Privacy Policy

 

Effective Date: January 1, 2023

1. OVERVIEW

This privacy policy (this “Policy”) applies to ALC & Co., LLC (“we,” “us,” or “our”), including the www.alcltd.com website and any related website or mobile application.  We strive to deliver outstanding products and services and value our customers’ business and loyalty. We recognize that privacy is an important issue. We have developed this Policy to explain our practices regarding the personal information we collect from you or about you when you purchase products from us, through written or verbal communications with us, when you use this website or mobile applications. While this Policy broadly describes the practices we have adopted the United States, local laws vary, and some jurisdictions may place restrictions on our collection, use, or disclosure of personal information. Our actual practices in such jurisdictions may be more limited than those described in this Policy to comply with local requirements. If you are a resident of California, please see Appendix A for information regarding your rights under California law.  If you are a resident of Nevada, please see Appendix B for information regarding your rights under Nevada law.  If you are a resident of Canada, please see Appendix C for information regarding your rights under applicable law.  If you are a resident of the European Economic Area, the United Kingdom or Switzerland, please see Appendix D for information regarding your rights under applicable law.

By accessing or using our website(s), mobile application(s) (“apps”), or submitting information to us, or otherwise agreeing to this Policy, e.g., in the context of registering for or purchasing any of our products or services, you understand and consent to our collection and use of your personal information as described herein.

2. PERSONAL INFORMATION WE COLLECT AND USE

Personal information is information that identifies, relates to or describes you or can reasonably be  associated with or  linked to you.  We collect personal information directly from you through our websites and apps and in our contact with you at our stores.  We may also collect information related to conversations, including records or copies of your correspondence with us or customer service calls for quality assurance and training purposes, and other communications such as website chat support, in-app messages, or SMS.

We collect and use personal information in certain common cases, including:

2.1 Establishing and Maintaining an Account

When you establish an account, we will collect personal information, including first name, last name and e-mail address, shipping address, billing address, telephone number, credit card name, credit card number, expiration date and security code, purchase history.  We collect this information for the purpose of facilitating the sale and delivery of our goods to you.  The personal information described in this paragraph is the “Account Data.”

2.2 Purchase of Goods

In connection with your purchase of goods from us at our stores or through our website or app, we collect personal information.  The information we collect in these cases may include first name, last name; shipping address, city, county, state, zip code; billing address, city, county, state, zip code; telephone number; e-mail address; gender; age; account name, account password; goods purchased; customer comments; date of purchase; a copy of your original invoice; invoice number; credit card number, expiration date and security code. We use this information to facilitate the purchase transaction.  The personal information described in this paragraph is the “Purchase Data.”

2.3 Customer Service

We provide customer service at our stores, by telephone and through our website.  In providing customer service we may collect personal information from you such as name, address, e-mail address, telephone, product purchases, product sales, and other information related to your service request.  We use this information in order to investigate, resolve and respond to your customer service issue.  The personal information described in this paragraph is the “Customer Service Data.”

2.4 Newsletter

If you subscribe to our newsletter we collect personal information including first name, last name; e-mail address; phone number; account name and password.  We use this information to provide our newsletter and other information about our goods and services to you and to help us understand the demographics of our customers.  The personal information described in this paragraph is “Newsletter Data.

2.5 Social Media

If you choose to participate in one of our sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, and friends list. We may also allow you to enter into contests to provide photos, such as of products you have purchased, which you may share with your connections on social media for votes, shared offers or other promotions.  We use this information for providing information about our goods and services and for understanding the needs and preferences of our customers.  The personal information described in this paragraph is the “Social Data.”

2.6 Contests and Sweepstakes

We may run contests or sweepstakes in which you may choose to participate. The personal information we collect may include first name, last name, e-mail address, telephone number, address, date of birth and other individual responses as indicated at the time of collection. Prize winners may be required to provide a social security number for tax reporting purposes.  We use this information to facilitate the contest or sweepstakes.  The personal information described in this paragraph is the “Contest Data.”

2.7 Customer Surveys

We may collect personal information at various events or online through surveys in which you may choose to participate. The information we collect may include age; date collected; purchase history, habits, and preferences; email; first name; last name; and other individual survey responses as indicated at the time of collection.  We use this information to understand the needs and preferences of our customers so that we can improve our goods and services.  The personal information described in this paragraph is the “Survey Data.”

