1. OVERVIEW

1.1 Welcome to the websites, applications and services provided by Confidento, Inc., a UK corporation (on behalf of itself and its subsidiaries, "Confidento, Inc."), which include without limitation www.confidento.com and store.confidento.com (the “Sites”).
1.2 This policy is based on our goal to provide our visitors with quality information and resources while maintaining personal privacy. Please forward any comments you may have regarding this policy to [email protected].
1.3 By visiting the Sites, registering with us or contacting us, you signify that you understand and agree to the collection, use and transfer of your information under the terms of this policy. If you do not accept, or do not wish to be bound by this policy, please do not use the Sites.
1.4 If you are a California resident or data subject in Europe, please see the “Additional Disclosures for California Residents” and “Additional Disclosures for People in Europe” in Sections 16 and 17, respectively. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

2. INFORMATION WE COLLECT FROM YOU

2.1 When you access our Sites, we collect and in the last 12 months we have collected the types of information, described in Sections 3 through 5 below entitled "access information," "contact information" and " information from other sources.”

3. ACCESS INFORMATION

3.1 We may collect information about your computer, including where available your geographic location, IP address, operating system and browser type, device type, bandwidth, etc. for system administration and to report aggregate information to our advertisers.
3.2 We may also keep details of your visits to our Sites including, but not limited to, traffic data, location data, weblogs and other communication data, time spent on the Sites, number of pages viewed, referring web pages, the resources that you access and the date and time of access, etc. To the extent this information can identify you directly, or indirectly when combined with other information, it will be subject to this privacy policy.
3.3 Our Sites use cookies, web beacons, and other technologies in order to provide you with an improved browsing experience; and to allow us to improve our Sites and to serve targeted advertising. We may collect advertising information, including but not limited to, type of ads seen, number of times ads were served, pages where the ads were served, etc. When you first access the Sites, depending on your location, you may receive a message advising you that cookies and similar technologies are in use.

4. CONTACT INFORMATION

4.1 You may also give us information about you by filling in forms on the Sites. This includes information you provide when you register to use our Sites, subscribe to our services, participate in discussion boards or other social media functions on our Sites, enter a competition, promotion or survey and when you report a problem with our Sites. The information you give us may include your name, shipping and billing address, e-mail address and phone number, financial and credit card information, personal description and photograph. 4.2 You can also create an account on our Sites and subscribe to our services using your social media profile. When creating an account on our site directly, you may provide or be provided specific information necessary for such account like a password. In the event that you are given (or where you have chosen) a password which enables you to access certain parts of the Sites, you are responsible for keeping this password confidential. You must not share a password with anyone. If you subscribe to our service using your social media profile, we will automatically collect selected information about you from your social media account. The information we collect depends on your social media privacy settings for sharing such personal data, and may include name, profile picture, age range, gender, language, country and other public information.

5. THIRD PARTY INFORMATION

5.1 We may also receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with other parties (including, for example, business partners, affiliates, sub-contractors in technical, payment and delivery services, search information providers, credit reference agencies, social networks, advertising networks, advertising exchanges, data management platforms, content recommendation platforms and analytics providers) and may receive information about you from them. Depending on its nature, this information from other sources will either be "access information" or "contact information", as described below.

