INTRODUCTION

This website is owned and operated by AERIN Holdings LLC. We respect your privacy and understand that you have a right to know why we collect your personal information and what we do with it. This Privacy Policy applies to information we collect through our Sites (as defined below) as well as information we may collect offline.

This policy describes the type of information we collect from you and/or that you may provide us when you visit and/or use this website and/or any of our mobile applications (individually or collectively, “Sites”). “You/your/user(s)” means you as a user of our Sites.

By accessing the Sites, you acknowledge this Privacy Policy and agree to be bound by the terms hereof, the Terms of Service, and any other terms or policies we post on the Sites. If there is anything you do not understand, please email any inquiry to privacy@aerin.com. If at any time you do not agree to this Privacy Policy, please do not use the Sites or provide us with any personal information.

We reserve the right to change or update this Privacy Policy by posting such changes or updates to the Sites or emailing you notice of the changes. Amendments to this Privacy Policy will be posted at this URL and will be effective when posted. You can tell if this Privacy Policy has changed by checking the last modified date that appears at the end of this Privacy Policy. Your continued use of the Sites following the posting of any amendment, modification or change shall constitute your acceptance thereof.

YOUR SECURITY

We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. All payment transactions will be handled through our third party payment processor, and we will not have access to your credit card number or other such financial data.

Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Sites, any transmission of Personal Information is at your own risk. We cannot guarantee that such information will not be intercepted by third parties, and we will not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for unauthorized circumvention of any privacy settings or security measures contained on the Sites.

INFORMATION WE COLLECT

We collect various information that identifies you as a person (“Personal Information”) in two ways. First, we collect Personal Information that you provide to us. Second, we collect certain Automated Information that may contain Personal Information when you use our Sites.

Personal Information You Provide to Us

The Personal Information you provide to us is generally:

• contact details including name, email, telephone number and shipping, billing address
• login and account information, including unique user ID and password
• personal details including date of birth (optional) and purchase history
• payment or credit card information through our third-party payment processor
• personal preferences including marketing preferences

We collect Personal Information directly from you when you provide it to us. This typically occurs when you:

• Sign up for our email list
• Place an order with us online
• Buy a product at any of our retail locations
• Send us an email or other communication
• Register for an account with us
• Participate in our promotions, surveys, and/or contests

Automated Information

We also collect information, some of which may be Personal Information, through automated means when you visit our Sites (“Automated Information”) such as:

• the IP address of the device you use to connect to the internet (which may include information about your geographic location)
• the unique identifiers of your device
• your browser characteristics
• your device characteristics
• your operating system
• your language preferences
• the URLs through which you were referred to our Site
• information on actions taken by you on our Site
• dates and times of your visits to our Site
• the pages you accessed on our Site

We collect Automated Information automatically as you navigate through our Site as explained further below.

We may collect information, which may include certain Personal Information data such as your IP address, from your browser when you use our Sites. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (a) IP-address; (b) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (c) unique device identifier and device type; (d) domain, browser type and language; (e) operating system and system settings; (f) country and time zone; (g) previously visited websites; (h) information about your interaction with our Sites such as click behavior, purchases and indicated preferences; and (i) access times and referring URLs.

Most web browsers automatically accept cookies. If you do not wish to have cookies on your system, you can set your browser to refuse them. Please review the specific instructions from your browser in order to do this. However, please note that not accepting cookies may make certain features of our Sites unavailable or difficult to view or use.

In some of our email messages we may use a “click-through URL” linked to content on our Sites. When you click one of these URLs, you will pass through our web server before arriving at the destination web page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our Sites. If you prefer not to be tracked through our emails, simply avoid clicking text or graphic links in the email.

Third parties may also collect information via our Sites through cookies, third party plug-ins and widgets in order to deliver our targeted advertisements to you across the Internet.

Our web server may collect clickstream information such as the address (or URL) of the website that you came from before visiting the Sites, which pages you visit on the Sites, which browser you used to view the Sites, and any search terms you may have entered on our site, among other things. The Sites may also use other technologies to track which pages our visitors view.

