Privacy Policy

Privacy Policy and

Terms of Use and Membership Agreement

 

Last updated: January 1, 2024

 

Disclaimer

 

Our members trust us to find only the best, and it is not a responsibility we take lightly. This is why when we consider new partners, products, services, experts or ideas, our values and interests have to align with the expectations of our members and our mission.

In this Privacy Policy and Terms of Use, members, experts, and others who access our Services are often also referred to as users.  We commonly refer to the products, services, experts and companies we feature as “partners”. We are referring to marketing partnerships, and we do not in any way have ownership in their separate businesses, nor do they have ownership in Exclusivia. If we do have ownership of a product or company, we make sure to state it. We also feature certain thought leaders as experts.  Those experts might be our partners.  They might also recommend a product or service.  We require those experts to disclose whether they have any affiliation with the product or service they are recommending, and we disclose that our members.  We do this because we believe members want to know about these relationships.

Except for content contributed by experts and partners, all of the information and descriptions of offerings featured on our website (the “Site”) or our other Services reflect the opinion of Exclusivia, based upon our own experience and analysis, as well as our review of the research and materials provided to us by our partners. We do not guarantee that any featured products or services will yield specific results or will be fit for a particular purpose.  However, we are strongly vetting the products and services we feature to provide you our informed opinions based on our own experience.

Regarding your use of health-related products or services we feature on our Services, Exclusivia is not a medical organization and does not employ doctors. We do not and cannot make medical recommendations to members, and nothing on our Services should be interpreted as medical advice. While the information we share and promote may be designed to scientifically improve health, each individual must make their own choice regarding whether these solutions are appropriate for their situation. We strongly recommend that you consult with your own doctor prior to using any health-related products or services.

At this time, Exclusivia makes money by charging membership dues and through the direct sale of products, but we reserve the right to make money in other ways in the future, including but not limited to partner revenue sharing, affiliate payments,  licensing of image rights, and program sponsorship. For example, Exclusivia anticipates occasionally getting paid a commission for the sale of third-party products or services on the Services.  Members should assume that purchases of products or services on the Services may result in a commission or other financial benefit to Exclusivia.

Exclusivia was built for our members, and we will continue to make sure our members’ interests come first. Integrity is the foundation of our mission.  We commit to you that, the fact that we receive compensation from any of these sources will not influence our vetting process or the opinions, content, information, offerings or experts featured by Exclusivia on the Site

General Terms

The above Disclaimer and these General Terms are incorporated into Exclusivia’s Privacy Policy and into our Terms of Use and Membership Agreement below.

Interpretation.  If we use the words “include” “includes” or “including”, we mean “include, without limitation,” “includes, without limitation,” or “including, without limitation”.  Section headings are present for convenience only and are not meant to comprehensively describe all matters within that section.  The singular of any term will also include the plural and the plural will include the singular where context requires. Masculine or feminine terms include masculine, feminine, gender neutral and gender fluid terms where context requires.  Each of our documents has been prepared originally in the English language, and in any dispute with respect to the interpretation of a version translated into a language other than English, interpretation of the English version will control.

Governing Law.  The Privacy Policy and Terms of Use and Membership Agreement are governed by the laws of the State of Texas, without reference to conflicts of laws principles.

Jurisdiction and Venue. The United States District Court for the Western District of Texas and state courts of competent jurisdiction within Bexar County, Texas, and the Supreme Court of the State of Texas shall have jurisdiction in any litigation or other court proceeding with respect to any matter arising from or in connection with this Privacy Policy or Terms of Use and Membership Agreement.  Both Exclusivia and you hereby submit to jurisdiction and consent to venue in such courts and waive any defense based on forum non conveniens.

Waiver of Jury Trial.  EACH PARTY HEREBY WAIVES ITS RIGHT TO A TRIAL BY JURY IN ANY LITIGATION OR OTHER COURT PROCEEDING WITH RESPECT TO OR RELATED IN ANY WAY WITH ANY MATTER ARISING FROM OR IN CONNECTION WITH OUR PRIVACY POLICY OR TERMS OF USE AND MEMBERSHIP AGREEMENT.