6. THE WAY WE USE INFORMATION

6.1 We collect and use your information for business and commercial purposes in accordance with the terms of our privacy policy in effect at the time of our use. Our business and commercial purposes for collecting and using information, including in the last 12 months are:
6.1.1 Providing and managing the Site and services, including: (a) providing you with access; (b) customizing your experience; (c) allowing you to participate in panels, events, sweepstakes, and contests; and (d) analytics;
6.1.2 Administrative purposes, including: (a) bug detection and error reporting; (b) auditing user interactions; (c) fraud and security monitoring; and (d) complying with legal obligations;
6.1.3 Delivering advertising, including online tracking and advertising (See our Cookies Policy for additional information);
6.1.4 Working with service providers, affiliates, and partners;
6.1.5 Developing new products and services; and
6.1.6 Otherwise with your consent or at your direction.
6.2 We may also share your personal information as we believe is necessary or appropriate to comply with applicable law or legal process or to protect, enforce, or defend the legal rights, privacy, safety, or property of the Sites and services, our employees, agents or users.
6.3 Your "access information" is used to route the requested web page to your computer or mobile device for viewing. It enables us to provide you with access to our Sites. We use this information in line with our legitimate interests to administer our Sites and for internal operations, including troubleshooting, data analysis, site analysis, testing, research, statistical and survey purposes, to improve our Sites, to ensure that content is presented in the most effective manner for you and for your device, to allow you to participate in interactive features of our services, when you choose to do so, as part of our efforts to keep our Sites safe and secure; to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, and where you have provided your consent, to make suggestions and recommendations to you about goods or services that may interest you;
6.4 Your "contact information" enables us to operate and manage the Sites, provide services to you, or information tailored more specifically to your needs, or to forward your message or enquiry to another entity that is better able to do so. As such, it may enable us or our selected partners to contact you, for example, to respond to a query you have submitted to us. We will also use and analyze the information we collect so that we can administer, support, improve and develop our business, customer service and the features of our Sites and our services generally;
6.5 The information we receive from other sources will be combined with access information and/or contact information. We will use the combined information for the purposes set out above;
6.6 We will use the information you provide to us to contact you by email, telephone, and/or post to notify you occasionally about important changes or developments to the Sites. Where you have provided the appropriate form of consent, we may also use your information to let you know by email, telephone, and/or post about other goods and services which we, or our selected partners, offer which may be of interest to you; and 6.7 We will ask you to give your consent to the use of your personal data for marketing purposes, and to provide you with information about our goods and services, or those of other parties, which we believe, may be of interest to you. If you change your mind about being contacted by selected parties or us, please click "unsubscribe" from any emails received.
6.8 With your opt-in consent, we may also permit selected parties to use your information, to provide you with information about goods and services which may be of interest to you. We or they may contact you about these by email.

7. DISCLOSURE OF YOUR INFORMATION

7.1 We share your information as described in this privacy policy. The types of entities to whom we disclose and have shared information with in the last 12 months, include the following: 7.1.1 members of our group, which means our subsidiaries, affiliates, our ultimate holding company and its subsidiaries and affiliates. We share information with these group members for our business purposes such as marketing and technical operations, and commercial purposes; 7.1.2 business partners, suppliers and sub-contractors who require access to personal data to assist in the performance of any contract we enter into with them or you; 7.1.3 trusted companies and individuals to perform functions in certain situations on our behalf or our service providers. These functions include cloud storage providers, email services, providing marketing assistance and data analysis, handling transactions, fulfilling orders and providing customer service and credit referencing. These agents have access to information in order to perform their functions but may not use, retain or disclose it for any purpose other than to perform the services; 7.1.4 analytics and search engine providers that assist us in the improvement and optimization of our Sites; 7.1.5 vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below; and 7.1.6 others companies with notice to you and your consent. 7.2 We may also disclose your information to other parties: 7.2.1 where we are required to do so by law; 7.2.2 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or 7.2.3 to exchange other information with other companies and organizations for fraud protection and credit risk reduction.

8. ANALYTICS AND ADVERTISING

8.1 We and other parties use analytics services, such as Google Analytics, to help us understand how users access and use the Sites. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
8.2 As part of this process, we may incorporate tracking technologies into our own Sites (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
8.3 Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics 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/.
8.4 The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
8.5 Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. 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.

9. PROVIDING INFORMATION IS YOUR CHOICE

9.1 There is no legal requirement for you to provide any information at our Sites. However, our Sites will not work without certain "access information" described above. Failure of your browser to accept "cookies" will not prevent your use of our Sites but may prevent certain features from working.
9.2 For any "contact information" that is requested on a Site, failure to provide the requested information will mean that the particular feature or service associated with that part of the Site may not be available to you.
9.3 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 and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

10. HOW LONG WE STORE YOUR INFORMATION

10.1 We will only retain your information, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your information as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. In line with this policy, we will either securely delete or anonymize your personal data so that it cannot be linked back to you.

11. DATA SECURITY

11.1 The transmission of information via the internet is not completely secure. Although we will do our best to protect your information and implement appropriate technical and organisational security measures, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access. To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate safeguards to secure the information we collect online, consistent with the policies of Confidento, Inc. and industry standards.
11.2 Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

12. EMAIL POLICY

12.1 Confidento, Inc. offers email newsletters. If you no longer wish to receive emails, follow the "unsubscribe" instructions located near the bottom of each newsletter.

13. CHILDREN UNDER 16

13. 1 The Sites are not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Sites. Confidento, Inc. does not knowingly target advertising to, or collect information from, children under the age of 16. If you are under 16, do not use or provide any information on the Sites or on or through any of its features, register on the Sites, use any of the interactive or public comment features on the Sites, or provide any information about yourself to us, including your name, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected]. We also do not knowingly “sell” the personal information of minors under 16 years old who are California residents.