2.8 Security

Our stores use security cameras to monitor the activity of our customers and staff.  The information we collect includes video recordings.  Audio is not recorded.  The camera images are not monitored in real time.  The recordings are viewed only if there is reason to believe that there has been a breach of security.  We use this information to detect security incidents and to report to law enforcement agencies.  The personal information described in this paragraph is the “Security Data.”

2.9 Automatically Collected Personal Information

By its nature, our websites and apps also automatically collect some personal information about you. In order for you to view or interact with our website or apps, we receive individual identifiers like your IP address, and some network information like the date and time that pages are visited. We may collect this personal information even if you are not logged in.  We collect some personal information automatically using cookies or other tracking technologies as described below in Section 7. The personal information automatically collected may be collected by or on behalf of third parties who may provide us with inferences or aggregate reporting based on analysis of such personal information.   We use this information to understand how our customers are using our websites and apps.  The personal information described in this paragraph is the “Use Data.”

2.10 Employees

We collect personal information in the context of your role as an applicant to, an employee of, director of, or officer of, our business. The personal information we collect in these cases may include name, social security number, address, date of birth, gender, race, ethnicity, bank account and routing number, tax filing status, emergency contact information, telephone number, family member names, educational background, criminal background and employment history, medical provider information, dependent name(s), date of birth, gender and address, medical insurance provider, compensation and benefits data, workplace, and title. We only use this information for purposes of evaluating qualifications related to your job application or your job duties; evaluating your performance; or for providing compensation, benefits and services in the context of the employment relationship. The personal information described in this paragraph is the “Employee Data.”

2.11 Individuals Representing Businesses

We collect personal information in the context of your role as a representative of a business.  The personal information we collect in these cases may include name, address, email address, telephone, date of birth, gender, social security number and personal financial information.  We use this information for communicating with you in your role as a representative of a business or if you are an owner of a business to evaluate your creditworthiness.  The personal information described in this paragraph is the “Biz Rep Data

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from other information we collect.

3. SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION

We may collect personal information about you from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to your use of our websites or apps or interaction with us at our stores. For example, we may collect personal information from publicly accessible sources (e.g., property records); directly from a third party, (e.g., credit reporting agencies or customer due diligence providers); or from a third party with your consent (e.g., your bank). We may merge or co-mingle that personal information with the personal information we maintain about you and other data collected on or through our website.  Categories of sources from which we may collect personal information include: advertising networks; internet service providers; data analytics providers; government entities; operating systems and platforms; and social networks

4. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

In addition to the purposes set forth in Section 2 above, we may collect your personal information for the following purposes:

4.1 Auditing

Auditing related to a current interaction with you, 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;

4.2 Security

Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;

4.3 Debugging

Debugging to identify and repair errors that impair existing intended functionality;

4.4 Transient Use

Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with us provided that your personal information is not disclosed to a third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;

4.5 Services

Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage or providing similar services on our behalf;

4.6 Advertising

Providing advertising and marketing services to you.

4.7 Research

Research.  Undertaking internal research for technological development and demonstration; and

4.8 Quality and Safety

Undertaking activities to verify or maintain the quality or safety of our products and services and to improve, upgrade, or enhance our products and services.

4.9 Commercial Interests

Advancing our commercial or economic interests, such as by inducing a person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

5. LIMITED USE OF PERSONAL INFORMATION

We will only use your personal information for the purposes for which we have collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.

If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.

6. OUR DISCLOSURE OF PERSONAL INFORMATION

In order to provide you with the best products and services, we disclose your personal information to our affiliates, service providers, contractors and other third parties as described below.

6.1 Affiliates

We may disclose your personal information to our parent company and entities under shared corporate control (“Affiliates”) for the purposes described in Sections 2 and 4 above.

6.2 Contractors

We disclose personal information to entities that help us fulfill a business or commercial purpose including, but not limited to, shipping companies that deliver our products to you (“Contractors”).  Contractors are not permitted to sell or share your personal information or to use your personal information other than to perform the tasks we assign to them.

