PRIVACY POLICY

Last updated: 10/30/2023

Thank You for joining the Pikolinos family at our Website, www.pikolinos.com. This Privacy Policy explains how we collect, use, disclose, and protect Your information when You use Our Website and tells You about Your privacy rights under the law and our Company policies.

We use Your Personal data to provide you with a great customer experience and to improve the Website and our Company. By using the Website, You agree to the collection and use of information in accordance with this Privacy Policy.

INTERPRETATION AND DEFINITIONS

INTERPRETATION

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

DEFINITIONS

For the purposes of this Privacy Policy:

Account means a unique account created for You to make purchases on our Website or parts of our Website or to sign up for e-mails or contests on our Website.

Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to PIKOLINOS USA CORP. (“PIKOLINOS”), and its affiliates, (6701 NW 7th St UNIT 100, Miami, FL 33126, United States).

Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: United States

Device means any device that can access the Website such as a computer, a smartphone, or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.

Sensitive Personal Information means Personal Information that reveals (1) (A) your social security, driver’s license, state identification card, or passport number; (B) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer’s precise geolocation; (D) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a your mail, email, and text messages unless we are the intended recipients; (F) your genetic data or (2) (A) the processing of biometric information to identify you, or (B) Personal Information collected and analyzed concerning your health, sex life, or sexual orientation. Although We do store your login and password to our website, We do not collect other Sensitive Personal Information and do not collect or store financial information, such as debit or credit card numbers, in combination with your security codes or passwords.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website, to provide the Website on behalf of the Company, to perform services related to the Website or to assist the Company in analyzing how the Website is used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Website.

Usage Data refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).

Website refers to PIKOLINOS

You means the individual accessing or using the Website, or the company, or other legal entity on behalf of which such individual is accessing or using the Website, as applicable.

COLLECTING AND USING YOUR PERSONAL DATA

TYPES OF DATA COLLECTED PERSONAL DATA

While using Our Website, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

•     Email address

•     First name and last name

•     Phone number

•     Address, State, Province, ZIP/Postal code, City

•     Usage Data

USAGE DATA

Usage Data is collected automatically when using the Website.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.

TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on Our Website

and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Website. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Website or may not get the benefit of certain convenience features of our Website. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Website may use Cookies.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling_or_deleting_loc%20al_shared_objects_

• Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: https://www.allaboutcookies.org/manage-cookies/index.html.

We use the following types of cookies in or website:

a.  Technical Cookies: These cookies are necessary to facilitate correct browsing through our website and ensure that the content is loaded efficiently, enabling the correct use of the different options or services provided in it, for example, to carry out the purchase process or control fraud linked to the security of the service.

b.  Analytics Cookies: These cookies allow us to obtain information for statistical analysis of how users use the website. 

c. Customisation Cookies: These cookies allow us to discover users’ preferences in order to improve the services offered. 

d.  Advertising Cookies: These cookies allow us to show you advertising and other content that we believe is best suited to your interests and your digital behaviour.

Depending on the length of time they remain activated on the computer, they will be session cookies (only stored while the website is being accessed) or persistent cookies (stored during the specified time on the information table).

Below is a list of the cookies used at Pikolinos, indicating the type, origin, and purpose, as well as a link so that the user can access the Cookies Policies on different websites of origin

Technical Cookies

Analytics Cookies

Customisation Cookies

Advertising Cookies

Administered by: Us

USE OF YOUR PERSONAL DATA

The Company may use Personal Data for the following purposes:

•     To provide and maintain our Website, including to monitor the usage of our Website.

•     To manage Your Account: to manage Your registration as a user of the Website. The Personal Data You provide can give You access to different functionalities of the Website that are available to You as a registered user.

•     For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Website.

•     To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

•     To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

•     To manage Your requests: To attend and manage Your requests to Us.

•     To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.

•     For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Website users is among the assets transferred.

•     For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of ourpromotional campaigns and to evaluate and improve our Website, products, services, marketing and your experience.

We may share Your personal information in the following situations:

•     With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Website, to advertise on third party websites to You after You visited our Website, for payment processing, to contact You.

•     For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

•     With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and its other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

•     With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.

•     With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and

description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

•     With Your consent: We may disclose Your personal information for any other purpose with Your consent.

PIKOLINOS do not share your personal information in any way.

RETENTION OF YOUR PERSONAL DATA

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Website, or We are legally obligated to retain this data for longer time periods.

