PRIVACY POLICY

This Privacy Policy describes the types of information CIPRIANI TRADE, INC. (“Cipriani”, “our”, “we” or “us”) collects from and about you when you visit our website (the “Website”) and explains how we may collect, use, disclose and/or store your personal data, as follows:

1. Collection of Information; Cookies. We may collect personal information including your name, address, email address, telephone or mobile number, user name and password, geolocation information, and if you make a purchase on the Website, your payment information, as well as non-personal information about your use of the Website.

2. Use of the Information Collected. We may use the information we collect from and about you for several purposes including selling you goods, providing you with newsletters and/or offers, advertising through email, postal mail, text message, and/or contacting you.

3. Sharing of Information Collected. We may share the information we collect from and about you with third parties such as third-party service providers, law enforcement agencies and/or government to the extent required.

4. Retention of Information Collected. Your personal data will not be kept for longer than it is necessary to fulfil the specific purposes outlined in this Privacy Policy and/or to otherwise allow us to comply with legal requirements.

COLLECTION OF INFORMATION; COOKIES

CIPRIANI collects information from you when you use or visit the Website, create an account on the Website, purchase goods on the Website, request information from us, sign up for newsletters or other online services, complete online forms, participate in contests or surveys, or otherwise contact us. The information we collect from you may include your name, address, zip code, e-mail address, mobile number, user name(s) and password(s), geolocation information and other personal information. If you purchase goods through the Website, we may collect additional information such as credit/debit card numbers, billing address, banking information, and other information typically used to process payments. If you purchase a gift card for someone else, we may also collect personal information about others.

When you use or visit the Website, we may use cookies, pixel tags, web beacons, log files or other technologies to automatically collect information from you or about you including, without limitation, your browser type, operating system, software version, IP address, information about your smartphone and/or mobile carrier, date and time you access the Website, which pages you visit, the amount of time you spend on the Website, the number of times you return, and other usage data.

We may gather information about you from other sources, including, without limitation, social network platforms (e.g., Facebook, Instagram, etc.) that you may use to connect to the Website. We may use this information together with the information we collect from and/or about you to provide you with offers, notifications or other communications that may be of interest to you.

The Website uses cookies (i.e., data files placed on a computer, tablet or other electronic device used to visit the Website) to, among other things, gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are information and/or data that a website sends to your computer’s hard drive while you are viewing a website. We might use both session cookies (these cookies are temporary and expire once you close your browser) and/or persistent cookies, which remain on your hard drive until you erase them. You have the option to set your browser or operating system to limit tracking or to decline cookies, however, this may limit certain features of the Website and make your use of the Website less effective. For example, if you block our cookies, you may not be able to add items to your cart or checkout. That being said, the “help” feature on most browsers explains how to prevent your browser from accepting new cookies, how to set the browser to notify you when you receive a new cookie, or how to disable cookies altogether. You can disable or delete similar data used by browser add-ons by changing the add-on’s settings.

USE OF THE INFORMATION COLLECTED

Information we collect from you and/or about you may be used for a variety of purposes, including, without limitation, the following:

To notify or otherwise contact you;

For data usage analysis purposes or statistical purposes;

To create targeted offers for you;

To respond to your questions or requests;

To process orders and payments

To prevent online fraud or other fraudulent activity

To develop offers, new products or services or to promote existing products; and/or

For advertising purpose.

SHARING OF INFORMATION COLLECTED

CIPRIANI is not in the business of selling personal information. However, there are certain instances in which the information collected from you or about you may be shared with third parties. For example, we may share information collected from you and/or about you with our affiliates for marketing or analytical purposes. We may also hire other companies and individuals to perform services on our behalf, such as, for example, express couriers and online payment service providers, and/or we may send offers to our customers on behalf of other businesses.

We may release personal information to law enforcement, governmental agencies or authorized thirty parties when we believe release is appropriate or required to comply with applicable laws, orders and/or regulations, enforce our Terms of Use and other agreements, or protect the rights, property, or safety of others. This includes providing and/or exchanging information with law enforcement, governmental authority and/or other companies and organizations for law enforcement purposes, fraud protection etc.

Except as described above, you will receive notice when information about you might is provided to third parties, and you will have the right to choose not to share the information.

RETENTION OF INFORMATION COLLECTED

Your personal data will not be kept for longer than necessary to fulfill the specific purposes outlined in this Privacy Policy and/or to allow us to comply with our legal requirements.

