Privacy Policy

Thank you for visiting civilpleasures.com, an onlineservice (e.g., website) owned and operated by Civil Pleasures, Inc.(referred to herein as “Company,” “we”, or “our”) and thatposts a link to this Notice (“Service”). This Notice will provide youwith information about how Company collects, uses, and shares information aboutyou, including the choices Company offers with respect to that information.This Notice applies to your use of any Service, regardless of how you access oruse it. For certain Services, there may be additional notices about informationpractices and choices. Please read those additional privacy disclosures tounderstand how they apply to you.By visiting or otherwise using the Service, you agreeto the Service’s Terms of Service to Company’s data collection, use, anddisclosure practices, and other activities as described in this Notice, and anyadditional privacy statements that may be posted on an applicable part of theService. If you do not agree to our practices described in this Notice, pleasediscontinue the use of our Service, and uninstall Service.

1. INFORMATION WE COLLECT AND USE.

a. Information that You Provide.

Company, and/or its Service Providers (defined below), maycollect information you provide directly to Company and/or its ServiceProviders via the Service. For example, Company collects information when youuse or register for the Service, subscribe to notifications, post on theService, participate in promotional activities, or communicate or transactthrough the Service. In addition, when you interact with Third-Party Services(defined below), you may be able to provide information to those third parties.For more information on how and why we share your information with thirdparties and service providers, please see the section of this Notice titled “InformationWe Share With Third Parties.”

We may collect Personal Information from you for thefollowing purposes:

· Account Creation andManagement: To process yourregistration, manage your account, upload your User Generated Content (“UGC”),confirm your age to allow you to use the Service, confirm your veteran statusfor discounts, or otherwise manage your interactions and transactions, we maycollect your name; home address; IP address; purchasing tendencies; records ofproducts or services considered; records of products or services purchased;personal email; postal address; billing address; contact details; date ofbirth; phone number; work email; and military veteran status;

· Communications andTransactions: When we processinteractions and transactions, including when we transact with you, provideservices or information you request, respond to your comments, questions andrequests, serve you content and/or advertising, and send you notices, we maycollect your account name; full name; home address; personal email; postaladdress; billing address; city; state; credit card number; and debit cardnumber;

· Marketing: For the Company’s and Affiliates’ marketing andother purposes, we may collect information about your purchasing transactions;records of products or services considered; records of products or servicespurchased; geolocation (by default, general location based on IP address, orprecise geolocation if enabled); social media contact; age; attitudes;behavior; characteristics; predispositions; account name; full name; homeaddress; personal email; postal address; subscriber identification number;unique personal identifier; account age; account number; credit card number;date of birth; phone numbers; work email; age; marital status; gender identityand gender expression; and military or veteran status; Account Creation andManagement: To process your registration, manage your account and/orupload your UGC, we may collect your date of birth; storepreference; device information, email address, and social media contact(s); and

· Business WholesaleLicense Documents: If you interact with uson behalf of a business, we may collect your account name; full name; username;account number; billing address; city; credit card number; and phone numbers toconfirm your company’s license to operate in a given state; and

· Leases: If you interact with us on behalf of a business witha commercial lease, we may collect your full name; home address; postaladdress; signature; account number; bank account information; routing number;company/entity; job title/role; office location; and work email to fulfill ourcontractual obligations.

Sometimes we will de-identify Personal Information byremoving or modifying the personally identifiable elements or extractingnon-personally identifiable elements so they can’t be associated with a person(“de-identified information”). De-identified information is non-PersonalInformation and may be used and shared without obligation to you, except asprohibited by applicable law. To the extent any non-Personal Information iscombined by or on behalf of Company with Personal Information Company itselfcollects directly from you on the Service, Company will treat the combined dataas described in this Notice.

b. Information Collected Automatically.

Company, its Service Providers, and/or Third-Party Servicesmay also automatically collect certain information about you when you access oruse the Service (“Usage Information”). Usage Information may include IPaddress, device identifier, browser type, operating system, information aboutyour use of the Service, and data regarding network connected hardware (e.g.,computer or mobile device).

