As an organization, COWRIECROWD LLC respects your privacy and cares about safeguarding your personal data. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it. As you read our Notice, please keep in mind that it applies to all COWRIECROWD LLC’s entities. If you reside outside of the USA, UK and the European Economic Area (the “EEA”), accessing and using any of COWRIECROWD LLC’s Services means that you accept the terms and obligations of COWRIECROWD LLC’s privacy statement. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions by sending us an email at corporate@cowriecrowd.com or submitting a request through the “Contact Us” form on our website.

Who Is Collecting It?

Any personal data provided to or collected by COWRIECROWD LLC is controlled by COWRIECROWD LLC, the data controller. This Privacy Notice applies to personal data collected by COWRIECROWD LLC in connection with the services and products we offer. References to “COWRIECROWD LLC” in this Notice means COWRIECROWD LLC and any company directly or indirectly owned and/or controlled by COWRIECROWD LLC that you are interacting with or have a business relationship with.

What legal basis do we have to collect your data?

Our legal basis for processing your data:

1. Your consent.
2. Our contractual obligations to process orders you have purchased.
3. Our legal obligations to keep our records.
4. Our legitimate interest We may use the information to improve our products and services and from time to time to contact you or market research purposes by email phone fax or mail. The acquired information will be used to tailor the website according to your interests. Additionally we may also send promotional emails about new products special offers or other information which we think you may find interesting using the email address which you have provided if you have chosen to opt into this. However our legitimate interest will never prevail over your interests fundamental rights or freedoms.

What personal Data is being collected?

Personal data means any information that can be used to identify directly or indirectly a specific individual. You are not required to provide COWRIECROWD LLC the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

We may collect personal data from a variety of sources. This includes:

• Personal data you give us directly
• Personal data we collect automatically and
• Personal data we collect from other sources.

The personal data we may collect from you includes:

• contact details you provide to us by filling in contact forms on the website or any other information submitted to us via the websiteemail.
• records of correspondence whether via the Website email telephone or other means
• details of the transactions you carry out with us whether via the Website telephone or other means
• details of your visits to the Website including but not limited to traffic data location data weblogs and other communication data
• your responses to surveys or market research that we carry out.

You are not required to provide COWRIECROWD LLC the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

How do we collect your personal data?

We may collect personal data from a variety of sources. This includes:

Personal data you give us directly.

• We collect data about how you use our services and products such as the types of content you view or engage with or the frequency and duration of your activities. We also collect personal data you provide us when you sign up for a marketing newsletter complete a survey or register for an account with us. In so doing we may ask for personal data such as your name gender date of birth address email address telephone number etc. COWRIECROWD LLC may collect special categories of personal data about you with your explicit consent. For more information on the special categories of data we collect and how we use it please refer to the relevant section below.

Personal data we collect from other sources.

• We collect personal data from other sources including our trusted partnerships with third parties and where we operate COWRIECROWD LLC accounts on thirdparty platforms. Additionally we receive information about you and other visitors interactions with our advertising to measure whether our advertising is relevant and successful.

When and why we collect “special categories of personal data”

Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under the European data protection legislation. COWRIECROWD LLC limits the circumstances where we collect and process these special categories of data.

How do we protect children’s privacy?

We understand the importance of taking extra precautions to protect the privacy and safety of children online. COWRIECROWD LLC ’s websites are designed and intended for use by adults. If we discover that we have inadvertently collected personal data from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that personal data as soon as practical. We sometimes use your personal data to carry out age verification checks and enforce age restrictions.

What Purpose Do We Use Your Data For?

We collect, process and disclose your personal data only for specific and limited purposes. For example, to process your payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products, communications and targeted advertising as well as product recommendations to you.

Additionally, COWRIECROWD LLC processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.

We collect, process and disclose your personal data for the following purposes:

• To provide you with your order status deal with your enquiries and requests and assess and handle any complaints
• To process and answer your inquiries or to contact you to answer your questions andor requests
• To develop and improve our products services communication methods and the functionality of our websites
• To communicate information to you and to manage your registration andor subscription to our newsletter or other communications
• To authenticate the identity of individuals contacting us by telephone electronic means or otherwise
• To understand and assess the interests wants and changing needs of consumers to improve our website our current products and services andor developing new products and services and

Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

In some cases, we rely on legitimate interest for processing your personal data This ground will only be used where it is necessary to achieve a legitimate interest, for example to assist in the performance of a contract, or to optimize a service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this, and you have the right to ask for this information.