6.3 Service Providers

We disclose your personal information to companies that process personal information on our behalf for a business or commercial purpose, including, but not limited to,  website hosting, app design, database management, web analytics, app analytics, billing, payment processing, and communicating with you about our products or services (“Service Providers”).  Service Providers are not permitted to sell or share your personal information or to use your personal information other than to perform the tasks we assign to them.

6.4 Third Parties

In addition to third parties in the foregoing categories, we may disclose personal information to the following categories of third parties: advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks and data brokers.  For the purposes of this Policy, “third party” or “third parties” are entities that may sell, retain, use, or disclose personal information for purposes beyond providing services directly to us for our business  or commercial purposes. We disclose personal information to advertising networks so they may help us deliver advertisements to you based on your activity on our website or apps or your activity on other websites or apps.

6.5 Compliance with Laws

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your personal information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary to comply with any legal obligation, enforce or apply our terms and conditions, respond to claims and legal process, protect our services, members, dealers, our rights and/or the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).  As purchasers of secondhand goods, we are required in some jurisdictions to report to local or state law enforcement agencies personal information about those from whom we purchase such goods.

6.6 Sale or Transfer of Business or Assets

We may disclose some or all of your personal information in connection with a merger, bankruptcy, or other transaction in which another entity assumes control of all or part of our business.  If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.

7. COOKIES AND OTHER TRACKING TECHNOLOGIES

Third parties, including Google and Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting using the options described in the Opting Out section below. The tracking technologies we utilize include the following:

7.1 Cookies

We may use different types of cookies when providing different types of web-related services. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable important service features. We use both session ID cookies and persistent cookies. Session ID cookies are used to maintain your browser state as you browse through services, and they expire when you close your browser. A persistent Cookie remains on your hard drive for an extended period, and we use that to identify you should you return to services and want to find information you had previously entered or accessed.

We may also contract with analytics services, third-party affiliate services, and third-party advertising companies to collect similar information. These cookies allow the ad servers to recognize your computer each time they send you an online advertisement, and compile information about you or others who use your computer. This information allows such advertising networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

You may disable cookies through your web browser. For information about opting out of these collection services, please see the Your Choices section below.

7.2 Web Beacons/Tags

We may automatically collect aggregate anonymous information through files embedded in our services and emails known as “web beacons.” We may deliver a web beacon to you through our services from an advertising network with which we have contracted. Web beacons allow third parties to provide anonymized and aggregated auditing, research, and reporting for us. Web beacons also allow us to tell whether email recipients are able to properly view messages or if email messages have been opened, to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by web beacons to personal information.

7.3 Flash LSOs

When we post videos, third parties may use local shared objects, known as “Flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash cookies are different from browser cookies because of the amount and type of data and how the data is stored. The cookie management tools provided by many popular browsers will not remove Flash cookies. To learn how to manage Flash cookie privacy and storage settings, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

7.4 Analytics

We may use analytics tools or similar tools provided by third parties (“Data Analytics Providers”) to help analyze how you and other users utilize our services. Analytics tools use cookies and other tracking technologies to collect information such as how often users visit our website, what pages they visit, and what other websites they have used prior to visiting our website. We use the information we get from analytics tools only to improve services. Analytics tools collect the IP address or other unique identifier assigned to you on the date you visited services. We do not combine the information generated through the use of analytics tools with your other personal information. Analytics tools provided by third parties plant a persistent cookie on your web browser to identify you as a unique user the next time you visit our website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy. To learn about how Google uses data related to website analytics when you use our site or apps, click here: https://policies.google.com/technologies/partner-sites. For information about how Facebook uses cookies and other storage technologies, click here: https://www.facebook.com/policies/cookies/.

7.5 BY USING OUR WEBSITE, YOU GIVE CONSENT FOR US TO SHARE YOUR DATA WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU SERVICES.

8. OPTING OUT

You can make the following choices regarding your personal information:

8.1 Promotional and Other Emails

You may choose, during the account registration processes on one of our websites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our services. You can stop receiving these emails by sending a request to the email address in the Contact Us section below. If you decide not to receive these emails, we may still send you communications related to your current or former membership.

8.2 Behavioral Advertising

Our services may use behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our website, or on other websites not operated by us. If you do not want third parties to collect information about your use of our services, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.

PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

8.3 Analytics

Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that, typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files you may clear the opt-out cookie.

You may learn more about the use of information by and opting-out of analytics from our third-party provider by visiting its opt-out page at the following links:  www.google.com/policies/privacy/partners/ and https://tools.google.com/dlpage/gaoptout .   

8.4 Cookies

You may disable, or delete cookies in your Web browser, but doing so may impact the usability of the website. To block cookies, you can also browse our service using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari, etc.).   

9. INTERNATIONAL TRANSFERS OF INFORMATION

Your personal information may be processed in the country in which it was collected and in other countries, where laws regarding personal information may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach or other use that is prohibited in your country. By submitting your personal information, you agree to this transfer, storage and/or processing, including all associated risks.

10. INFORMATION SECURITY

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. We make efforts to protect your personal information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If you have questions about the security of your personal information, contact us at the email or regular mail address specified in the Contact section below.

11. MINORS

Our website and app and our services are not directed to minors. We actively seek to dissuade registration by and sales to persons under 18 and do not knowingly collect personally identifiable information from them. If you are under 18 years of age, you are not eligible to use our website or apps or to receive our services.

12. DATA RETENTION

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

13. THIRD-PARTY LINKS

Our websites or apps may contain links to other websites or apps. We are not responsible for the privacy practices or the content of these other websites or apps. You should read the policy statement of these other websites or apps to understand their policies. When you access linked websites or apps, you may be disclosing private information. It is your responsibility to keep such information private and confidential.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time, in our sole discretion. When we do so, we will post the new Policy on our website. You should consult this Policy regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.

15. CONTACT US

If you have questions regarding this Policy, its appendices, or our treatment of your personal information, you may contact us at:

            ALC & Co., LLC

            818 South Broadway, Fourth Floor

            Los Angeles, CA  90014

            Attention: Privacy Policy Questions

 

Email: privacy@alcltd.com with the subject “Privacy Policy Questions”

 

APPENDIX A

CALIFORNIA PRIVACY RIGHTS NOTICE

Effective Date: January 1, 2023

1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if you are a resident of California you have the following rights with respect to your personal information.

1.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information about You.

Personal information as defined in the CCPA is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, including the following categories of information: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of personal information we have collected about you; the categories of sources from which we collect personal information; our business or commercial purpose for collecting, disclosing, sharing or selling personal information; the categories of third parties to whom we disclose, share or sell personal information, if any; and the specific pieces of personal information we have collected about you.  Personal information includes “sensitive” personal as described below.

1.2 Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information about You.

“Sensitive” personal information as defined in the CCPA is personal information that reveals: (a) your social security, driver’s license, state identification card, or passport number; (b) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) your precise geolocation; (d) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of your mail, email, and text messages unless we are the intended recipient of the communication; and (f) your genetic data. “Sensitive” personal information also includes biometric information that is processed for the purpose of identifying you, information that is collected and analyzed concerning your health; or your sex life or sexual orientation.

You have the right to know the categories of “sensitive” personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting, selling or sharing “sensitive” personal information, the categories of third parties with whom we sell or share “sensitive” personal information, if any, and the specific pieces of “sensitive” personal information we have collected about you.

1.3 Right to Delete Your Personal Information

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers, contractors and third parties to delete your personal information from their records.

We are not required to, and reserve our right to not delete your personal information if it is necessary to: (i) 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 you and us; (ii) help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) 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; (v) 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; (vi) 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; (vii) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; and (viii) comply with a legal obligation.

1.4 Right to Correct Inaccurate Personal Information.

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to correct any inaccurate personal information in our records, and to have us direct our service providers, contractors and third parties to correct any inaccurate personal information from their records.

If we cannot verify your identity pursuant to the CCPA and its regulations we may deny a request to correct.  In such event, we shall inform you that your identity cannot be verified.

In determining the accuracy of the personal information that is the subject of your request to correct, we shall consider the totality of the circumstances relating to the contested personal information. We may deny your request to correct if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

1.5 Right to Be Free from Discrimination

You have the right to not be discriminated against by us because you exercise any of your rights under the CCPA. This means we cannot, on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against you as an employee, applicant for employment or independent contractor.