SPECIFIC LOCATION PRACTICES

California

Residents of the State of California can request a list of all third parties to which CIPRIANI has disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at privacy@cipriani.com. For all requests, please ensure you put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response.

Please note that we will not accept requests via the telephone, mail or by fax, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

EUROPEAN ECONOMIC AREA (EEA)

If you use the Website from the EEA, you have certain rights regarding your personal information, subject to local laws. These include, without limitation, the following rights: (i) the right to access to customer personal information, (ii) the right to rectify information we hold about our customers, (iii) the right to erase customer personal information, (iv) the right to restrict our use of customer personal information, (v) the right to object to our use of customer personal information, (vi) the right to receive customer personal information in a usable electronic format and transmit it to a third party (right to data portability), and (vii) the right to lodge a complaint with the local data protection authority.

Additionally, please review the section entitled “CUSTOMER DATA PROTECTION RIGHTS” and review the protections afforded to CIPRIANI customers who are covered under the General Data Protection Regulation (GDPR).

THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website may link. The inclusion of a link on the Website does not imply vetting and/or endorsement of the linked site. Specifically, we assume no responsibility for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, etc. or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal information you disclose to other organizations.

THIRD-PARTY ADVERTISING

The Website may use third-party advertising companies to post ads regarding goods and services that may be of interest to you or to customers in general. You may see such ads when you access and/or use our Website. Such third-party advertising companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.

PROTECTING YOUR INFORMATION

We use our commercially reasonable efforts to protect the Website or your personal information within. However, we cannot guarantee that your data will not be compromised. If you have reason to believe that your data has been compromised, please immediately notify us at: privacy@cipriani.com. Likewise, it is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer and do not provide your credit card information unless you are connected to the Website using a secured connection.

CUSTOMER DATA PROTECTION RIGHTS

Under certain circumstances, you have:

The Right to be Informed: You have the right to know how we collect your data and how we are going to use your data (a/k/a, privacy information). We achieve

this through this Privacy Policy.

The Right to Access: You have the right to receive a copy of your data and to verify that we are lawfully processing it.

The Right of Correction: You have the right to ask us to correct any incomplete or inaccurate information we hold about you.

The Right to Erasure: You have the right to ask us to delete or remove your data where there is no compelling reason for us to keep it.

The Right to Restrict Processing: You have the right to request that we restrict processing of your personal data, under certain conditions.

The Right to Data Portability: You have the right to request us to transfer your personal information to another company.

The Right to Object to Processing: You have the right to challenge certain types of processing.

Rights in Relation to Automated Decision Making and Profiling: You have the right to be informed if we are carrying solely automated-decision making, including

profiling with legal or significant effects.

HOW TO CHANGE YOUR PERSONAL INFORMATION

If you would like update or delete your personal information, please write to: privacy@cipriani.com. When writing to us, please clearly identify what information you would like to update or delete. When processing your request, we may ask you questions to verify your identity. Please note that we are required to retain certain information for recordkeeping purposes and/or to complete any order placed prior to your request. There may also be residual information that will remain within our databases and other records, which will not be removed.

SENSITIVE PERSONAL INFORMATION

Do NOT provide us with any sensitive personal information such as your social security number, banking information (other than your credit or debit card number), medical records, biometrics or genetic characteristics, or criminal background. We would NOT be asking this information in connection with the services offered through the Website.

MINORS

If you are under 18, you may use the Website only with the involvement and supervision of a parent or guardian. We do not knowingly collect personal information from

children under the age of 13 without the consent of the child’s parent or guardian.

USER’S ACCEPTANCE OF OUR PRIVACY POLICY; CHANGES TO OUR PRIVACY POLICY

By visiting and/or using the Website, you automatically signify your acceptance to our Terms of Use, including our Privacy Policy. If you do not agree with our Terms of Use and/or Privacy Policy, please refrain from visiting and/or using the Website.

We reserve the right, in our sole discretion, to update this Privacy Policy, change, modify, add and/or remove portions from this Privacy Policy at any time. Your continued use of the Website following the posting of changes to our Terms of Use and/or Privacy Policy signify your acceptance of such changes.

CONTACT US

If you have any questions, feedback, or concerns about this Privacy Policy, please contact us privacy@cipriani.com.