Privacy Policy

1. OUR APPROACH TO PRIVACY

Effective Date: February 3, 2023

a) This Privacy Policy sets out how Universal Standard Inc. ("Universal Standard", "we", "our" or "us") collects, stores, processes, transfers, discloses and uses your information, our use of cookies and similar technologies, and your rights and choices with respect to our data practices.

b) We operate an e-commerce platform, which we make available through our website www.universalstandard.com (our "Website").

c) This Privacy Policy applies to our Website and to our US stores (together, the "Service") and any other offline or online location that make this Privacy Policy available to you. Please ensure that you have read this Privacy Policy and our Terms of Service and understand how we collect, store, use and disclose your information, both online and offline through the Service. If you do not agree with our data practices, discontinue use of the Service.

d) Some regions provide additional rights by law. For region-specific terms, please see below.

· California

· Nevada

· Virginia

· European Economic Area, Switzerland, and United Kingdom

2. INFORMATION WE COLLECT FROM YOU WHEN YOU USE THE SERVICE

a) We collect information that you voluntarily submit directly to us when you use the Service. This includes information you provide to us when you set up an account on the Website, fill in a form on the Website, purchase a product, interact with us in-store, correspond with us by phone, participate in a promotion, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of the Website.

b) The categories of information we collect include:

i. Contact Data, including your first and last name, email address, postal address, and phone number.

ii. Account Credentials, including your username, password, password hints, and information for authentication and account access.

iii. Demographic Data, including your age, gender, and country.

iv. Payment Data, including your payment instrument number (such as credit or debit card number), expiration date, and security code as necessary to process your payment.

v. Profile Data, including your interests, inferences, preferences and favorites.

vi. Content, including when you contact us directly, content within any messages you send us (such as feedback and questions to customer support) or publicly post on the Service (such as a product review), and information you provide when you voluntarily participate in a promotion, survey, or other marketing event.

vii. Personal Contacts Data, including the first and last name, email address, and phone number of your personal contacts. We collect data about your contacts with your consent and to fulfill a request by you, such as finding your contacts on the Service or inviting your contacts to join the Service. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.

c) If you choose not to provide such information, we may not be able to provide certain parts of the Service to you or respond to your other requests.

d) You may choose to voluntarily provide other information to us that we do not request, and in such instances, you are solely responsible for such information.

3. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY

a) We also automatically collect information about you when you access and use the Website. The categories of information we automatically collect include:

i. Service Use Data, including information about the data and time of your transaction on the Service, the purchase channel, products viewed, if you read our emails, how you otherwise engage with us, how frequently you access the Service, how long you use the Service, your referring and exiting pages, the Website pages you visit, the links you click on while on the Service.

ii. Device Data, including type of device, Internet service provider, platform type, device type, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), operating systems, browsers and applications connected to the Service through the device, your mobile network, your IP address and your device’s telephone number (if it has one). When you access our Service from a mobile device, we collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, and mobile device operating system brand and model.

iii. Non-precise Location Data, including approximate device location (such as by analyzing other information, like an IP address or data that indicates a city or postal code level).

We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, file information, and similar tracking technologies. For more information on cookies and other tracking technologies we use and your rights and choices with respect to them, please see Sections 8, 9, 10 and 11 below.

4. INFORMATION FROM OTHER SOURCES

a) We also collect information from other sources. The categories of sources from which we collect information include:

i. Social Networks with which you interact.

ii. Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.

iii. Publicly available sources including information in the public domain.

We link or combine the information you provide and the information we collect automatically with information we get from other sources. This allows us to provide you with a personalized experience regardless of how you interact with the Service.

5. USE OF INFORMATION

a) We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

i. To process any orders that you make using the Service.

ii. To set up and authenticate your account and future account logins.

iii. To tailor how the Website is displayed to you (such as the language displayed).

iv. To deal with enquiries and complaints made by or about you relating to the Service.

v. To communicate with you, including sending service-related communications.

vi. To develop and send advertising, direct marketing, and communications about our and other entities’ products, offers, promotions, rewards, events, and services.

vii. When you voluntarily participate in a promotion, sweepstakes, or contest, including to verify your eligibility and provide and deliver prizes in connection with your entries when applicable.

viii. To conduct research, including focus groups and surveys.

ix. To monitor and analyze trends, usage, and activities.

x. To administer and improve the Service, and other Universal Standard websites, apps, marketing efforts, products, and services.

xi. To operate, maintain and provide the social features and functionalities of the Service.

xii. To address your questions, issues, and concerns.

xiii. To process your payments for products and services available through the Service.

xiv. To send to you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

xv. To prevent and address fraud or suspicious activity in relation to your account and the Service.

xvi. To comply with our legal obligations.

xvii. To fulfill any other purpose at your direction.

xviii. With notice to you and your consent.

xix. To engage in personalized advertising, including Interest-based Advertising.