1.6 Right to Opt-Out of the Sharing of Personal Information

We may disclose your personal information to third parties for cross-context behavioral advertising purposes (“Share” or “Sharing”).  This means the targeting of advertising to you  based on your personal information that we obtain from your activity across businesses, distinctly-branded websites, applications, or services, other than our business, distinctly-branded website, application, or service. We may Share personal information with advertising networks so they may help us to deliver advertisements to you based on your activity on our website or apps and/or your activity on other websites or apps.

You have the right to opt-out of the Sharing of your personal information and you may exercise your right by clicking the following link: Do Not Sell or Share My Personal Information. If you exercise your right to opt-out of the Sharing of your personal information, we will refrain from Sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information.

1.7 Right to Opt-Out of the Sale of Personal Information

We may disclose your personal information to third parties in exchange for monetary or other consideration.  Such disclosures are considered to be “Sales” under the CCPA.  We may Sell personal information to advertising networks so they may help us to deliver advertisements to you based on your activity on our website or apps and/or to recommend our products and services to you based on your activity on other websites or apps.  You have the right to opt-out of the Sale of your personal information and you may exercise your right by clicking on the following link: Do Not Sell or Share My Personal Information. If you exercise your right to opt-out of the Sale of your personal information, we will refrain from Selling your personal information, unless you subsequently provide express authorization for the Sale of your personal information.

1.8 Right to Opt-Out by Using Opt-Out Preference Signals.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal information (“Opt-Out Preference Signal”).  We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of personal information for your browser or device, and, if known, for you.

If the opt-out preference signal conflicts with other privacy settings that you have submitted to us, we will process the opt-out preference signal but may notify you of the conflict and provide you with the opportunity to consent to the sale or sharing of your personal information.

If the Opt-Out Preference Signal conflicts with your participation in a financial incentive program, we may notify you of the conflict and request your affirmation that you intend to withdraw from the financial incentive program.  If you affirm your intent to withdraw we shall process the Opt-Out Preference Signal.  If you do not affirm your intent to withdraw, we will not process the Opt-Out Preference Signal.

1.9 Right to Limit the Use of “Sensitive” Personal Information

[We may use your “sensitive” personal information for purposes other than is necessary to provide our goods and perform our services as reasonably expected by you.  For example, we may share your “sensitive” personal information with advertising networks that may use such information to target advertising to you.  You have the right to limit our use of your “sensitive” personal information to that which is necessary to provide our goods and services to you by clicking on the following link: Limit the Use of My Personal Information.

1.10 Right of Children to Opt-In to the Sale of Personal Information

We do not knowingly collect or sell the personal information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their personal information, we have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, we require the consumer to affirmatively authorize the sale of the consumer’s personal information.  In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which we have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, we require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require that the consumer’s parent or guardian verify the consumer’s identity, which we have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete your request if we cannot verify your identity. If you are a parent or guardian seeking to opt-out on behalf of their child, please contact us at 909-361-3238 or email us at privacy@alcltd.com with the subject “Minor Opt-Out.”

2. HOW TO EXERCISE YOUR CCPA RIGHTS

Unless otherwise specified, to exercise any of your rights described in this Appendix A, please submit your request to us at 909-361-3238 or at privacy@alcltd.com with the subject “CCPA Consumer Request.”

In order to verify your request, we will need you to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates.  If feasible, we will match the identifying information provided by you with the personal information that we already maintain about you.

You may designate an authorized agent to make a request under the CCPA on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require that you verify your own identity with us directly.

We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf.  You may only make a request to access or receive copies of personal information twice within a 12-month period.  Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

3. OUR PERSONAL INFORMATION COLLECTION, USE AND DISCLOSURE PRACTICES

A description of the personal information that we collect online and off-line is provided in Section 2 of the main Policy.  The purposes for which we collect and use personal information are described in Sections 2 and 4 of the main Policy.  Sources from which we receive personal information are described in Section 3 of the main Policy.  Our personal information disclosure practices are described in Sections 6 and 7 of the main Policy.  Our personal information retention practices are described in Section 11 of the main Policy.

3.1 Categories of Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

Category of Personal Information

Collected

Sold or Shared in the Past 12 Months?

Categories of Third Parties to Whom Sold or Shared

Disclosed for a Business Purpose in Past 12 Months?