Privacy Policy

Last updated: January 26, 2024

 

Exclusivia LLC (“Exclusivia,” “we” or “us”) cares about your privacy and the security of your information. Our purpose in collecting your information is to deliver the Services we provide to you through the Site or otherwise and to improve your experience with Exclusivia and our partners when you interact with the Site or with us otherwise. For more detail, see Use of Personal Information below.  We also want you to be familiar with how we collect, use and disclose your information. This Privacy Policy describes our practices in connection with information we collect through our Site, HTML-formatted email messages (“Emails”), offline contacts and any other services that we offer to you as a member (“Other Services”) (The Site, Emails, and Other Services, are individually and collectively referenced in this Privacy Policy as the “Services”).

To use our Services as a member, we require that you agree to the terms of this Privacy Policy and to our Terms of Use and Membership Agreement.   You may also opt-in to receive email communications from us here.  After you have opted in, you may opt out of receiving email communications from us or modify your email preferences at any time by contacting us as provided in the Contact us section.

 MODIFICATION OF THIS PRIVACY POLICY

From time to time, we may change this Privacy Policy. When we do, the “Last Updated” line at the beginning of this Privacy Policy will be revised. You are responsible for regularly reviewing this Privacy Policy. Your continued use of the Services after we post changes to our Privacy Policy indicates your acceptance of those changes. Unless we provide you with specific notice, no changes to our Privacy Policy will apply retroactively before the earlier of the date it is posted to our Site or the date you receive notice of the change from us.

PERSONAL INFORMATION THAT WE COLLECT

When you use our Services, including by subscribing to our newsletter, browsing our Site, or otherwise interacting with our Services, we gather personal information. This information is necessary to deliver the Services to you or enhance your user experience as described in this Privacy Policy.

Personal information is information that identifies you as an individual or relates to an identifiable individual. Several types of personal information can be gathered when you interact with the Services. Examples of such personal information include your name, email address, mailing address, IP address, approximate geographic location, and, when you indicate interest by making a purchase through the Site, your interests.

COLLECTION OF PERSONAL INFORMATION

How we collect personal information

We and our service providers collect personal information in a variety of ways, including when you:

  • Use the Services;
  • Sign up to receive emails, newsletters or other communications;
  • Allow push notifications;
  • Participate in interviews, surveys, contests, sweepstakes or other promotions we offer via the Services;
  • Request customer service or other assistance;
  • Otherwise communicate with us via the Services; or
  • Take a survey offline or participate in an in-person interview related to the Services or your membership.

If you disclose any personal information of other people to us or to our service providers, partners or experts in connection with the Services, you represent that you have the authority and all necessary permissions to do so and to permit us to use the information you contribute about them in accordance with this Privacy Policy.

What we collect

Information You Provide.  We collect information that you provide us, including your account and profile information, content you submit or post to our Services, your purchase information, your communications, and information you provide to us as part of surveys, interviews and contests.

 

  • Account and Profile Information.When you create an account on our Services, we collect information you provide us, like your name, email address, interests, and profile information (when you make a purchase on the Site). If you are a professional or are in business, you may also provide us information related to your business, including a business description and areas served.
  • Content You Submit.We collect information and content that you submit, post to, or create in our Services, including your photos, comments, reviews, recommendations, searches, discussions, and as an expert or provider of a product or service, other types of content provided for in our Exclusivia expert business account tools, as they become available.

 

  • If you purchase or sell products or services or make or receive payments within our Services, we collect certain information in order to complete your purchases, sales, and payments, such as your phone number, address, and payment method (for example, credit card or bank account information).
  • When you communicate with us (through our Services via email, phone, or otherwise) we collect the information you provide to us in order to fulfill our contract with you.   You are using our Services when you make calls to these professionals and sellers by using a link to their phone number displayed on our Services, if any.  We will provide you notice or obtain your consent in accordance with applicable law before recording or monitoring any calls. Otherwise, to the extent you communicate with professionals, sellers, and other users outside our Services, those communications are not monitored or tracked by us and not subject to this Privacy Policy but are subject to the privacy policies and terms of use of such third parties.

 

  • Surveys and Contests.If you participate in our surveys, contests, or promotions, we will collect the information you provide to us.