HOW WE USE THE INFORMATION WE COLLECT

Most commonly we will use your Personal Information in the following circumstances:

• Where you have asked us to do so, or consented to us doing so;
• Where we need to do so in order to perform a contract we have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

We are committed to maintaining your trust and we want you to understand when and with whom we may share Personal Information and information collected about you. We do not share your Personal Information with any third parties except as set forth herein.

We may disclose your Personal Information to outside individuals and/or companies that help us bring you the products and services we offer and to create, operate, and maintain our Sites. For example, we may work with third parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; (g) provide order fulfillment and/or delivery services; and (h) provide other services designed to assist us in developing and running our Sites and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.

If we seek investors or go through a business transition, including but not limited to, a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be shared as part of the negotiation of the transaction and will likely be among the assets transferred in the event of a sale or partial sale of our assets.

We may disclose your Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the Website, to limit our legal liability and protect our rights or to protect the rights, property or safety of Users of the Sites or the public.

TARGETED ADVERTISING AND REMARKETING

You may see advertisements for our products/services on other websites and mobile applications because we work with third party advertisers to engage in remarketing and retargeting activities. Through our relationships with these advertisers, we can target messaging to our users by interest-based, demographic, contextual, and other means. These third party advertisers track your online activities over time and across websites and mobile applications by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites and mobile applications that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites or apps. This data collection takes place both on our Sites and on third-party websites and mobile applications that participate in the advertising networks. This process also helps us track the effectiveness of our marketing efforts. Some third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offer a single location to opt out of ad targeting from member companies ( www.networkadvertising.org).

If you are a California resident, you may ask us to refrain from sharing your information with certain of our affiliates and other third parties for their marketing purposes. See the “Privacy Notice for California Residents” here.

OTHER WEBSITES

Our Sites may contain links or references to websites operated by third parties, or you may have come to our Sites using a link found in another website. This does not mean that we endorse these websites or the goods or services they provide. We do not make any representations or warranties about any website that may be linked to the Site. Such other websites are independent from us, and we have no control over, or responsibility for, their information, products or activities. Our privacy practices may differ from those of these other websites. If you provide Personal Information at one of these third party websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand the other website's privacy policy before providing such website with any Personal Information.

If you use a third-party website or application (e.g. Facebook, Google +, Twitter) to access our Sites or your account on our Sites, your activities on such third-party sites or apps are governed by the privacy practices of those sites or apps. The privacy policies of other sites and apps may differ significantly from ours, and we have no control over the operation of those sites or apps or the manner in which the collect, store, or process data.

YOUR CHOICES ABOUT HOW WE USE YOUR INFORMATION AND OPTING OUT

There are ways by which you can control how your Personal Information is used.

Tracking

You can set your browser to refuse some or all cookies or to alert you when cookies are being sent. Please visit your specific browser’s instructions for doing this. The “Help” function on most browsers contains information on how you can set your browser to notify you before accepting cookies, or you can disable them entirely. If you opt out of cookies, you will not be able to take advantage of various features of the Sites that are available to other users. For example, we may use cookies to recognize you by name when you return to this site so you don’t have to login again and provide your password each time. If you use more than one browser, you will need to change each browser’s settings in order to refuse cookies.

Promotional Offers

If you do not wish to receive our email promotional offers, you may opt-out by checking the relevant box when we collect your information, logging into your account to update your preferences, or clicking on the “unsubscribe” link found in emails we send to you. Please allow up to ten (10) business days for changes to your email preferences to take effect. During that time, you may continue to receive email communications from us that were already in process. Opting out of receiving our communications will not affect your receipt of service-related communications, such as payment confirmations and delivery status updates, if we have a data breach, or other such communications for which we have a legal obligation to inform you and/or to prevent fraud or harm to our Sites, our business, and/or third parties.

Advertising

If you do not want us to use information that we collect for us to deliver advertisements to you, you can opt-out of receiving such advertising.