Categories of Third Parties to Whom Disclosed

Individual Identifiers

 

Yes

Yes

Advertising Networks; Data Analytics Providers

Yes

Contractors;

Service Providers;

Government Entities;

Affiliates

Categories Described in California Consumer Records Act, Civil Code §1798.81.5

Yes

 

Yes

Advertising Networks; Data Analytics Providers

Yes

 

Contractors;

Service Providers;

Government Entities;

Affiliates

Characteristics of protected classifications under California or federal law.

 

Yes

 

No

 

Not Applicable

 

Yes

 

Contractors;

Service Providers;

Government Entities;

Affiliates

Commercial information.

 

Yes

Yes

 

 

 

Advertising Networks; Data Analytics Providers

 

Yes

Contractors;

Service Providers;

Government Entities;

Affiliates

Biometric information.

 

Yes

 

No

Not Applicable

Yes

Contractors

Internet or other electronic network activity.

 

Yes

Yes

 

Advertising Networks; Data Analytics Providers

Yes

 

Contractors; Service Providers

 

Geolocation data (other than IP address).

 

No

No

Not Applicable

 

No

Not Applicable

 

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

 

No

 

Not Applicable

Yes

Governmental Entities;

Contractors

 

Professional or employment-related information.

Yes

No

 

 

Not Applicable

 

Yes

Contractors;

Service Providers;

Affiliates

Education information.              

 

Yes

 

No

 

Not Applicable

Yes

 

Contractors;

Service Providers; Affiliates

Inferences drawn from any of the information identified above.

None

No

 

Not Applicable

No

None

 

3.2 Categories of “Sensitive” Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

 

Category of Sensitive Personal Information

Collected

Shared or Sold in the Past 12 Months?

Categories of Third Parties to Whom Shared or Sold

Disclosed for a Business Purpose in Past 12 Months?

Categories of Third Parties to Whom Disclosed

Social Security, Driver’s License,

State ID, Passport Number.

Yes

No

Not Applicable

Yes

Government Entities

Account Log-in and Password

Yes

No

Not Applicable

No

Not Applicable

Financial Account, Debit Card, Credit Card Number and account access information.

Yes

 

No

Not Applicable

 

Yes

 

Service Providers

 

 

 

Precise Geolocation.

No

 

No

 

Not Applicable

 

No

 

Not Applicable

 

Racial or ethnic origin, religious or philosophical beliefs or union membership.

No

No

 

 

 

Not Applicable

 

No

Not Applicable

Contents of e-mail, text messages unless we are intended recipient.

Yes

 

No

Not Applicable

No

Not Applicable

Genetic Data

 

No

No

 

Not Applicable

No

 

Not Applicable

 

Biometric Information for purpose of identification.

No

No

Not Applicable

 

No

Not Applicable

 

Health information collected and analyzed.

No

 

No

 

Not Applicable

No

Not Applicable

 

Sex life or sexual orientation collected and analyzed.

No

No

 

 

Not Applicable

 

No

Not applicable

 

 

4. OTHER CALIFORNIA PRIVACY RIGHTS
4.1 Shine the Light Request.

Individual consumers who reside in California and have provided us with their personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: privacy@alcltd.com with the subject “California Shine The Light Request” or ALC & Co., LLC, 818 South Broadway, Fourth Floor, Los Angeles, CA 90014, Attention: Shine the Light Request. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

4.2 Minor’s Right to Remove Posted Content.

If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@alcltd.com with the subject “Privacy Rights for Minors.”  Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

 

4.3 Do Not Track

Our website recognizes and responds to “Do Not Track” requests available through many popular web browsers. If we recognize that you have enabled one of these “Do Not Track” signals, we will not track or sell cookie information about your online activities.

 

APPENDIX B

NEVADA PRIVACY RIGHTS NOTICE

Effective Date:  January 1, 2023

Under Nevada Revised Statues Section 603A., et. seq., residents of Nevada have certain rights with respect to the personal information that we collect on this website.

  1. The categories of personal information that we collect and the categories of third parties with whom we share personal information are described in the chart in the above Appendix A. California Privacy Rights Notice.
  2. You may review and request changes to the personal information that we collect or process on this website by sending an e-mail to privacy@alcltd.com.
  3. Any material changes to this notice shall be posted in this Appendix B to this Policy.
  4. When you use our websites, we may share personal information about your online activities over time and across different internet sites or online services with third parties.