The methods that may be used on the Service to collectUsage Information include:

· Log Information. Log information is data about your use of theService, such as IP address, browser type, Internet service provider,referring/exit pages, operating system, date/time stamps, and related data, andmay be stored in log files.

· Information Collected byCookies and Other Tracking Technologies. Cookies,web beacons (also known as “tracking pixels”), embedded scripts,location-identifying technologies, device fingerprinting, device recognitiontechnologies, in-app tracking methods and other tracking technologies now andhereafter developed (“Tracking Technologies”) may be used to collectinformation about interactions with the Service or e-mails, includinginformation about your browsing and purchasing behavior. Here is more detail oftypes of Tracking Technologies:

· Cookies. A cookie is a small text file that is stored on auser’s device, which may be session ID cookies or tracking cookies. Sessioncookies make it easier for you to navigate the Service and expire when youclose your browser. Tracking cookies remain longer and help in understandinghow you use the Service, and enhance your user experience. Cookies may remainon your hard drive for an extended period of time. If you use your browser’smethod of blocking or removing cookies, some but not all types of cookies may bedeleted and/or blocked and as a result some features and functionalities of theService may not work. A Flash cookie (or locally shared object) is a data filewhich may be placed on a device via the Adobe Flash plug-in that may bebuilt-in to or downloaded by you to your device. HTML5 cookies can beprogrammed through HTML5 local storage. Flash cookies and HTML5 cookies arelocally stored on your device other than in the browser and browser settingswon’t control them. To identify certain types of local shared objects on yourdevice and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html . The Service may associate some or all of these types ofcookies with your devices.

· Web Beacons (“TrackingPixels”). Web beacons are small graphic images, also known as“Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Webbeacons may be used, without limitation, to count the number of visitors to theService, to monitor how users navigate the Service, and to count content views.These may also be used to locate (sometimes precisely) you, or make assumptionsabout your location, for purposes such as verifying your location anddelivering or restricting content based on your location. If you have enabledGPS or use other location-based features on the Service, your device locationmay be tracked.

· Embedded Scripts. An embedded script is programming code designed to collectinformation about your interactions with the Service. It is temporarilydownloaded onto your computer from Company’s web server, or from a third-partywith which Company works, and is active only while you are connected to theService, and deleted or deactivated thereafter.

· DeviceFingerprinting. Collection and analysisof information from your device, such as, without limitation, your operatingsystem, plug-ins, system fonts, and other data, for purposes of identificationand/or tracking.

· Device RecognitionTechnologies. Technologies, including applicationof statistical probability to data sets, as well as linking a common uniqueidentifier to different device use (e.g., Facebook ID), which attempt torecognize or make assumptions about users and devices (e.g., that a userof multiple devices is the same user or household) (“Cross-device Data”).

· In-App Tracking Methods. There are a variety of Tracking Technologies that may beincluded in mobile applications, and these are not browser-based like cookiesand cannot be controlled by browser settings. Some use device identifiers, orother identifiers such as “Ad IDs” to associate app user activity to aparticular app and to track user activity across apps and/or devices.

Some information about your use of the Service and certainThird-Party Services may be collected using Tracking Technologies across timeand services, and used by Company and third parties for purposes such as toassociate different devices you use, and deliver relevant ads and/or othercontent to you on the Service and certain Third-Party Services.

Company may use any or all of the Usage Informationdetailed above for the following purposes:

· Online Experience: To facilitate, manage, personalize, and improve your onlineexperience and for research and development;

· Account Creation andManagement: To process yourregistration, manage your account and/or upload your UGC;

· Rewards: To use loyalty points to generate monetary rewards;

· Marketing Sales andAnalytics: To perform analytics on your experiences with us inorder to provide more personalized experiences and advertisements, and toimprove our products and services; and

· Debugging: To fix any technical issues that arise in the course ofproviding the Service.

c. Information Company Collects From Other Sources.