 

Information from Others.

  • Other Services.We may receive information about you from third-party services or platforms when you allow the third-party services to share this information with us or allow Exclusivia to obtain this information from the third party. For example, if it is available, you may sign-up for or access our Services through social media, Google, or Apple; or use our Services (or a third-party integration on our Services) to manage and send communications (e.g., email, chat communications, instant messages or text messages).
  • Publicly Available Information.We may collect information about you from publicly available sources. For example, we may receive your name and contact information from industry associations and other networks in which you participate.

 

  • Our Partners and Service Providers.We may receive information about you from our partners and service providers. For example, our payment processors may update your payment information, advertising partners may help us send communications to your address and notify us of a failed delivery attempt, and third parties may help us prevent fraud by verifying your contact information. In addition, our banking and payment processing partners may provide us information regarding the status of your purchases from us.

 

  • Third-Party Sites.Certain third-party sites embed a plug-in, widget, or content, including through buttons, badges, and slideshows. Any plug-ins, widgets, embedded content, pixels or beacons we may use will collect information pursuant to our Cookie Policy.

 

Automatically Collected Information.  Each time you access the Services, information is sent to our server by your Internet browser or app and stored in our log files. We collect information about your use of our Services, including your search activity on our Site, the pages you view, the date and time of your visit, and if you use our browser extensions, and how you navigate and interact with a page or screen on our Site. We also collect information that your device provides to us in connection with your use of our Services, such as your browser type, type of device, browser language, IP address, mobile carrier, unique device identifier, and requested and referring URLs.

  • Cookies and Similar Technologies. We use cookies and similar technologies in connection with your use of our Services to collect information related to what you see and interact with on our Site and other Services. Please see our Cookie Policy for more information on our use of cookies and how to accept or opt-out of cookies, but please note that unless required by law, we do not change system behavior within our Services in response to browser requests not to be tracked.
  • Location Information. We will receive your device’s location if you enable this through your browser or mobile device. We may infer your general location from your IP address. You may also choose to provide us your location information by inputting this information in our Services, including in your Exclusivia settings, or when you sign up for membership or make a purchase on the Site and provide a shipping or billing address.

COLLECTION OF PERSONAL INFORMATION OF CHILDREN

 

Our Services are intended for general audiences and are not directed to children, including children under age 16.  We do not knowingly collect or use personal information of children.  If we learn that we have collected personal information of a child, we will take appropriate steps to delete that information. If you become aware or believe that a child has provided us with personal information or that we have the personal information of a child, please contact us as provided in the Contact Us section

USE OF INFORMATION

We use the personal information we collect to provide, support and personalize our Services and to communicate with you about the Services (both on and outside our Services).  We do this for the following purposes and based on one or more of the following:

  • To provide the Services to you, as well as related content you request.
  • To perform agreements we have with you and to enforce compliance with agreements we have with you, including our Terms of Use and Membership Agreement; to comply with legal obligations that we are subject to; to pursue or defend lawsuits, mediation, arbitration or other legal proceedings; and to respond to lawful requests by public authorities (including national security and law enforcement requests).
  • To evaluate, optimize and improve our Services, their features and functionality, including evaluating the use of our Services for our business purposes and to determine whether to offer new products and services.
  • To perform statistical, demographic, and marketing analyses of the use of our Services using aggregated and anonymized data.
  • To fulfill your purchases through our Services, and process, store, and deliver your communications; to provide customer service and support; to respond to your requests or inquiries.
  • To back-up our systems; and to improve the security of our Services.
  • To maintain a quality experience, including to filter for spam and communications that violate our agreements with you.
  • To detect, investigate, and prevent activities, including spam and fraud, that may violate our policies or be illegal.
  • To communicate with you about your account, respond to your inquiries, and provide you information features and enhancements of the Services and about changes to our policies.
  • To provide feedback to experts and sellers on our Services.
  • To send you newsletters and emails.
  • To administer contests, sweepstakes, promotions, and surveys.
  • To fulfill other legitimate interests of Exclusivia, a third party or you. “Legitimate interest” is used in the context defined under the General Data Protection Regulation (GDPR).

