Eltara Casata by Radmila Lolly, LLC (“Company”, “we”, “us” or “our”) and its subsidiaries, parents and affiliated companies respects the privacy of its users (“User” or “you”) that use our website located at www.eltaracasata.com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website” or “Site”, as context may require).

The following privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that the Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the end of this document) and review any changes since the last time you used the Website. This Privacy Policy is expressly incorporated into our Terms of Use.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

From time to time, we may want to contact you with information about announcements, Website updates, and special offers. We also may want to contact you with information about products and services from our business partners. You may opt out of such communications at any time by clicking the “unsubscribe” link found within the Company’s emails and changing your contact preferences. If you have a User Account on our Website you may continue to receive transactional messages related to our services, even if you unsubscribe from promotional emails.

For EEA users: We only send marketing communications to users located in the EEA with your prior consent. Please see the section “For EEA users” below.

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally

“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, the Company gathers from users of the Website Non-Personally Identifying Information of the sort that web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website, as more fully described herein. Although such information is not Personally Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company may analyze Non-Personally Identifying Information gathered from users of the Website to help the Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

User Content

We also may any collect User Content. “User Content” is defined as all text, documents, or other content or information uploaded, entered, or otherwise transmitted by you to us in connection with your use of the Website.

Automatically Collected Information

Certain data about the devices you use to connect with our Website and your use of the Website are automatically logged in our systems, including:

Mobile Device Information. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

Log data. As with most websites and technology services delivered over the internet, our servers automatically collect data when you access or use our Website and record it in log files. This log data may include the IP address, browser type and settings, the date and time of use, information about browser configuration, language preferences, and cookie data.

Usage information. This is information about the Website and how you use it. We may also obtain data from our third-party partners and service providers to analyze how users use our Website. For example, we will know how many users access a specific page on the Website and which links they clicked on. We use this aggregated information to better understand and optimize the Site.

Device information. These are data from your computer or mobile device, such as the type of hardware and software you are using (for example, your operating system and browser type), as well as unique device identifiers for devices that are using our software.

Web Cookies. Data obtained from cookies are described below and in our Cookie Policy.

Web Cookies

Web Cookies are small text files stored on your device and used by web browsers to deliver personalized content and remember logins and User Account settings. The Company uses Web Cookies and similar technologies, including tracking pixels and web beacons, to collect usage and analytic data that helps us provide our Website to you, as well as to help deliver ads for relevant products and services to you when you visit certain pages on the Website and then visit certain third-party sites.

WEBSITE USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally Identifying Information. They are a technique that the Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

Analytics

We may use third-party vendors, including Google, who use first-party Web Cookies (such as the Google Analytics cookie) and third-party Web Cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads). More information on Web Cookies can be found in our Web Cookie Policy.

Aggregated and Non-Personally Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

Additional Terms for Mobile Device Users

A.    Geo-Location Information.

Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for Company to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.

B.    Push Notifications.

We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

C.    Mobile Analytics.

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally Identifying Information you submit within the mobile application.

Social Media

We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Instagram’s “follow” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated, and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So, for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites or applications of these social networks and are not within our control.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION

Website Registration

As defined above, Personally Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally Identifying Information from and about Website users. Much of the Personally Identifying Information collected by Company about users is information provided by users themselves when (1) registering for a User Account with the Website, (2) logging in with social network credentials, (3) communicating with us, or (4) signing up to our mailing list. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by the Company from time to time. Users of the Website are under no obligation to provide Company with Personally Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features. BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Company Communications

We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the Website. Generally, you may opt out of such emails at the time of registration or through your User Account settings, if available, though we reserve the right to send you notices about your User Account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.

Company Disclosures

Company will disclose Personally Identifying Information under the following circumstances:

A.    By Law or to Protect Rights.

When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

B.    Marketing Communications.

Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your User Account settings (if applicable) or contacting us using the contact information below.

C.    Third-Party Service Providers.

We may share your Personally Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.

D.   Business Transfers; Bankruptcy.

Company reserves the right to transfer all Personally Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally, Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Changing Personally Identifying Information; Account Termination

You may at any time review or change your Personally Identifying Information by going to your User Account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your User Account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your User Account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your User Account settings (if applicable) or contact us as provided below. We will retain in our files some Personally Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your User Account.

General Use

The Company uses the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website (1) to deliver the products and services that you have requested; (2) to manage your User Account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to develop and display content and advertising tailored to your interests on the Website and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our goods and services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.

Collection and Use of Information by Third Parties Generally

Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally Identifying Information received from Company, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets and a variety of other third-party applications accessible through the Website. Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.

Security

We take the security of your Personally Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology. Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our software installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Website and services.

We are dedicated to protecting all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your User Account. If you lose control of your User Account, you should notify us immediately.

PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your User Account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information when changes go into effect.

PRIVACY POLICY CHANGES

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a user of the Website or has otherwise transferred Personally Identifying Information to the Website, please contact Company using our contact information below to have that child’s User Account terminated and information deleted.

NOTICE TO NEVADA RESIDENTS

Nevada law allows consumers to direct certain businesses not to sell their personally identifiable information collected on a business’s platform or other online service to third parties to license or sell that information to additional third parties. If you are a Nevada resident, you may submit such opt-out requests by email at [email protected]. To be effective, your request must include your full name, address, phone number, and email address to verify the authenticity of your request.

ADDITIONAL RIGHTS AND CHOICES FOR CALIFORNIA RESIDENTS

If you are a California resident, the following additional rights may be available to you.

Shine the Light

Customers who are California residents may request (i) a list of categories of personal information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please send us an email or a letter to the addresses in the section entitled “Contact Us” below and specify you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

California Consumer Privacy Act of 2018 (CCPA)

Beginning January 1, 2020, the CCPA provides California residents with additional rights as described below. Please note your right to know and right to delete are subject to certain exceptions under the CCPA.

Notice of Collection

During the past twelve (12) months, we have collected the following categories of personal information that the CCPA covers:

• Identifiers, including name, email address, date of birth, phone number, User Account name, IP address, and an ID or number assigned to your User Account.
• Consumer records, billing and delivery address, and credit or debit card information.
• Commercial information, including purchases and engagement with our Website and mobile applications.
• Internet activity, including your interactions with our Website and mobile applications.
• Audio data, including information collected for customer care quality assurance.
• Geolocation data, including location enabled services such as GPS.
• Inferences, including information about your interests, preferences and favorites.
• This privacy statement includes additional information about our data practices. For more information on information we collect, including the sources we receive information from, review this Privacy Policy in its entirety. We collect and use these categories of personal information for the business purposes described herein, including to provide and manage our Website.

Right to Know

You have the right to know certain information about our data practices in the preceding twelve (12) months. You have the right to request the following information from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or “selling” the personal information; and
• The specific pieces of personal information we have collected about you.

Right to Delete

You have the right to request the deletion of personal information that we collect or maintain about you and your User Account.

Right to Opt-Out of “Sale”

Company does not sell information as the term “sell” is traditionally understood. However, Company may disclose certain information about you when you use our Services for purposes that may be considered a “sale” under the CCPA. For example, we may disclose information to advertising partners, advertising technology companies, and companies that perform advertising-related services in order to provide you with more relevant advertising tailored to your interests. This information may include identifiers such as your IP address, advertising identifiers, commercial information, your internet or other electronic network information such as your interaction with an ad, geolocation data and inferences. To the extent Company sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by contacting us as further set forth below.

How to Exercise Your CCPA Rights

To exercise any of these rights, please email us at [email protected]. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those difference are reasonable related to your information.

Please note that if you opt out of receiving marketing communications from us, we may still send communications to you about your transactions, any User Accounts you have with us, and any contests, competitions, prize draws or sweepstakes you have entered. Opting out of one form of communication does not mean you’ve opted out of other forms as well.  For example, if you opt out of receiving marketing emails, you may still receive marketing text messages if you’ve opted in to receiving them.

If you wish to exercise any of the rights set above, please contact us at [email protected], or at the address below.  We will need you to provide specific information to help us confirm your identity.  This is a security measure to help ensure that your personal information is not disclosed to someone that does not have the right to receive it.

FOR EEA USERS

Individuals located in the European Economic Area (EEA) have certain rights in respect to their personal information, including the right to access, correct, or delete Personally Identifying Information we process through your use of the Website and/or services. If you’re a user based in the EEA, you can:

• Request a Personally Identifying Information report by submitting a request to [email protected]. This report will include the Personally Identifying Information we have about you, provided to you in a structured, commonly used, and portable format. You must be signed into your user Account to submit this request. Please note that the Company may request additional information from you to verify your identity before we disclose any information.
• Have your Personally Identifying Information corrected or deleted. Some Personally Identifying Information can be updated by you: You can update your name and email address, as well as language preference, through your user Account settings. If you registered for the Website using Google or Facebook, or if you otherwise have problems updating this information, please contact us. You can remove your Personally Identifying Information from the Website by deleting your user Account.
• Object to us processing your Personally Identifying Information. You can ask us to stop using your Personally Identifying Information, including when we use your Personally Identifying Information to send you marketing emails. We only send marketing communications to users located in the EEA with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within our emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our Website, even if you unsubscribe from marketing emails.
• Complain to a regulator. If you are based in the EEA and believe that we have not complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.

DO-NOT-TRACK-POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.

Last Updated: April 15, 2020