Company may also obtain information about you from othersources, including Service Providers and Third-Party Services, and combine thatwith Personal Information. We may use information collected from ServiceProviders and Third Parties for the following purposes:

· Communications andTransactions: When we transact withyou, provide services or information you request, respond to your comments,questions and requests, serve you content and/or advertising, and send younotices, we may collect your name; address; phone number; IP address; emailaddress; chat logs; and social media contact(s);

· Marketing: For the Company’s and Affiliates’ marketing and otherpurposes, we may collect your name; email address; social media contact; visualinformation (e.g., videos); alias; and username;

· Account Creation andManagement: To process yourregistration, manage your account and/or upload your UGC, we maycollect your date of birth; store preference; device information, emailaddress, and social media contact(s); and

· Debugging: To fix any technical issues that arise in the course ofproviding the Service.

d. Third-Party Content, Third-Party Services, SocialFeatures, Advertising and Analytics.

Third-Party Services. TheService may include hyperlinks to, or include on or in connection with, theService (e.g., apps and plug-ins), websites, locations, platforms,applications or services operated by third parties (“Third-Party Service(s)”).These Third-Party Services may use their own cookies, web beacons, and otherTracking Technology to independently collect information about you and maysolicit Personal Information from you.

Social Features. Certainfunctionalities on the Service permit interactions that you initiate betweenthe Service and certain Third-Party Services, such as third-party socialnetworks ( “Social Features”). Examples of Social Features include:enabling you to send content such as contacts and photos between the Serviceand a Third-Party Service; “liking” or “sharing” Company’s content; logging into the Service using your Third-Party Service account (e.g., usingFacebook Connect to sign-in to the Service); and to otherwise connect theService to a Third-Party Service (e.g., to pull or push information toor from the Service). If you use Social Features, and potentially otherThird-Party Services, information you post or provide access to may be publiclydisplayed on the Service or by the Third-Party Service that you use. Similarly,if you post information on a Third-Party Service that references the Service (e.g.,by using a hashtag associated with Company or other Company Affiliates in atweet or status update), your post may be used on or in connection with theService or otherwise by Company and Company Affiliates. Also, both Company andthe third-party may have access to certain information about you and your useof the Service and any Third-Party Service.

Interest-Based Advertising. Company may engage and work with Service Providers andother third parties to serve advertisements on the Service and/or onthird-party services. Some of these ads may be tailored to your interest basedon your browsing of the Service and elsewhere on the internet, sometimesreferred to as “interest-based advertising” and “online behavioral advertising”(“Interest-based Advertising”), which may include sending you an ad on athird-party service after you have left the Service (i.e.,“retargeting”). To update your cookie preferences, please click here.

Analytics. Companymay use Google Analytics, Adobe Analytics or other Service Providers foranalytics services. These analytics services may use cookies and other TrackingTechnologies to help Company analyze Service users and how they use theService. Information generated by these services (e.g., your IP addressand other Usage Information) may be transmitted to and stored by these ServiceProviders on servers in the U.S. (or elsewhere) and these Service Providers mayuse this information for purposes such as evaluating your use of the Service,compiling statistic reports on the Service’s activity, and providing otherservices relating to Service activity and other Internet usage.

Third Party Practices. Informationcollected, stored, and shared by third parties remains subject to their privacypolicies and practices, including whether they continue to share informationwith Company, the types of information shared, and your choices on what isvisible to others on Third-Party Services.

Company is not responsible for and makes no representationsregarding the policies or business practices of any third parties, including,without limitation, analytics Service Providers and Third-Party Servicesassociated with the Service, and encourages you to familiarize yourself withand consult their privacy notices and terms of use.

e. Other Purposes.

We may also use any of the information we listed above forthe following purposes:

Internal Purposes: Improve the Service and for any other internal business purposes reasonably related to providing the Service;
Tailored Content: Tailor our content, advertisements, and offers;
Other Disclosed Purposes: Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so;
Territory Restrictions: Determine your location and manage digital content rights (e.g., territory restrictions);
Security; Fraud Detection; Safety: Improve the safety and reliability of the Service, and detection, prevention and response to fraud, breaches of policies or terms, security risks and threats or harm; and
Legal Requirements: To comply with legal process such as a search warrant, subpoena or court order, or if requested by regulatory agencies with authority over the tobacco industry such as the Food and Drug Administration.