You may opt out of Internet-based and mobile advertising on your mobile device by visiting TRUSTe’s Ad Preference Manager, currently available at https://preferences-mgr.truste.com/, the Digital Advertising Alliance’s consumer choice page, currently available at http://www.aboutads.info/choices/, or the Network Advertising Initiative (NAI) opt out tool currently available at http://www.networkadvertising.org/choices/.

When using the ad industry opt out tools described above, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third-parties. We do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.

Analytics

Our products and services use Google Analytics and its associated tracking technologies to help display our ads you see on other sites, and to help us manage and optimize our online advertising efforts. To access the Google Analytics Opt Out Browser Add-on, visit https://support.google.com/analytics/answer/181881?hl=en

DISCLOSURE FOR LEGAL PURPOSES

You hereby authorize us to disclose any of your Personal Information pursuant to judicial and administrative proceedings and to law enforcement or government agencies if we are legally required to do so. You also authorize us to disclose Personal Information if we believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Sites, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put us at risk for liability.

NOTICE TO CALIFORNIA CONSUMERS

If you are a resident of California, please refer to the Privacy Notice for California Residents for specific provisions that apply to you.

DISPUTES

This Privacy Policy will be interpreted in accordance with the laws of the State of New York and the United States of America, without regard to its conflict-of-law provisions. By visiting the Sites, you agree that, except as otherwise specified herein, the laws of the State of New York without regard to principles of conflict of laws, will govern any dispute of any sort that might arise between us or any of our affiliates regarding your visit and use of the Sites.

We and you agree that in the event of any dispute, the party wishing to address the dispute must contact the other party in writing, including by e-mail, and advise the other party of the dispute in reasonable detail as well as informing the other party of the remedy being sought. We may send you notices via the email address or physical address you provide to us, and all notices to us shall be sent to the following email address: privacy@aerin.com and include the words “DISPUTE NOTICE” in the subject. The parties shall then make a good faith effort to resolve the dispute before resorting to more formal means of resolution. In the event that the dispute is not resolved through this procedure, the party raising the dispute may proceed to mandatory arbitration as set forth below.

Arbitration

ANY AND ALL DISPUTES BETWEEN YOU AND US WILL BE RESOLVED BY BINDING ARBITRATION. YOU HEREBY AGREE TO GIVE UP YOUR RIGHT TO GO TO COURT to assert or defend your rights under this Privacy Policy, except for matters that may be taken to small claims court. Your rights will be determined by a neutral arbitrator, NOT a judge or jury. You agree that any dispute arising out of or relating to this Privacy Policy, including with respect to the interpretation of any provision of this Privacy Policy or other agreements between you and us, or concerning the performance or obligations of you and us, shall be resolved by mandatory and binding arbitration submitted to JAMS in accordance with its Commercial Arbitration Rules at the request of either us or you pursuant to the following conditions:

• Place of Arbitration Hearings. Unless you elect to conduct the arbitration by telephone or written submission, an in-person arbitration hearing will conducted at a JAMS facility in your area or at a JAMS facility in New York, New York.
• Selection of Arbitrator shall be made pursuant to JAMS’ Streamlined Arbitration Rules & Procedures or JAMS’ Comprehensive Arbitration Rules & Procedures, depending on the amount of the claim as specified herein.
• Conduct of Arbitration. The arbitration shall be conducted by a single neutral arbitrator under JAMS’ Streamlined Arbitration Rules & Procedures. For claims exceeding $5,000.00, the arbitration shall be conducted under JAMS’ Comprehensive Arbitration Rules & Procedures Subject to the applicable JAMS procedure, the arbitrator shall allow reasonable discovery in the forms permitted by the Federal Rules of Civil Procedure, to the extent consistent with the purpose of the arbitration. The arbitrator(s) shall have no power or authority to amend or disregard any provision of this section or any other provision of these Terms of Service, except as necessary to comply with JAMS’ Policy on Consumer Arbitrations Pursuant to Pre-Dispute Clauses Minimum Standards of Procedural Fairness. The arbitration hearing shall be commenced promptly and conducted expeditiously. If more than one day is necessary, the arbitration hearing shall be conducted on consecutive days unless otherwise agreed in writing by the parties.
• Findings and Conclusions. The arbitrator(s) shall, after reaching judgment and award, prepare and distribute to the parties written findings of fact and conclusions of law relevant to such judgment and award and containing an opinion setting forth the reasons for the giving or denial of any award. The award of the arbitrator(s) shall be final and binding on the parties, and judgment thereon may be entered in a court of competent jurisdiction.
• Costs and Fees. You will be subject to a filing fee, set by JAMS, to initiate the arbitration. To the extent permitted by JAMS procedures, each party shall bear its own costs and expenses and an equal share of the arbitrators’ and administrative fees of arbitration, and we will remain responsible for its share of costs, expenses and fees plus any costs, expenses and fees required under JAMS procedures.
• Litigation. The Federal Arbitration Act and federal arbitration law apply to these Terms. Either party also may, without waiving any remedy under these Terms, seek from any court having jurisdiction any interim or provisional relief that is necessary to protect the rights or property of that party, pending the establishment of the arbitral tribunal (or pending the arbitral tribunal’s determination of the merits of the controversy).