After expiry of the applicable retention periods, or maximum after 6 years of no-contact with Pikolinos, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of the data. For more information on retention periods please contact us.

TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

DISCLOSURE OF YOUR PERSONAL DATA

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

•     Comply with a legal obligation

•     Protect and defend the rights or property of the Company Prevent or investigate possible wrongdoing in connection with the Website

•     Protect the personal safety of Users of the Website or the public

•     Protect against legal liability

CONTESTS ON OUR WEBSITE

When you provide information to enter a contest, we may share that information with the contest sponsor or the provider of the contest prize for marketing purposes and prize fulfillment.

SECURITY OF YOUR PERSONAL DATA

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

“In the event of a data breach we will notify you via the email address you provided. If you would prefer to be notified via mail, please email us at rgpd@pikolinos.com.

DETAILED INFORMATION ON T HE PROCESSING OF YOUR PERSONAL DATA

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

ANALYTICS

We may use third-party Service providers to monitor and analyze the use of our Website

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Salesforce commerce Cloud

Their Privacy Policy can be viewed at https://www.salesforce.com/company/legal/agreements/

EMAIL MARKETING

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt- out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. We may use Email Marketing Service Providers to manage and send emails to You.

Selligent – Marigold Engage

Their Privacy Policy can be viewed at https://www.selligent.com/privacy-center/

PAYMENTS

We use third-party services for payment processing.

We do not store Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help

ensure the secure handling of payment information.

A.  Forms of Payment: Visa, Mastercard and American Express.

B.  We use the following third party sites for payment processing.

Paypal through Ayden. Ayden’s disclosure policy can be viewed at Responsible disclosure - Adyen; the link for their privacy policy can be viewed at Privacy Statement - Adyen; link for their cookies policy which can be found at Cookie policy - Adyen

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Klarna Their privacy policy can be viewed at Privacy (klarna.com); and Your California Privacy Choices (klarna.com);

BEHAVIORAL REMARKETING

The Company uses remarketing services to advertise to You after You accessed or visited our Website. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Website so that We can improve our Website to reflect Your interests and serve Youavertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Website in accordance with their Privacy Policies and to enable Us to:

•     Measure and analyze traffic and browsing activity on Our Website

•     Show advertisements for our products and/or services to You on third-party websites or apps

•     Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

•     The NAI's opt-out platform: http://www.networkadvertising.org/choices/

•     The EDAA's opt-out platform http://www.youronlinechoices.com/

•     The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Website with these third-party vendors. This allows Our third- party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below. The third-party vendors We use for Behavioral Remarketing are:

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Bing Ads Remarketing

Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized- ads.

You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in

Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

We use Salesforce for retargeting ads, which appear when you visit websites that are part of Salesforce’s marketing program. Salesforce may use data about your activity on our website to provide personalized advertising relevant to our customers as explained at . Their Privacy Policy can be viewed at https://www.salesforce.com/company/privacy .

You can disable Salesforce Services by going to How To Master Ad Retargeting As A Marketing Tactic - Salesforce Canada Blog or Terms of Service - Salesforce.com

NEVADA PRIVACY

If you are a Nevada resident, even though we do not sell personal information, you still have the right to formally opt-out of the sale of your personal information by submitting a verifiable privacy request. To do so, sign in to your account on this website and click on “Privacy Request Form. Complete the request form and click “Submit”. We will respond to your request within 60 days, although we may extend this to 90 days on notice to you. If you have any difficulty with the “Privacy Request Form” please call us at 1(877)-745-4872.

CCPA PRIVACY

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

CATEGORIES OF PERSONAL INF ORMATION COLLECTED

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered. Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Website or advertisement. Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location. Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

•     Publicly available information from government records

•     Deidentified or aggregated consumer information

•     Information excluded from the CCPA's scope, such as:

o  Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

o  Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

SOURCES OF PERSONAL INFORMATION

We obtain the categories of personal information listed above from the following categories of sources:

•     Directly from You. For example, from the forms You complete on our Website, preferences You express or provide through our Website, or from Your purchases on our Website.

•     Indirectly from You. For example, from observing Your activity on our Website.

•     Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Website.

•     From Service Providers. For example, third-party vendors to monitor and analyze the use of our Website, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third- party vendors that We use to provide the Website to You.

USE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES OR COMMERCIAL PURPOSES

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

•     To operate our Website and provide You with our goods, information, and services.

•     To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Website.