2. INFORMATION WE SHARE WITH THIRD PARTIES.

As noted above, Company may share non-Personal Information,and De-Identified Information with third parties, or Company and theiraffiliates (“Affiliates”) for any purpose, as long as the information isnot associated with an identifiable person. When information is associated withan identifiable person, it is considered Personal Information, and Company mayshare Personal Information for the following reasons:

Affiliates: We may share your Personal Information with our affiliates and subsidiaries if we need to, in order to maintain our business and provide products and services to you. If we share your information, we will share only the information that is necessary and we will take reasonable steps to make sure that third parties take prudent steps to protect your information.
Marketing: We may share your Personal Information to deliver marketing communications to you. Absent your consent (which may be by means of opt-in, or a third-party interaction described in the next bullet point), however, Company will not share your Personal Information with third parties, other than Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
Your Disclosure or Agreement: Your activities on the Service may, by their nature, result in the sharing of your Personal Information (as well as your non-Personal Information) with third parties and by engaging in these activities you agree to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third-party, not Company.
Service Providers: Company’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including, without limitation, Personal Information and Usage Information, in connection with their work on Company’s behalf, provided however, Company does not authorize its Service Providers to use Personal Information provided by Company to the Service Providers to send you direct marketing messages other than related to Company and Company Affiliates beyond what is needed to assist Company;
External Auditors: For its own internal business purposes as well as its compliance obligations under the laws, Company must allow external auditors to access and evaluate certain information to perform their audit function;
External Agencies: Company is required by law to make certain reports to external agencies in order to operate within the bounds of the law and the industry regulations that apply to the Company;
Trade Customers: If you are making a purchase from the Company on behalf of your employer, we will share your information with your employer as needed to complete the transaction;
Legal Obligations: To comply with the law, law enforcement or other legal process, and in response to a government request (including, without limitation, Food and Drug Administration and other regulatory agency inquiries and requests);
Defending and Protecting Rights: If Company believes your actions are inconsistent with Company’s terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Company, the Service or its users, or any third-party;
Corporate Transactions: In addition, Company may share your Personal Information and your non-Personal Information in connection with or during negotiations of any proposed or actual merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Company assets, or transfer of all or a portion of Company’s business to another company (“Corporate Transactions”);
Sweepstakes, Contests, and Promotions: Company may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to Company, Company Affiliates, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law ( e.g. , on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include agreeing to additional or differing data practices from those contained in this Notice. Please review those rules carefully;
Information You Disclose to Others; Social Networks: The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Company. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Information included in UGC is not subject to Company’s usage or sharing limitations, or other obligations, regarding Personal Information or other Personal Information under this Notice or otherwise, and may be used and shared by Company and third parties to the fullest extent not prohibited by applicable law. Company encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service’s Terms of Use click here.
Additionally, the Service may offer you the option to send a communication to a friend. If so, Company relies on you to only send to people who are at least twenty-one (21) years of age and who have given you permission to do so. The friend’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Company for any other marketing purpose unless Company obtains agreement from that person. Your contact information and message may be included in the communication.

3. DATA SECURITY AND MONITORING.

Company takes reasonable measures to protect PersonalInformation (excluding UGC) from loss, theft, misuse and unauthorized access,disclosure, alteration, and destruction. Nevertheless, transmission via theinternet and online digital storage are not completely secure and Companycannot guarantee the security of your information collected through theService.

To help protect you and others, Company and its ServiceProviders may (but make no commitment to) monitor use of the Service, and maycollect and use related information including Personal Information for allpurposes not prohibited by applicable law or inconsistent with this Notice,including, without limitation, to identify fraudulent activities andtransactions; prevent abuse of and investigate and/or seek prosecution for anypotential threats to or misuse of the Service; ensure compliance with the Termsof Service and this Notice; investigate violations of or enforce theseagreements; and otherwise to protect the rights and property of Company,Company Affiliates, third parties, and other users. Monitoring may result inthe collection, recording, and analysis of online activity or communicationsthrough our Service. If you do not consent to these conditions, you mustdiscontinue your use of the Service.

4. CHOICES: SELLING, TRACKING AND COMMUNICATIONSOPTIONS.

a. Tracking Technologies Generally.