Class-Action Waiver

Any arbitration, claim or other proceedings by or between you and us shall be conducted on an individual basis and not in any class action, mass action, or on a consolidated or representative basis. You further agree that the arbitrator shall have no authority to award class-wide relief or to combine or aggregate similar claims or unrelated transactions. You acknowledge and agree that this agreement specifically prohibits you from commencing arbitration proceedings as a representative of others. If for any reason a claim proceeds in court rather than in arbitration, each party waives any right to a jury trial. Any claim that all or part of this Class Action Waiver is unenforceable, unconscionable, void, or voidable may be determined only by a court of competent jurisdiction and not by an arbitrator.

CHILDREN

We do not knowingly permit persons under 18 years of age to use the Sites, and we do not knowingly collect, use or disclose Personal Information from anyone under 18 years of age. If we determine upon collection of Personal Information that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian's consent. If we become aware that we have unknowingly collected Personal Information from a child under the age of 18, we will make reasonable efforts to delete such information from our records.

CONFIDENTIAL INFORMATION

We do not want you to send to us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to us will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to you. However, we will not use your name unless we are required by law to identify the source of the materials, information, suggestions, ideas or comments, or unless we first obtain your permission.

ASSIGNMENT

We may freely assign this Privacy Policy or any of our rights and/or obligations hereunder to any successor.

CONTACT

If you have any questions about your privacy or security at the Sites, or wish to update your Personal Information, please send an email to privacy@aerin.com

DATE LAST MODIFIED: July 14, 2020

The following applies to you only if you are a California resident.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit an email request to the following email address: privacy@aerin.com and include the words “CALIFORNIA PRIVACY” in the subject line, and you must put the statement “Your California Privacy Rights” in the body of the request and state the name of our specific website with respect to which you are requesting the information as well as your name, street address, city, state, and zip code.

Please note the following:

• Users can visit the Sites anonymously without providing their Personal Information, but we may collect Personal Information, such as IP addressed, automatically through the use of cookies or other tracking technologies;
• We will add a link to this Privacy Notice on our home page, or at a minimum, on the first significant page after entering the Sites;
• Our Privacy Policy link includes the word “Privacy” and can be easily be found on the page specified above;
• Users will be notified of any privacy policy changes on our Privacy Policy page;
• Users are able to change their Personal Information by emailing us, by calling us, or updating their Personal Information in their online accounts with us;
• Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. Because uniform standards for “Do Not Track” signals have not yet been adopted, we do not process or respond to such signals in users’ web browsers at this time; and
• We allow the collection of users’ behavioral tracking by third parties for analytical purposes and to deliver advertisements to you regarding our products.

Your Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides consumers who are California residents with specific rights regarding their Personal Information.

Right to Know About Personal Information Collected, Disclosed, or Sold

As a California consumer, you have a right to request what Personal Information we collect, use, disclose, and sell.