 

APPENDIX C

Canada PRIVACY RIGHTS NOTICE

Effective Date:  January 1, 2023

Notice to residents of Canada:  By using this our site or sites, you signify your acceptance of our Policy, and you adhere to the terms and conditions posted on our website. By submitting your information, you agree that it will be governed by our Policy.

You may request details about our privacy practices, access or correct your personal information, or make a complaint by contacting us in writing at: privacy@alcltd.com or ALC & Co., LLC, 818 South Broadway, Fourth Floor, Los Angeles, CA 90014, Attention: Privacy

If you are not satisfied with our response to your inquiry, you may contact the Office of the Privacy Commissioner of Canada: 1-800-282-1376 (toll-free) or priv.gc.ca

 

APPENDIX D: NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA), THE UNITED KINGDOM AND SWITZERLAND

This Section provides additional information to individuals located in the EEA, the United Kingdom or Switzerland at the time their personal information is collected by Us. All capitalized terms in this Section have the meaning as defined in the General Data Protection Regulation (GDPR) and/or, as applicable, the GDPR as it is saved and incorporated into United Kingdom law following Brexit (UK-GDPR) or the Swiss Data Protection Act (including, but not limited to “Personal Data”, “Processing”, “Controller”, “Processor”, “Data Subject”, “Consent”).

1.1  Data Controller and Representatives

The Controller for the Processing described in this Privacy Policy is:

ALC & Co. LLC
818 South Broadway, Fourth Floor
Los Angeles, CA 90014
privacy@alcltd.com

For Data Subjects in the EU and the UK:
We value your data subject rights under GDPR and UK-GDPR and therefore have appointed the following entities as representatives according to Art 27 GDPR and Art. 27 UK-GDPR in order to provide you with an easy way to submit to us privacy related request like a request to access or erase your personal data. If you want to make use of your data subject rights, please visit: gdpr-rep.eu/q/13529322 

EU Representative:

UK Representative:

 

1.2. Legal Basis of Our Processing. The Legal basis of Our Processing of your Personal Data within the scope of application of the GDPR, the UK-GDPR or the Swiss Data Protection Act is as follows:

  • Contract (Art. 6 (1) b GDPR), where we Process your purchase transactions (e.g. orders, exchanges and returns, shipping notifications) and answer your support and customer service requests as this is necessary for the performance of Our contract with you;
  • Legitimate Interests (Art. 6 (1) f GDPR):
    • In our legitimate interest in providing a secure Website user experience, we Process Your Personal Data to administer Our Programs and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; further information can be found in Our Cookie Policy;
    • For an appealing surfing experience, we Process your Personal Data to allow you to participate in interactive features of our Website or our social media accounts, when you choose to do so;
    • Responding to your comments and questions is part of Our legitimate business interests in providing you with first class services;
    • In our legitimate interest in expanding marketing offers to potential customers, we Process your Personal Data to share it with other advertising networks;
    • To protect Our financial interests or to otherwise protect Ourselves against fraud or unauthorized transactions, we Process your Personal Data, e.g., we conduct credit card screenings, and perform monitoring to identify potential unauthorized users or hackers;
    • Our legitimate interest in promoting Our business is the purpose for Processing your Personal Data to facilitate any contests, sweepstakes, or promotions and process and deliver entries and rewards;
    • If you want to work with Us and apply for a job, We Process your Personal Data to evaluate your application;
    • To protect Our rights and interests (e.g., protect the Company against legal claims) we can use your data with, or otherwise distribute, share or disclose your Personal Data to any of the Company’s professional advisors such as attorneys or accountants in order to facilitate their professional advice.
  • Consent (Art. 6 (1) a GDPR):
    • Unless consent is not required under applicable law, we send you promotional communication about Our products, services, offers, and events offered by Us and others, and provide news and information We think will be of interest to you only after you have consented to such communication. You can withdraw your consent at any time with future effect, e.g. by clicking the unsubscribe-link in each promotional email;
    • We request your consent to monitor and analyze your usage of Company Programs and advertising to understand their effectiveness, and to personalize your experience when you use a Company Program;
  • Compliance with Legal Obligations (Art. 6 (1) c GDPR):
    • We Process your Personal Data for compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including, without limitation, for Company’s tax reporting) or as may be requested, e.g., under any subpoena or court order.