Regular cookies may generally be disabled or removed bytools available as part of most commercial browsers, and in some instancesblocked in the future by selecting certain settings. Browsers offer differentfunctionalities and options so you may need to set them separately. Also, toolsfrom commercial browsers may not be effective with regard to Flash cookies(also known as locally shared objects), HTML5 cookies, or other TrackingTechnologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html . Please be aware that if you disable or remove thesetechnologies, some parts of the Service may not work and that when you revisitthe Service your ability to limit browser-based Tracking Technologies issubject to your browser settings and limitations.

Some app-related Tracking Technologies in connection withnon-browser usage (e.g., most functionality of a mobile app) can only bedisabled by uninstalling the app. To uninstall an app, follow the instructionsfrom your operating system or handset manufacturer.

b. "Do Not Track" Signals

Your browser settings may allow you to automaticallytransmit a “Do Not Track” signal to online services you visit. Note, however,there is no consensus among industry participants as to what “Do Not Track”means in this context. Like many online services, Company currently does notalter Company’s practices when Company receives a “Do Not Track” signal from avisitor’s browser.

c. Analytics and Advertising Tracking Technologies.

You may exercise choices regarding the use of cookies fromGoogle Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out BrowserAdd-on.

You may choose whether to receive some Interest-basedAdvertising by submitting opt-outs. Some of the advertisers and ServiceProviders that perform advertising-related services for us and third partiesmay participate in the Digital Advertising Alliance’s (“DAA”)Self-Regulatory Program for Online Behavioral Advertising. To learn more abouthow you can exercise certain choices regarding Interest-based Advertising,visit http://www.aboutads.info/choices/ , and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobileapps. Some of these companies may also be members of the Network AdvertisingInitiative (“NAI”). To learn more about the NAI and your opt-out optionsfor their members, see http://www.networkadvertising.org/choices/ . Please be aware that, even if you are able to opt out ofcertain kinds of Interest-based Advertising, you may continue to receive othertypes of ads. Opting out only means that those selected members should nolonger deliver certain Interest-based Advertising to you, but does not mean youwill no longer receive any targeted content and/or ads (e.g., from otherad networks). Also, if your browsers are configured to reject cookies when youvisit these opt-out webpages, or you subsequently erase your cookies, use of adifferent device or web browsers or use a non-browser-based method of access (e.g.,mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, beeffective. Company supports the ad industry’s 2009Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf) and expects that ad networks Company directly engages toserve you Interest-based Advertising will do so as well, though Company cannotguarantee their compliance. Company is not responsible for effectiveness of, orcompliance with, any third-parties’ opt-out options or programs or the accuracyof their statements regarding their programs.

d. Communications.

You can opt out of receiving certain promotionalcommunications from Company at any time by following the instructions providedin e-mails to click on the unsubscribe link, or if available by changing yourcommunication preferences by logging onto your account. Please note that youropt-out is limited to the e-mail address used and will not affect subsequentsubscriptions. If you opt-out of only certain communications, othersubscription communications may continue. Even if you opt out of receiving promotionalcommunications, Company may, subject to applicable law, continue to send younon-promotional communications, such as those about your account, transactions,servicing, or Company’s ongoing business relations.

5. INTERNATIONAL TRANSFER.

Company is based in the U.S. and the information Company,and its Service Providers collect is governed by U.S. law. If you are accessingthe Service from outside of the U.S., please be aware that informationcollected through the Service will be transferred to, processed, stored, andused in the U.S. Data protection laws in the U.S. may be different from thoseof your country of residence. Your use of the Service or provision of anyinformation therefore constitutes your agreement to the transfer to and from,processing, usage, sharing, and storage of your information, including PersonalInformation, in the U.S. as set forth in this Notice.