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request as described below, we will disclose to you:

• The categories of Personal Information we collected about you
• The categories of the sources for the Personal Information we collected about you
• Our business or commercial purpose(s) for collecting or selling that Personal Information.
• The categories of third parties with whom we shared that Personal Information.
• The specific pieces of Personal information we collected about you

In addition, if we sold or disclosed your Personal Information to third parties, we will provide you with two separate lists disclosing:

• Disclosures for a business purpose, identifying the Personal Information categories disclosed that each category of recipient; and
• Sales and/or disclosures for a commercial purpose, identifying the Personal Information categories that each category of each category of recipient.

Right to Request Deletion of Personal Information

As a California consumer, you have the right to request that we delete any or all of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request to delete your Personal Information if retaining the Personal Information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
• Debug products to identify and repair errors that impair existing intended functionality
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
• Comply with a legal obligation
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Right to Opt-Out of the Sale of Personal Information

As a California consumer, you have the right to opt-out of the sale of your Personal Information. Under our understanding of the CCPA, we do not sell your Personal Information.

Right to Non-Discrimination if You Exercise any of Your Rights

As a California consumer, you have the right not to be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your California rights, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights to Know and to Delete

To exercise your rights to know and/or to delete described above, please submit a verifiable consumer request to us by either:

• Calling us at 866-647-3330
• Emailing us at privacy@aerin.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with your Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We will confirm receipt of your verifiable consumer request within ten (10) business days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding our receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is useable and should allow you to transmit the information from one entity to another entity.

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

Information We Collect From California Consumers

We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal Information does not include:

• Publicly available information that is lawfully made from federal, state, or local government records
• Deidentified or aggregated consumer information
• Medical information or protected health information governed by California and federal health information privacy laws
• Clinical trial information subject to the Federal Policy for the Protection of Human Subjects (the Common Rule)
• Personal information regulated by the Fair Credit Reporting Act (FCRA)

Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers. Some of the categories may overlap with each other:

Category of Personal Information	Examples	Collected
A. Identifiers	A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number	YES
B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e))	All of the Identifiers listed above, plus: Bank account number, credit card number, debit card number, or any other financial information through our third party payment processors	YES
	Signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, medical information, or health insurance information	NO
C. Legally Protected Characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	NO
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	YES
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or similar network activity	Browsing history, search history, information regarding a consumer's interaction with a website, mobile application, or online advertisement	YES
G. Geolocation data	Physical location or movements	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
I. Employment information	Professional or employment-related information	NO
J. Education information, defined as nonpublic personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
K. Inferences drawn of other categories of Personal Information	A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	NO

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from our Users. For example, from information that you provide to us through our online forms, email, or other means

Indirectly from activity on our Sites. For example, from website usage details collected automatically

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to fulfill your product order
• To provide you with information, products or services that you request from us
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us , including for billing and collections
• To improve our Sites and present the contents to you
• For testing, research, analysis and product/service development
• As necessary or appropriate to protect the rights, property or safety of us, our Users, or others
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
• As described to you when collecting your Personal Information or as otherwise set forth in the California Consumer Privacy Act (CCPA)
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred

We may also use or disclose the Personal Information we collect for the following commercial purpose: to advance our commercial or economic interests, such as by inducing another 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

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

Sharing Personal Information

We may disclose your Personal Information to a third party for a business and/or commercial purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories
• Category D: Commercial information
• Category F: Internet activity
• Category G: Geolocation Data

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a commercial purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories
• Category D: Commercial information
• Category F: Internet activity

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates.
• Our service providers
• Third parties to whom you authorize us to disclose your Personal Information in connection with products or services we provide to you

products or services we provide to you In the preceding twelve (12) months, we have not sold any Personal Information as we understand the meaning of “sale” under the CCPA.

Grievances and Complaints

Under California Civil Code Section 1789.3, residents of California who use this Website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at dca@dca.ca.gov.

Contact for More Information

If you have any questions or concerns about our Privacy Policy or this Notice regarding your privacy or Personal Information, please contact us at privacy@aerin.com

Date last updated: July, 14, 2020