1.3. Social Media Accounts We maintain accounts with various social media networks. When you visit these social media networks, a variety of Data Processing operations are triggered. We use your Personal Data when you visit Our profiles on these social media networks, or when you click on the like-button on one of our social media advertisements. When you visit Our profiles, your Personal Data is not only used by Us but also by the social network provider, regardless of whether you have a profile in the social network or not. The individual Processing and its scope differ from provider to provider, and they are not completely transparent to Us. Details about the Processing of the social network providers can be found in the relevant social media network’s Privacy Policy:

The social network providers collect your usage information to provide us with usage statistics. To learn more about how such tracking takes place and to understand how we use social media plugins on our Site please read our Cookie Policy.

1.4. International Transfers We may share your Personal Data with recipients (including our group members, service providers or business partners, as described in this Policy), located in the EEA, the UK and Switzerland; or in the United States and/or otherwise in countries outside the EEA, the UK and Switzerland which do not provide for an adequate level of data protection from an EU or Swiss law perspective. For such transfers, we will ensure that the recipients are subject to appropriate safeguards as permitted under the applicable data protection laws, e.g. by entering into appropriate data transfer agreements on the basis of updated EU standard contractual clauses issued by the Commission, on the basis of the UK’s International Data Transfer Agreement (IDTA) or by reliance upon the Article 49 GDPR derogations or corresponding derogations under the UK-GDPR or Swiss Data Protection Act, as applicable. A copy of the respective appropriate safeguards is available upon request.

1.5. Duration of Our Data Processing We retain Personal Data you provide to Us for as long as necessary for the purpose such Personal Data was originally collected or otherwise processed for, e.g., in order to meet Our contractual obligations towards you, until you withdraw your consent, or as long as you maintain a customer account with Us. If required under applicable law, We will store your Personal Data for a period of up to ten more years (e.g., under tax law). Apart from that We can further store your Personal Data for the establishment, exercise or defense of legal claims.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve Our Services.

1.6. Your Data Protection Rights under the GDPR You have the following rights pursuant to the GDPR, where applicable, which can be exercised using the contact details of the Controller listed above:

  • Right of Access, pursuant to GDPR Article 15, to obtain from Us confirmation as to whether or not Personal Data has been Processed and, if so, access to that Personal Data and additional information about the categories of Personal Data and its source, and how it has been Processed, e.g., the purpose, the categories of recipients, the planned retention period, the existence of the Data Subject’s rights;
  • Right to Rectification, pursuant to GDPR Article 16, to request the correction of incorrect Personal Data or any completed Personal Data stored by Us;
  • Right to Erasure, pursuant to GDPR Article 17, to request the deletion of the Personal Data stored by Us, except for the allowed continued uses permitted by the GDPR;
  • Right to Restriction, pursuant to GDPR Article 18, to demand the restriction of the Processing of the Personal Data where one of the following applies: (i) as far as the accuracy of the Personal Data is disputed by you; (ii) the Processing of the Personal Data is unlawful, but you reject its deletion; (iii) We no longer need the Personal Data, but you require it to exercise or defend legal claims; or (iv) you have objected to the Processing in accordance with GDPR Article 21;
  • Right to Data Portability, pursuant to GDPR Article 20, to receive your Personal Data as provided to Us, in a structured, common and machine-readable format or to request the transfer to another Controller;
  • Right to Withdrawal, pursuant to GDPR Article 7(3), you have the right to withdraw, at any time, your once granted consent. As a result, We are no longer allowed to continue the Processing based on that consent for the future, but such withdrawal does not affect the lawfulness of the Processing based on such consent before such withdrawal; and
  • Right to Lodge a Complaint with a Supervisory Authority, pursuant to GDPR Article 77, to complain to a Supervisory Authority (e.g., that of Your usual place of residence or work or place of the alleged infringement). You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO): casework@ico.org.uk or 0303 123 1113 / +44 1625 545 700; www.ico.org.uk.

 

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