have about your child from our records and provide confirmation in accordance with the Children's Online Privacy Protection Act.

Transfer of Data to Other Countries

Any information you provide to Wolverine through the use of the Site may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the country in which you reside. However, Stacy & Krill will handle your personal information in accordance with this Policy regardless of where your personal information is kept.

Notice to California Residents

The following section applies to California residents.

Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed in the “How to Contact Us” section below and specify you are making a Shine the Light request.

California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.

Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months and used it for business purposes:

• Identifiers
• Consumer Records
• Legally Protected Characteristics
• Commercial Purchasing Information
• Biometric Information
• Internet or Network Activity
• Geolocation
• Information Typically Detected by the Senses
• Employment Education
• Education Information
• Inferenced from Above Used to Profile

We use the above categories of information to perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or similar services on behalf of the business or service provider.

Additionally, we use identifiers and commercial purchasing information to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.

Sharing Your Information. We may disclose or sell some of your personal information to third parties.

We disclose the following categories of personal information covered by the CCPA for a business purpose:

• The following identifiers: name, address, zip code, email address, phone number, IP address
• The following consumer records: credit card number
• The following legally protected characteristics: gender
• Commercial purchasing information
• The following internet or network activity: website browsing history and other cookie data
• Geolocation
• Inferenced from above used to profile

We disclose some or all of the above categories of information to the following third parties and/or service providers for a business purpose: advertising networks, internet service providers, data analytics providers, and operating systems and platforms.

We sell the following categories of personal information covered by the CCPA:

• The following identifiers: IP address
• Commercial purchasing information
• Internet or network activity

We sell the above categories of information to advertising networks, data analytics providers, and social networks.

Source of Personal Information Our Privacy Policy contains more comprehensive details about the sources from which we obtain your personal information. To read this more detailed disclosure, see the section entitled “Personal Information We Collect” above. More broadly, we obtain the categories of personal information that are listed above in the following ways:

Directly from You. For example, when you:

• Make a purchase on our Site.
• Create a personalized account with us.
• Sign up to receive emails or text messages.
• Provide your contact information to us.
• Submit a request to us.
• Submit product reviews.
• Complete, submit, or otherwise participate in one of our contests, questionnaires, or surveys.
• Interact with our social media pages.

We collect the following categories of personal information directly from you: identifiers, consumer records, legally protected characteristics, commercial purchasing information, biometric information, information typically detected by the senses, employment information, and education information.

Passively. For example, when you:

• Visit and navigate our Site on any device.
• Click on sponsored links or third-party advertisements.
• Receive or interact with our communications and Site that may contain cookies.

We collect the following categories of personal information passively: identifiers, commercial purchasing information, and internet or network activity.

From Third Parties. We may receive information about you from other sources. For example, we get information from:

• Our business partners, including online advertising networks.
• Social media platforms.
• Companies that provide information to supplement what we already know about you, including data brokers.

We collect the following categories of personal information from third parties: identifiers, consumer records, legally protected characteristics, commercial purchasing information, employment information, education information, and inferenced from above used to profile.

Your Rights. The CCPA gives you certain rights regarding your personal information:

• Right to Know.You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your credit card number even if it is something we collected).
• Right to Delete.You may request that we delete certain personal information we have collected about you, with certain exceptions.
• Right to Opt Out.Opt out of the sale of your personal information to third parties.

Exercising Your Right to Opt Out. To opt out of the sale of your personal information, you must turn off third-party advertising trackers on any device used to access the Site.

Exercising Your Additional Rights. To exercise your right to know or delete, emailing us at Support@stacynkirill.com,Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name, email, and type of request you would like to make. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request.

After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request.

Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. You may also make a request on behalf of your minor child.

We will not discriminate against you if you choose to exercise your rights. However, we may offer financial incentives for the collection of your personal information (like signing up for email marketing) in the form of order discounts or a chance to win a contest or sweepstakes which may impact product pricing. If you have received an incentive, there is no obligation to allow us to continue to process your personal information or for you to remain opted in to email marketing. You may unsubscribe from email marketing at any time or exercise your other Consumer Rights as described in this section.

Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable.

We do not charge a fee to process or respond to your request unless your request 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 prior to completing your request.

Notice to Nevada Residents

Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. We do not sell your personal information for monetary consideration; however, this right applies even if we do not sell personal information for monetary consideration.  If you are a Nevada consumer and wish to exercise this right, please emailing us at Support@stacynkirill.com

Data Transfers, Storage, and Processing Globally

When we share your personal data with our partners, myspotifyplaque-affiliated companies, and service providers, your personal data may be transferred to and/or made accessible from countries out of the European Economic Area. In such circumstances, we will enter into model contractual clauses as adopted by the European Commission, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our partners or service providers have adopted such internal policies approved by European data protection authorities.

Legal Basis For The Processing of Personal Data from EEA Residents

It may be necessary—by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence—for us to disclose personal data. We may also disclose personal data if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

If you reside within the European Economic Area (EEA), our processing of your personal data will be legitimized as follows: Whenever we require your consent for the processing of your personal data such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 ("GDPR"). If the processing of your personal data is necessary for the performance of a contract between you and us or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your data on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).

How to Contact Us

If you have questions or concerns about our privacy policy or practices, please contact us at:

Email: Support@stacynkirill.com