14. CHANGES TO THIS PRIVACY POLICY

We reserve the right to edit and reissue this policy at any time. Any changes will be effective immediately upon posting of the revised policy. Your continued use of our Sites indicates your consent to the privacy policy then posted. Please check this policy regularly for any changes. If the changes are material, we may provide you additional notice to your email address.

15. CONTACT US

15.1 Should you have other questions or concerns about our privacy policies and practices, please contact us at [email protected].
15.2 If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at [email protected].

16. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

16.1 These additional disclosures and rights for California residents apply only to individuals who reside in California beginning January 1, 2024. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
16.2 In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:
16.2.1 Identifiers - including name, email address, phone number, account name, IP address, and an ID or number assigned to your account.
16.2.2 Customer records - billing and shipping address, and credit or debit card information.
16.2.3 Demographics - such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
16.2.4 Commercial information - including purchases and engagement with the Sites and/or services.
16.2.5 Internet activity - including your interactions with our Sites and/or services.
16.2.6 Geolocation data - including location enabled services such as WiFi and GPS.
16.2.7 Employment and education data - including information you provide when you apply for a job with us.
16.2.8 Inferences - including information about your interests, preferences and favorites.
16.3 For more information on information we collect, including the sources we receive information from, review the “Information We Collect From You” in Section 2 and as further detailed in Sections 3 through 5 . We collect and use these categories of personal information for the business purposes described in section 6 entitled “The Way We Use Your Information” (Section 6), including to provide and manage our Sites.
16.4 Confidento, Inc. does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the “Analytics and Advertising” section as a “sale,” we will comply with applicable law as to such activity. Confidento, Inc. discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Sites. Please review the “Disclosure of Your Information” section for more detail about the parties we have shared information with.
16.5 If you are a California resident, you have the right to delete the personal information we have collected from you and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
16.5.1 The categories of personal information we have collected about you;
16.5.2 The categories of sources from which the personal information was collected;
16.5.3 The categories of personal information about you we disclosed for a business purpose or sold;
16.5.4 The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
16.5.5 The business or commercial purpose for collecting or selling the personal information; and;
16.5.6 The specific pieces of personal information we have collected about you.
16.6 To exercise any of these rights, please submit a request through our online form available at here, or 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 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.
To the extent Confidento, Inc. sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, 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 the “CA Do Not Sell My Info” link in the footer of the Site. You may also submit a request to opt-out by emailing us at [email protected].
16.7 You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. 16.8 You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
16.9 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.

17. ADDITIONAL DISCLOSURES FOR PEOPLE IN EUROPE

17.1 This Section 17 only applies to individuals within the European Economic Area (“EEA”). Under Europe’s General Data Protection Regulation (“GDPR”), in certain circumstances, you have the right to (a) request access to any personal data we hold about you and related information, (b) obtain without undue delay the rectification of any inaccurate personal data, (c) request that your personal data is deleted provided the personal data is not required by us for compliance with a legal obligation under European or Member State law or for the establishment, exercise or defence of a legal claim, (d) prevent or restrict processing of your personal data, except to the extent processing is required for the establishment, exercise or defence of legal claims; and (e) request transfer of your personal data directly to a third party where this is technically feasible.
17.2 In addition, where you believe that we have not complied with its obligation under this privacy policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner's Office.
17.3 If you would like to exercise any of these rights, please email us at [email protected].
17.4 We collect and use your information for business and commercial purposes in accordance with the terms of our privacy policy in effect at the time of your use. Our business and commercial purposes for collecting and using information, including in the last 12 months, include where: (a) you have provided your consent which can be withdrawn at any time; (b) the processing is necessary to facilitate your request such as for the performance of a contract to which you are a party or to perform services you have requested; (c) we are required by law, (d) where processing is required, to protect your vital interests or those of another person; or (e) the processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by your rights and interests.
17.5 For personal data from the European Union or the EAA:
17.5.1 We will only transfer your personal data to trusted third-parties who provide sufficient security guarantees and who demonstrate a commitment to compliance with applicable law and this privacy policy.
17.5.2 We will not transfer personal data originating from the EEA to third parties located outside of the EU without ensuring adequate protection under European law.
17.5.3 Where transfer is to a third party is located in a country not recognized by the EU Commission as ensuring an adequate level of protection, we will take appropriate steps to refrain from such transfer unless such transfer meets any exceptions set forth in the GDPR (such as EU/US Privacy Shield).