Notwithstanding the above, we may anonymize and aggregate or de-identify any of the information we collect (so that it does not identify you) for any purpose except as prohibited by law. For more information on your rights and choices regarding how we use information about you, please see Sections 9, 10, 11, and 12.

6. DISCLOSURE OF INFORMATION

a) We disclose your information to the following categories of parties (in accordance with the purposes set out in this Privacy Policy):

i. Service providers. We disclose your information to service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services. To the extent required by law, we contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

ii. Vendors and other parties. We disclose information to vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information.

iii. Partners. We disclose personal information, including contact information and transaction information to our third-party marketing partners for commercial purposes, including, without limitation, in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.

iv. Promotional Partners. We disclose information with other parties to whom we jointly provide events, contests, sweepstakes, or other promotional activities. These partners will usually be clearly identified in the contest rules or promotional materials. When you voluntarily enter a promotion, we disclose information as set out in the official rules or additional terms that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list for sweepstakes and contests). By entering a promotion, you agree to the official rules or additional terms that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.

v. Product Reviews. We disclose information you make public through the Service when you submit a review of our products. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Additional Rights and Choices” section below.

vi. Business transactions. We disclose your information to other parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.

vii. Law enforcement, regulators and for other legal reasons. We disclose information as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Universal Standard, its users or others.

viii. Facilitating Requests. We disclose information at your request or direction.

ix. Consent. We disclose information with notice to you and your consent.

Notwithstanding the above, we may disclose information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we disclose information about you, please see Sections 8-11 below.

7. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

a) Security. We implement appropriate technical and organizational measures designed to protect your information against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

b) International Transfers. We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that the information we collect may be transferred to, processed, used, and stored in the U.S. and other jurisdictions outside your country of residence. If you are accessing our Website from the European Economic Area ("EEA"), your information will be processed outside of the EEA, including in the United States. For personal data transferred from Europe, we will ensure that: (i) the personal data is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.

8. COOKIES AND SIMILAR TECHNOLOGIES USED ON OUR WEBSITE

a) Cookies (small data files stored on your device) and similar technologies such as pixels (code embedded in a website, video, email, or advertisement) and Local Storage Objects (LSOs), like HTML5, (together "cookies") to distinguish you from other users of our Service. This helps us to provide you with a good experience when you browse our Website and also allows us to monitor and analyze how users interact with our Website so that we can continue to improve our Website. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you advertisements both on and off the Service.

b) Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site operators should in response to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or respond to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com. If you are a California resident, please visit the “Additional Disclosures for California Residents” section below for details on how to exercise your right to opt-out of sales or sharing through preference signals.

c) We use the following types of tracking technologies:

i. Session cookies. These are cookies that are required for the operation of our Website and expire when you close your browser. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services. These are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

ii. Persistent cookies. They allow us to personalize your experience, remember your preferences, and support security features. They also allow us to bring you advertising on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

iii. Log files. These are files that record events that occur in connection with your use of the Service.

iv. Pixels. Pixels are code embedded in a website, video, email, or advertisement that send information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels (e.g., the Facebook SDK) from separate entities that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality.

v. Device Fingerprinting. This allows us to analyze and combine sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

9. TRACKING TECHNOLOGIES USED IN OUR EMAILS

a) Our emails contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

b) Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

10. ANALYTICS AND INTEREST-BASED ADVERTISING

a) We participate in interest-based advertising and use agencies, advertising companies, ad networks, and other technology services to serve you targeted advertisements based on your browsing history and use of the Service. We may, or permit other parties to incorporate tracking technologies into our Service (including our Website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may collect information about your use of the Website over time and services so that they may play or display ads on the Website, on other websites, apps or services you may use (including Facebook), and on other devices you may use (“Interest-based Advertising”).

b) We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Service, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

c) We use analytics services, such as Google Analytics. These services enable us to understand how users access and use the Service. You may control your advertising preferences or opt-out of certain Google Analytics products by visiting the Google Ads Preferences Manager, at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.

d) To opt out of us uploading your data as part of a customer list for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of Matched Ads. We will remove your data from any subsequent lists shared with other parties for purposes of Matched Ads. Alternatively, you may directly contact the applicable party to opt out.

e) You can control interest-based advertising on a particular device through the settings on your device by selecting "limit ad tracking" (iOS) or "opt out of interest based ads" (Android). You also opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.

f) To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:

i. the Network Advertising Initiative’s online resources, at https://www.networkadvertising.org/choices;

ii. the DAA’s resources at www.aboutads.info/choices; and/or

iii. Your Online Choices at www.youronlinechoices.eu.

g) Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

h) Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.

i) Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.