•     To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Website, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.

•     To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

•     As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

•     For internal administrative and auditing purposes.

•     To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

•     Only if you opt-in to our text messaging service, to send you text message advertising.

The examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

DISCLOSURE OF PERSONAL INF ORMATION FOR BUSINESS PURPOSES OR COMMERCIAL PURPO S S

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

•     Category A: Identifiers

•     Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

•     Category D: Commercial information

•     Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.


SALE OF PERSONAL INFORMATION

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

•     Category A: Identifiers

•     Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

•     Category D: Commercial information

•     Category F: Internet or other similar network activity

SHARE OF PERSONAL IN FORMATION

We may share Your personal information identified in the above categories with the following categories of third parties:

-       Search engines.

-       Social media.

-       Website content providers.

SALE OF PERSONAL INFORMATION OF MINORS UNDER 16 YEARS OF AGE

We do not knowingly collect personal information from minors under the age of 16 through our Website, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their

permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal

information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

YOUR RIGHTS UNDER THE CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

•     The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

•     The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of Your personal information. Once We receive and confirm Your request, We will disclose to You:

•     The categories of personal information We collected about You

•     The categories of sources for the personal information We collected about You

•     Our business or commercial purpose for collecting or selling that personal information

•     The categories of third parties with whom We share that personal information

•     The specific pieces of personal information We collected about You

•     If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:

o  The categories of personal information categories sold

o  The categories of personal information categories disclosed

•     The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.

•     The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

o  Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business

relationship with You, or otherwise perform our contract with You.

o  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

o  Debug products to identify and repair errors that impair existing intended functionality.

o  Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

o  Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

o  Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.

o  Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

o  Comply with a legal obligation.

o  Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

•     The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:

o  Denying goods or services to You

o  Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

o  Providing a different level or quality of goods or services to You

o  Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Under the CPRA, you have the following additional rights:

o  The right to correct inaccurate Personal Information. You have the right to direct Us to correct Your personal information to the extent that it is inaccurate. To submit an correction request please contact Us.

o  The right to opt out of sharing data for cross-context behavioral advertising

o  The right to limit use and disclosure of Sensitive Personal Information.

o  The right to opt-out of the use of automated decision making.

EXERCISING YOUR CCPA AND CPRA DATA PROTECTION RIGHTS

In order to exercise any of Your rights under the CCPA and CPRA, and if You are a California resident, You can contact Us using any of the methods below:

o  Calling us at 1(877)745-4872

o  E-mailing[MCMTM6] pikolinosusa@pikolinos.com

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

o  Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative. Requests made by signing into your Account and clicking “Privacy Request Form” on your Account page will be considered verified in most cases.

o  Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with the required information if we cannot:

o  Verify Your identity or authority to make the request

o  And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

DO NOT SELL MY PERSONAL INF ORMATION

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact

Us. We do not sell Your personal information for money, although we may receive a non-monetary benefit from sharing your information.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Website that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal Pikolinos Website Compliance information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

WEBSITE

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Website:

o  The NAI's opt-out platform: http://www.networkadvertising.org/choices/

o  The EDAA's opt-out platform http://www.youronlinechoices.com/

o  The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

o  Criteo’s opt-out page: https://www.criteo.com/privacy/disable-criteo- services-on-internet-browsers/

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

MOBILE DEVICES

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

o  "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

o  "Limit Ad Tracking" on iOS devices

o  Criteo’s opt-out page: https://www.criteo.com/privacy/disable-criteo- services-on-mobile-applications/

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

" DO NOT TRACK " POLICY AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT ( CALOPPA)

Our Website does not respond to Do Not Track signals. We engage in cross-site tracking, which means that after you visit Our Website we may serve you ads on other sites as part of a retargeting campaign.

SENSITIVE PERSONAL INFORMATION

Our Website does not sell or transfer Sensitive Personal Information. The only Sensitive Personal information our site stores is the log-in and password to your account on this site.

CHILDREN' S PRIVACY

Our Website does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

YOUR CALIFORNIA PRIVACY RIGHTS

( CALIFORNIA' S SHINE THE LIGHT LAW)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

CALIFORNIA PRIVACY RIGHTS FOR MINOR USERS ( CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

LINKS TO OT HER WEBSITES

Our Website may contain links to other websites that are not operated by US. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, You can contact us:

o  By emai: pikolinosusa@pikolinos.com

o  By phone number: 1( 877)745-4872