DISCLOSURE OF PERSONAL INFORMATION

We do not rent or sell your personal information that would identify you individually (such as your email address associated with your account) to third parties to use for their direct marketing purposes except if directed by you or as otherwise disclosed in this Privacy Policy.

We may disclose personal information collected from you to our parent companies, subsidiaries and affiliates. We provide personal information collected from you to persons and entities that provide support services to us or perform functions on our behalf, such as marketing, analytics, and customer service. These recipients may need personal information to perform their functions. We also provide personal information collected from you to sellers of products or services on our Site to facilitate a purchase you might have made from them via our Services.

We may collect personal information from you in connection with sweepstakes, contests and similar promotions that we conduct on our Services.  We will let you know at the point of collection of your personal information if we do. and you will have the opportunity to opt out of such disclosures.  If you are a winner of such an event, we will share your personal information with any company that is responsible for fulfilling any prize you have won.

We may disclose personal information collected from you if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process; (b) protect and defend the our rights or property, the Services, or our users; or (c) act under emergency circumstances to protect the security or privacy of your personal information or the personal safety of any of our employees, agents, or contractors, or those of any of our parent companies, affiliates or subsidiaries, any users of the Services, or the public.

We will disclose or transfer your personal information to a third party upon a verifiable request received from you.

We will also disclose or transfer personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or a controlling interest in our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisers.

We may disclose personal information to third parties to help us determine how people use parts of the Services so we can improve them and develop new product offerings. We may provide personal information about how our users collectively use the Services in aggregated and anonymized form to our service providers and other third parties.

In connection with the Services, you may elect to disclose personal information:

  • On comments sections, contact forms and other services to which you are able to post information and content (including, without limitation, our social media pages).
  • Through your sharing activity. When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that Exclusivia has no control over and is not liable for any damages you might suffer as a result of the collection or use of shared information by the social media account provider, and the use of that shared information by the social media account provider will be governed by the social media provider’s privacy policy and terms of use.

Please remember that any information you share in public areas, such as comment sections or forums, or that you otherwise post, display or disseminate in an area that is viewable by other users of the Services, including outside of the Services on social media, becomes public. Please be careful about what you disclose and do not disclose any personal information that you expect to keep private.

OTHER INFORMATION

Other information is any information that does not specifically identify you and is collected through technology includes tracking information collected by us as well as third parties. Other information includes:

  • Information about your computer, mobile device, or other device that you use to access the Services such as your device type and brand, operating system, unique device identifiers, browser type, browser client ID, browser language, Internet service provider;
  • Usage information about your use of our Services, such as a reading history of the pages you view;
  • Additional “traffic data” such as time of access, visitor ID, traffic channel, traffic source, traffic medium, campaign name, date of access, software crash reports, session identification number, access times, and referring website addresses;
  • Search terms and search results;
  • Location data such as your IP address, geolocation information (longitude and latitude);
  • Demographic information and other information provided by you that does not reveal your specific identity; and
  • Other information that has been aggregated in a manner such that it no longer reveals your specific identity.

COLLECTION OF OTHER INFORMATION

We and our service providers may collect other information in a variety of ways, including:

Through your browser or device

Using cookies, pixel tags and other similar technologies

Like many websites, our Services may use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages and that record your preferences and actions. We use cookies to track use of our Services. We may also use cookies to monitor traffic, improve the Services and make it easier and/or relevant for your use.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. If you delete your cookies or if you set your web browser to decline cookies, some features of the Services may not work or may not work as designed. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding your use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We may use pixel tags (also known as web beacons and clear GIFs) to, among other things, track your actions as a user of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

We may also use web beacons. A web beacon (also known as an “action tag”, “tracer tag” or “single-pixel gif”) is an invisible graphic on a web page that is programmed to collect information about your use of a given website and deliver cookies.

IP address

As noted above, we collect and store your device’s source IP address. Your IP address is automatically assigned to your computer by your internet service provider. An IP address discloses the general location (i.e. city, state, country and continent) of your device at the time you access the Services. We may use your device’s IP address to:

  • Personalize offers and promotions for our Services and special events;
  • Optimize our products, services and operations;
  • Detect, investigate, and prevent activities that may violate our policies or be illegal;
  • Identify the country where you are located so that we can assess our legal obligations; and
  • Perform statistical, demographic, and marketing analyses of users of the Site.