11. MAILING CAMPAIGNS AND TRACKING TECHNOLOGIES

a) From time to time, we use information collected in accordance with the practices described in this Privacy Policy to send promotions via direct mail, such as through the use of postcards and catalogs (“Mailers”).

b) Universal Standard may engage and work with vendors and other parties to collect your email address and device information via cookies and tracking technologies when you visit our Service. These parties may combine your email address and device information with other information they have access to, such as mailing address, so that Universal Standard may serve relevant Mailers to you.

c) You may opt-out of receiving Mailers from us by using our Online Form or emailing us at the email address set out in the “Contacting Us” section below.

12. ADDITIONAL RIGHTS AND CHOICES

a) Profile and Account Information. You may update your profile and account information, such as your contact information, change some of your data sharing preferences by accessing your Account page on the Website.

b) Emails. You can stop receiving promotional email communications from us by clicking on the unsubscribe link provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

c) Text Messages. You can opt-out of receiving text messages at any time by texting “STOP” in response to any text message you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of text messages.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

d) Right to Know, Correct, and Delete. You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:

i. The categories of personal information we have collected about you;

ii. The categories of sources from which the personal information was collected;

iii. The categories of personal information about you we disclosed for a business purpose or sold or shared;

iv. The categories of third parties to whom the personal information was disclosed for a business purpose or sold or shared;

v. The business or commercial purpose for collecting or selling or sharing the personal information; and

vi. The specific pieces of personal information we have collected about you

In addition, you have the right to correct or delete the personal information we have collected from you; provided that a applicable legal exception does not apply. For example, we may not honor your request to delete if the personal information is necessary to complete a transaction with you, detect security incidents, comply with a legal obligation, or for internal use in a lawful manner compatible with the context in which you provided the personal information.

To exercise any of these rights, please submit a request through our Online Form or call our toll free number at 844-394-8587. Please note these rights are subject to exceptions. If you have an account with us, we may require you to use the account to submit the request. 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 10 days and respond to your request within 45 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. In the same manner, we will notify you if for any other reason we are unable to comply with your request to know or delete.

e) Right to Opt-Out. To the extent the we sell or share your personal information as the term “sell” or “share” is defined under applicable state law, 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 clicking Do Not Sell My Personal Information or emailing us at legal@universalstandard.net.

In addition, you may exercise this right by turning on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension.

When you submit an opt-out, your opt-out will only apply to sales and shares of personal information through tracking technologies form the specific browser from which you submitted the opt-out because the connection between your browser identifiers and other personal information we have about you is not known to us. Opt-outs also apply to any pseudonymous profiles we maintain associated with your browser or device. If you want the opt-out to also apply to other personal information we have about you (such as your contact information), please use the link and provide your contact information as requested or make sure you are logged into your account when submitting the opt-out.

f) Region-Specific Rights. In addition to these tights and choices, you may have rights based on your region. For region-specific terms, please see the relevant sections at the end of this Privacy Policy.

13. OTHER PARTIES

a) The Service contains links to and from websites, platforms, and services operated or controlled by other parties, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates.

b) Some examples include:

i. Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.

ii. Brand Pages. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Universal Standard in a tweet or post), we may use your reference on or in connection with our Service.

iii. If you follow a link or interact with other parties, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own privacy policies and practices. We do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those parties.

14. OUR POLICY TOWARDS CHILDREN

The Service is not directed at persons under 18. We do not knowingly collect or solicit personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If we learn that we have collected personal information, or if you are a parent or guardian and you believe that we have collected personal information, in violation of COPPA , please contact us at legal@universalstandard.net.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we may provide you with additional notice to your email address. Changes to this Privacy Policy are effective when they are posted on this page.

16. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.

17. CONTACTING US

a) Please contact us at legal@universalstandard.net if you have any questions or comments regarding this Privacy Policy:

i. By email: legal@universalstandard.net

ii. By mail: Universal Standard Inc., Attn: Legal, 625 Broadway, Fl 4, New York, NY 10012

b) This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at legal@universalstandard.net.

18. ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at legal@universalstandard.net.

19. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 as replaced by the California Privacy Rights Act (“CPRA”) provides additional rights to know, delete, correct, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

a) Notice of Collection. In the past 12 months, we have collected the following categories of personal information enumerated in the CPRA:

i. Identifiers, including name, postal address, email address, and online identifiers (such as IP address).

ii. Customer records, including phone number, billing address, and credit or debit card information.

iii. Characteristics of protected classifications under California or federal law, including gender.

iv. Commercial or transactions information, including records of products or services purchased, obtained, or considered.

v. Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.

vi. Non-precise Geolocation data.

vii. Inferences drawn from the above information about your predicted characteristics and preferences.