We process your personal data to perform a contract to which you are or will be a party.

We also process your personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing. For example, a court order or a subpoena may require us to process personal data for a particular purpose, or we may be compelled to process personal data to report suspicious transactions under the local anti-money laundering rules.

• COWRIECROWD LLC collects data, with your consent, from:
  • Our websites about what you view and the way you interact with our content
  • Our digital display advertising that we serve to you on social platforms and other publishers websites and
  • Forms you fill in online and send to us about what your interests are.
• We also track the products you buy when you click on one of our display adverts and go on to purchase something from a selection of our retail partners.

Who do we share your personal data with?

COWRIECROWD LLC shares your personal data within the COWRIECROWD LLC Group and with selected third parties in the following circumstances:

• Thirdparty service providers. In order to carry out your requests respond to your inquiries fulfil your orders or make various other features services and materials available to you through our websites we share your personal data with thirdparty service providers that perform functions on our behalf such as companies that host or operate COWRIECROWD LLC s websites process payments analyze data provide customer service postal or delivery services and sponsors or other thirdparties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations.
• Other third parties. Your personal data will also be used by us or shared with our sponsors advertisers advertising networks advertising servers social media networks and analytics companies or other third parties in connection with marketing promotional data enrichment and other offers as well as product information.

• Legal disclosure. We may transfer and disclose your personal data to third parties
  • To comply with a legal obligation
  • When we believe in good faith that an applicable law requires it
  • At the request of governmental authorities conducting an investigation
  • To verify or enforce our Terms of Use or other applicable policies
  • To detect and protect against fraud or any technical or security vulnerabilities
  • To respond to an emergency or otherwise
  • To protect the rights property safety or security of thirdparties visitors to COWRIECROWD LLC s websites COWRIECROWD LLC or the public.

International data transfers

COWRIECROWD LLC will not transfer your personal data outside the EU without your specific consent, unless required by the Law.

How Do We Protect Your Personal Data?

COWRIECROWD LLC takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure.

Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymize and anonymize personal data wherever possible.

Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third parties.

How Long Do We Keep Your Personal Data For?

We will keep your personal data for as long as we need it for the purpose it is being processed for.

Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.

We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.

We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.

What Are Your Rights?

Your rights in relation to your personal data how it is processed. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email or submitting a request through the “Contact Us” form on our websites.

Where we process your personal data, you have a number of rights over how the data is processed and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email or submitting a request through the “Contact Us” form on our websites.

• The right to be informed. You have the right to be provided with clear transparent and easily understandable information about how we use your personal data and your rights. Therefore were providing you with the information in this Notice.
• The right to access and rectification. You have the right to access correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights please contact us.
• The right to data portability. The personal data you have provided us with may be portable. This means it can be moved copied or transmitted electronically under certain circumstances.
• The right to be forgotten. Under certain circumstances you have right to request that we delete your data. If you wish to delete the personal data we hold about you please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it we will do what we can to delete destroy or permanently deidentify it.
• The right to restrict processing. Under certain circumstances you have the right to restrict the processing of your personal data.
• The right to object. Under certain circumstances you have the right to object to certain types of processing including processing for direct marketing (i.e. receiving emails from us notifying you or being contacted with varying potential opportunities).
• The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e. we rely on consent as a legal basis for processing your personal data) you have the right to withdraw your consent at any time (although if you do so it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided below.

Further information and advice about your rights can be obtained from the data protection Regulator in your Country.

How Do You Contact COWRIECROWD LLC ?

COWRIECROWD LLC nominated the Chief Privacy Officer who can be contacted at (include address) United States of America, Massachusetts or by email corporate@cowriecrowd.com.

If you have any questions or concerns about COWRIECROWD LLC ’s Privacy Notice or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an email corporate@cowriecrowd.com or submitting a request through the “Contact Us” form on our website.

How Do We Keep This Notice Up To Date?

We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will also keep prior versions of this Privacy Notice in an archive for your review.

We will not reduce your rights under this Privacy Notice without your consent.