USES AND DISCLOSURES OF OTHER INFORMATION

We may use and disclose other information (which does not specifically identify you) for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine other information with personal information. If we do, we will treat the combined information as personal information as long as it is combined.

SENSITIVE INFORMATION

Unless we specifically request it (for example, in connection with a particular survey), we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us. Any requested information that includes sensitive information about health, political opinions, ethnicity, race, religion, sex life or sexual orientation may be left unanswered.

INFORMATION SECURITY

We use reasonable efforts to safeguard personal information. However, no data storage system or transmission method can be guaranteed to be 100% secure. As a result, we cannot guarantee the security of any information (including personal information) that we obtain. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Us section.

RETENTION PERIOD

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you participate to a promotion with us or keep using the Services);
  • Data deletion standards within governing laws, rules or regulations;
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY ADVERTISING

We may work with third-party advertising companies that may utilize web beacons, cookies, pixel tags, or other similar technologies to provide to us analytics about goods and services that may be of interest to you and other users when you access and use the Services and other websites or online services.  We do not provide these companies access to your name, address, e-mail address, telephone number or other personal information.  They may, however, anonymously track your internet usage on the Services and across other websites in their networks beyond the Services. To learn more about the use of this information please

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 website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media account providers, operating system providers, wireless service providers or device manufacturers, or any of their affiliates, including with respect to any personal information you disclose to other organizations through or in connection with our social media pages.

USE OF SERVICES BY CHILDREN

Our Services are intended for general audiences and are not directed to children.  Use of the Services by children is prohibited by our Terms of Use.  We do not knowingly collect or store personal information from children.  If we learn that we have collected personal information from a child, we will take appropriate steps to delete that information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in the Contact Us section  If you are a resident of California, USA, under 18 years old and a registered user of the Services, please contact us as provided in the Contact Us section to change or update your personal information.

YOUR CALIFORNIA PRIVACY RIGHTS

Under the California “Shine The Light” law, California residents may opt out of our disclosure of personal information to third parties for their direct marketing purposes. We do not currently sell or plan to sell personal information to third parties for those purposes.  However if we do so, we will provide you the opportunity to opt out of the sharing of your personal information with third parties for marketing purposes at any time by submitting a request in writing to us as described in the Contact Us section.

California Minors Residents

If you are a minor resident in California, under 18 and a registered user of the Services, you may ask us to remove content or information that personally identifies you by contacting us as provided in the Contact Us section.  Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by you or another user on social media.

Additional Information for Individuals from California

This section provides notice and specific information for California consumers to address the California Consumer Privacy Act (“CCPA”).  We collect the following categories of personal information from you:

  • Contact information and other identifiers (for example, real name, address, email address, account name, or other similar identifiers);
    ● User ID or device identifiers (for example, IP address or other similar identifiers);
    ● Customer records (for example, customer records containing personal information, such as name, address, and telephone number);
    ●
    ● Purchase history and preferences (for example, records of products or services purchased or considered);
    ● Usage data (for example, internet activity information, including browsing history and interactions with our Site);
    ● Approximate  geolocation data (for example, latitude/longitude from a particular device);
    ● Audiovisual information (for example, photos, visual, audio, or similar information, only if you choose to provide this information);
    ● Biographical history (for example, professional information, if this information is provided).

The Use of Information section of this Privacy Policy describes the purposes for which we collect your personal information.

We do not disclose your data in exchange for money or valuable services, except at your request or direction. For California residents, the CCPA defines “selling” personal information to include providing it to a third party in exchange for valuable services. Disclosure of information to certain third parties in exchange for valuable services, such as advertising services, may constitute a “sale” under the CCPA. If we sell personal information in the future, we will offer you the opportunity to opt-out of this disclosure of your data for such commercial purposes.   As provided in our Terms of Use, use of the Services by children is strictly prohibited. Consequently, we do not knowingly disclose information regarding individuals under 18 years of age to third parties in exchange for consideration.