6. REQUIRED DISCLOSURES.

In certain circumstances, we may choose to or may berequired to provide additional or different disclosures to residents ofdifferent U.S. states. Below are the disclosures that may be applicable to you.

a. “Legal Categories” of Personal Information

Certain laws require us to tell you about the PersonalInformation we collect about you in a certain way – specifically, we need totie it back to “legal categories” of Personal Information that are listed inthe law. To do this, we bundled up the information we gave you above in thisNotice and matched the different types of Personal Information we collect aboutyou with the legal category. To make things easier to understand, we’ve putthis information in a chart that shows you five things:

The legal category of Personal Information,
Examples of the types of Personal Information included in each legal category,
The source from which your Personal Information is collected,
The purpose for why we collect and use your Personal Information for each legal category,
The business purposes for which we share your Personal Information and with whom, and
Whether we sell your Personal Information.

We’ve included these things in the PersonalInformation Privacy Chart at the end of this Notice. At the end of thePersonal Information Privacy Chart, we also included a list of PersonalInformation We Disclose for a Business Purpose and a list of PersonalInformation We Sell.

b. Your Rights and Choices

Some privacy laws require that we disclose to you theprivacy rights that you have regarding Personal Information collected fromand/or about you. We have defined the various privacy rights below. To seewhich rights apply to you, refer to the “Privacy Rights Chart” immediatelyfollowing this subsection.

Know: You may have the right to know what Personal Information is being collected, used, shared, and sold about you, including the categories, sources, and business purposes for collecting your Personal Information.
Access: You may have the right to request access to your Personal Information.
Erase, Delete: You may have the right to request that we delete or erase your Personal Information if we do not have a legal or business reason to keep it.
Correct: You may have the right to correct inaccurate Personal Information we have about you.
Data Portability: You may have the right to obtain Personal Information in a portable and readily usable format.
Opt Out of Sale or Sharing: You may have the right to ask us not to share or sell your Personal Information or use it for purposes of targeted advertising or profiling.
Limit Processing of Sensitive Personal Information: Sensitive Personal Information includes your Social Security number, driver’s license number, state ID card, passport number, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health and genetic data, biometric data, information about a sex life or sexual orientation, a consumer’s account login, 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, the contents of mail, email, and text messages if the business is not the intended recipient. You may have the right to ask us to limit our use of your Sensitive Personal Information to only what is required to accomplish the purposes we included in this privacy notice or that you reasonably expect from us. Our practice is to not process your Sensitive Personal Information except when it is necessary to accomplish the purposes disclosed in this Notice.
Non-Retaliation for Exercising Privacy Rights: You also may have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by applicable law.

These rights may be subject to certain limitations orexceptions depending on your state of residency and the purpose for which weprocess Personal Information about you.

Privacy Rights Chart

Right to Know

Right to Access

Right to Portability

Right to Limit Sensitive Personal Information

Right to Opt Out of the Sale or Sharing

Right to Non-Retaliation

Right to Correction

Right to Deletion

Right to Appeal

California Residents

✓

❌

✓

❌

Texas Residents

✓

❌

✓

Nebraska Residents*

✓

❌

✓

New Jersey Residents*

✓

❌

✓

*Privacy Rights effective January 1, 2025.

Where applicable and technically feasible, Company willaccommodate your valid request to exercise your privacy rights and choices. Youmay also designate an authorized agent to make a request on your behalf.

How to Make a Request : Ifyou would like to make a request, please email jesse@civilpleasures.com You will need to provide your first and last name, emailaddress, home address zip code, request details, the type of request you wantto make, and describe the nature of your relationship with us.

Responding to Requests: Yourrequest will be evaluated to determine whether the requested change meets legalregulatory requirements and does not risk making our other data less secure orchanging our other data. If we aren’t able to honor any part of your request,we will tell you that in our response, as well as the reason(s) we cannot doso.

Verifying Your Identity: Inorder for us to look into your request, we first need to verify your identity,meaning that we need to make sure that you are the consumer we may havecollected Personal Information about or a person who has been duly authorizedto make the request on behalf of the consumer. For example, if you make arequest, we will ask you to confirm your name and email address. For certainrequests, we will use a combination of your email address, name, and/or zipcode to verify your identity, so that we can help protect your information.

Requests by Authorized Agents: Youmay have the right to designate an authorized agent to make a request on yourbehalf. As permitted by California Privacy Law, any request you submit to us issubject to an identification and verification process, and confirmation of theagent’s authority, which may include attestation under penalty of perjury.Absent a power of attorney, we will also require the Consumer to verify theirown identity. We may verify identity based on matching information you providedwith data we have maintained on you in our systems. This data could include,but is not limited to, email address, mailing address, or phone number.