For further details on information we collect, including the sources from which we receive information, review the collection of information sections above. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to manage our Service. We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above. Please visit those sections for further details.

To the extent “sale” or “share” under the CPRA is interpreted to include the activities set out in this Privacy Policy, such as those disclosed in the “Analytics and Interest Based Advertising” section above, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, non-precise geolocation data, and inferences drawn. Please review the “Disclosure of Information” section above for further details about the categories of parties to whom we disclose information. For details on your rights regarding sales and shares, please see the “Right to Opt-Out” section below.

We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.

b) Right to Know, Correct, and Delete

You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:

i. The categories of personal information we have collected about you;

ii. The categories of sources from which the personal information was collected;

iii. The categories of personal information about you we disclosed for a business purpose or sold or shared;

iv. The categories of third parties to whom the personal information was disclosed for a business purpose or sold or shared;

v. The business or commercial purpose for collecting or selling or sharing the personal information; and

vi. The specific pieces of personal information we have collected about you.

In addition, you have the right to correct or delete the personal information we have collected from you; provided that a CPRA exception does not apply. For example, we may not honor your request to delete if the personal information is necessary to complete a transaction with you, detect security incidents, comply with a legal obligation, or for internal use in a lawful manner compatible with the context in which you provided the personal information.

c) Right to Opt-Out

To the extent the we sell or share your personal information as the term “sell” or “share” is defined under the CPRA, 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 clicking Do Not Sell My Personal Information or emailing us at legal@universalstandard.net.

In addition, you may exercise this right by turning on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension.

d) Authorized Agent

You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and verify your identity directly.

e) Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

f) Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us 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 write us at the email or postal address set out in “Contact Us” above and specify that 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.

g) Retention

We retain each category of personal information for the length of time reasonably necessary for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

20. ADDITIONAL DISCLOSURES FOR VIRGINIA RESIDENTS

These additional rights and disclosures apply only to Virginia residents. Terms have the meaning ascribed to them in the Virginia Consumer Data Protection Act (“VCDPA”).

You have the following rights under the VCDPA:

· To confirm whether or not we are processing your personal data

· To access your personal data

· To correct inaccuracies in your personal data

· To delete your personal data

· To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format

· To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you

To exercise any of these rights, please submit through this Online Form. We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request.

If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at legal@universalstandard.net and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

21. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE

These additional disclosures and rights apply only to individuals located in the EEA, Switzerland, or the United Kingdom (collectively, “Europe”). Terms have the meaning ascribed to them in the General Data Protection Regulation (“GDPR”).

a) Who is Responsible for the Use of Your Personal Data?

i. Universal Standard is the controller of the personal information we hold about you in connection with your use of the Service. This means that we determine and are responsible for how your personal information is used.

b) Lawful Basis for Processing

i. Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.

c) How Long Will We Store Your Personal Data?

i. We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.

ii. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

d) You have the following rights in respect of your personal data that we hold:

i. Right of access. The right to obtain access to your personal data along with certain related information.

ii. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

iii. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.

iv. Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.

v. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

vi. Right to withdraw consent. If you have provided consent for the processing of your personal data, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

e) You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case.

f) If you wish to exercise one of these rights, please submit through this Online Form.

g) You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here.

h) Privacy Shield. Universal Standard complies with the EU–U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, United Kingdom and Switzerland to the United States, respectively. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov. Universal Standard recognizes that the Court of Justice of the European Union invalidated Privacy Shield, and Universal Standard will continue to use appropriate safeguards to protect personal data from the European Union, United Kingdom, and Switzerland.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Universal Standard is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, Universal Standard may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Universal Standard commits to resolve complaints about your privacy and our collection or use of your personal data where transferred to the United States pursuant to Privacy Shield. If you have any questions about this Statement or the personal data that we collect from you in reliance on Privacy Shield, please contact us at the information provided in Section 17 of the Privacy Policy.

Though we do not rely on Privacy Shield, when transferring personal data to certain third parties (as described in our Privacy Policy), we will take reasonable and appropriate steps to ensure the third party processes personal data for limited and specified purposes and in a manner consistent with Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage.

In the event that you are concerned about how personal data you have provided to Universal Standard has been transferred in reliance on Privacy Shield, please address your inquiry or complaint first to us at the address listed in Section 17 of the Privacy Policy. Universal Standard shall endeavor to reply within 45 days of receiving a complaint regarding personal data transferred in reliance on Privacy Shield. If we fail to respond within that time, or if our response does not adequately address your concerns, you may submit your complaint free of charge to JAMS, our designated Privacy Shield dispute resolution provider, using this link: https://www.jamsadr.com/eu-us-privacy-shield.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

To learn more about the Privacy Shield Framework, and to view Universal Standard’s certification, please visit https://www.privacyshield.gov.