In addition to the rights described above and in the Your Choices and Rights section, California consumers may also, up to twice every 12 months and subject to certain exceptions, request us to provide information about how we have used and shared your personal information in the prior 12 months. Please submit these requests for information, as well as requests to access or delete your information, by contacting us as provided in the Contact Us section.

Your authorized agent may submit a request to know, delete, or opt out on your behalf. We may still require you to directly verify your identity and confirm that you have provided the authorized agent permission to submit the request. Whether you submit your request directly or through an authorized agent, generally, the only means we have to verify your identity is for you: to respond to a specific Exclusivia email to the email address associated with your Exclusivia account; to click a confirmation or similar button in a specific email from us sent to the email address associated with your Exclusivia account; or to submit your request from your logged-in account.

Learn more here about the types of personal information that we collect, disclose for a business purpose, or disclose in exchange for valuable services. The Collection of Information section of this Privacy Policy describes the sources from which we collect your personal information. The Use of Information section of this Privacy Policy describes the purposes for which we collect your personal information. The Disclosure of Information section of this Privacy Policy describes the types of third parties with whom we share your personal information.

Consistent with the CCPA, except to the extent reasonably related to the value of your personal information, we will not treat California consumers differently for exercising their rights under the CCPA.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Exclusivia is headquartered in the United States. If you are not within the United States, in order to provide you with the Services, personal information you provide to us or that we obtain as a result of your use of the Services will be collected in your country and subsequently transferred to us and processed in the United States.  Data protection laws differ among jurisdictions, and the United States and these other jurisdictions may not provide the same level of protection for personal information as your jurisdiction of residence. For example, your information may be required to be disclosed to law enforcement or government authorities under the laws of those jurisdictions. If you are from the European Economic Area (“EEA”) and we transfer your personal information to countries outside of the EEA, we will take appropriate steps to ensure your personal information is afforded the same level of protection as described in this Privacy Policy. If you are located in the EEA or Switzerland, we comply with all legal requirements for the transfer of personal information to countries outside of the EEA or Switzerland.

Some countries that are not located in the EEA are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, please contact us as provided in the Contact Us section to obtain a copy of the adequate measures we have put in place  to protect your personal data.

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA

If you are located in the EEA, our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. We collect and use your information for a variety of business purposes that are in our legitimate interests, in order to enter into or perform a contract with you, with your consent, or to comply with our legal obligations.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you wish to learn more about specific legal grounds we rely on to process your information for any particular purpose (including any legitimate interests we have to process this information), please contact us as provided under the Contact Us section. For example, we rely on our legitimate interests to process information for direct marketing purposes and for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms.

YOUR CHOICES AND RIGHTS

We respond to all verifiable requests we receive from individuals wishing to exercise their data protection choices and rights under applicable data protection laws.  We may ask you to verify your identity in order to help us respond to your request securely and efficiently by identifying yourself by name and by one or more elements of personal information and/or technical means.  You may request to receive a copy of personal information associated with you on our Services through your account settings. You may also access your Exclusivia information by contacting us as provided in the Contact Us section. To request permanent deletion of your personal information, please contact us as described in the Contact Us section.  To edit your personal information, you can manage your profile in your account settings, or you may contact us as provided in the Contact Us section about correcting or updating your personal information (including your marketing preferences). We will consider your request in accordance with applicable laws.

Exclusivia takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. In addition to the rights described above, you have additional rights in relation to your personal information, including the right to object to, or to ask us to restrict, the processing of your personal information. You can exercise these rights by contacting us as provided in the Contact Us section. You also can deactivate your Exclusivia profile through your Exclusivia settings and deactivate your account there or by contacting us.

Individuals in the EEA can complain to a data protection authority about our collection and use of your personal information in relation to the General Data Protection Regulation (GDPR) and other applicable law. For more information, and to submit a GDPR complaint, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

CONTACT US

If you have questions or comments about this Privacy Policy (including about the manner in which we or our service providers treat your personal information), you may contact us in these ways:

  1. Please email us at [email protected], Attn:  Chief Privacy Officer; or
  2. You may also reach our Chief Privacy Officer by mailing us at our address at                                                     , USA, Attn: Chief Privacy Officer.