How to Appeal: If we deny yourrequest, you may have the right to appeal. If we have denied your request andyou would like to appeal, please request by emailing jesse@civilpleasures.comYou will need to provide your first and last name, email address, home addresszip code, what type of request you made, the calendar year in which you madeyour request, why you are requesting an appeal and what you are requesting thatwe do.

c. Third Party Marketing and Your Additional CaliforniaPrivacy Rights

Separate from your “Do Not Sell” rights Californiaresidents have the following additional rights regarding disclosure of yourpersonal information to third parties for their own direct marketing purposes:

We provide California residents with the option to opt-into sharing of “personal information” as defined by California’s “Shine theLight” law with third parties, other than with our affiliates, for such thirdparties’ own direct marketing purposes. We do not share personal informationwith non-Affiliate third parties for their direct marketing purposes absentyour consent. If you are a California resident, you may request informationabout our compliance with the Shine the Light law and/or withdraw previouslygiven consent to sharing with non-Affiliate third parties for their directmarketing purposes by sending a letter to us at 447 Broadway, FL 2 #17, NewYork, New York 10013 (Attn: Legal Department). Requests must include“California Marketing Privacy Rights Request” in the first line of thedescription and include your name, street address, city, state, and ZIP code.Please note that we are only required to respond to one request per customereach year, and we are not required to respond to requests made by means otherthan through the provided e-mail address or mailing address.

As these rights and your privacy rights are not the sameand exist under different laws, you must exercise your rights under this lawand the other privacy laws separately.

d. Children's Privacy.

Per our Terms of Service, our online Service is only forindividuals twenty-one (21) years of age and older. Company does not seek to orintentionally collect Personal Information of individuals under twenty-one (21)years of age. If you suspect that an individual using our Service is under theage of 21, please contact Company by email at jesse@civilpleasures.com. We willthen make reasonable good faith efforts to remove the minor’s post fromprospective public view or anonymize it, so the minor cannot be individuallyidentified to the extent required by applicable law. This removal processcannot ensure complete or comprehensive removal. For instance, third partiesmay have republished or archived content by search engines and others that wedo not control.

7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION.

We will only retain your Personal Information for as longas necessary to fulfill the purposes for which we collected it, including forthe purposes of satisfying any legal, accounting, or reporting requirements. Todetermine the appropriate retention period for Personal Information, weconsider the amount, nature, and sensitivity of the Personal Information, thepotential risk of harm from unauthorized use or disclosure of your PersonalInformation, the purposes for which we process your Personal Information andwhether we can achieve those purposes through other means, and the applicablelegal requirements.

We cannot (fully) comply with a request to erase or deleteif we have to retain your Personal Information for certain purposes and for alonger period due to a statutory retention period. After the retention periodhas expired, we will delete your Personal Information.

8. CHANGES TO THIS PRIVACY NOTICE.

We reserve the right to change this Notice prospectivelyeffective upon the posting of the revised Notice and your use of our Serviceindicates your acknowledgement of the Notice posted at the time of use.However, should we update this Notice, we shall post a new version online andupdated the effective date, and where the law requires, we will notify you ifthe Personal Information processed about you will be materially different thanthat which was represented to you at the time it was collected. To the extentany provision of this Notice is found by a competent tribunal to be invalid orunenforceable, such provision shall be severed to the extent necessary for theremainder to be valid and enforceable.

9. CONTACT US.

Civilpleasures.com is owned and operated by CivilPleasures, Inc. If you have any questions about this Notice, please contactCompany by sending a letter to 447, FL 2 #17, New York, New York 10013 (Attn:Legal Department).

10. PERSONAL INFORMATION PRIVACY CHART.

We collect customers’ Personal Information as describedabove for the following purposes, when permissible under applicable law. Inparticular, we collected the following categories of Personal Information fromcustomers within the twelve (12) months preceding the date of thisNotice:

We may also collect information to comply with applicablelaw or regulatory requirements or legal requests.

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