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Privacy Policy

PRIVACY POLICY

CLO Virtual Fashion, LLC (“CLO”) respects the privacy rights of its users and protects the personal information collected, stored and used in connection with our services (our "Services"). To further this commitment, we have adopted this Privacy Policy ("Privacy Policy") to guide how we collect, store, and use the information you provide us.

By setting up a CLO account, by using our Services, by using or downloading software made available by CLO, or by clicking the “I accept” button (or its equivalent), you are accepting the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not register for an account with CLO, download software made available by CLO, or otherwise access our Services.

We will notify you of any revisions to this Privacy Policy in accordance with our Terms of Service. You will be deemed to have agreed to any such modifications by your continued use of our Services after any such modification is posted. It is important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If you do not agree with the modifications, please discontinue use of our Services immediately.

WE DO NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF 13. If you are a parent or guardian and believe your minor child has provided us with personal information without your consent, please contact us as described in the “Inquiries” section below and we will take steps to delete such personal information from our systems.

1. SCOPE OF PRIVACY POLICY

This Privacy Policy describes CLO’s collection and use of personal information submitted and collected through our Services. Personal information includes any individually identifiable information about you, such as your name, address, telephone number, or e-mail address, and information concerning you collected and/or maintained in personally identifiable form.

Please be aware that advertisers or websites with links to and from our Services may collect personal information about you. This Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites.

2. INFORMATION WE COLLECT

We may collect and process the following data about you:

  1. Personal information such as your name, address, telephone number, e-mail address, and credit card number when you register for an account with CLO, make sales inquiries, request support, or make a purchase or payment.
  2. We collect certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, operating system, browser type, date/time stamp, and/or program or system error messages and other system information. We may combine this automatically collected log information with other information we collect about you to improve our Services, to improve marketing, analytics, or website functionality.
  3. If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.
  4. We collect details of your use of our Services and the resources that you access. Such usage information includes information about how and when you access or use our Services.
  5. User feedback, community discussions, chats and other interactions on our Services.
  6. If you access our Services on your mobile telephone or other mobile device, including tablets, we collect mobile device identifiers, including MAC Address, and IP Address. Certain aspects of our Services will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, geo-location and any other information you choose to provide or allow us to access.

Please keep in mind that when you voluntarily disclose personal information which is publicly viewable, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who views information (and what they do with information) you voluntarily post publicly.

3. USE & SHARING OF INFORMATION COLLECTED

CWe use your personal information and non-personal information, both individually or combined together:

  1. To help us manage, operate and deliver our Services to you
  2. To improve your experience with our Services
  3. To develop new products or services for you
  4. To provide you with customer support
  5. To communicate with you about our Services (unless you have not consented to allow us to use your information for these purposes)
  6. For marketing and promotional purposes
  7. For internal training purposes and statistical analysis

We work with our affiliates and third party service providers located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons (such as processing credit cards, sending emails, etc.) When our affiliates or our third party service providers collect or receive personal information, we require them to agree to strict data protection requirements in keeping with our privacy policy standards and the European Union's General Data Protection Regulation.

In a business transaction, such as a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, customer information, including personal information, generally is one of the transferred business assets. In the event that CLO undergoes such transactions, including preparation of any of such transactions, we may share, disclose or transfer all of your information, including personal information, to the successor. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

Occasionally we may be required by law enforcement or judicial authorities to provide personal information to the appropriate governmental authorities. We will disclose personal information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.

CLO will not sell personal information to advertisers or other third parties without your consent.

4. HOW WE COLLECT

CLO’s collects information from you when you provide it to us directly, such as via an online form or when you talk with our customer support team. CLO and third parties also use certain technologies described below to collect information to deliver excellent experiences.

Cookies. We use cookies for various purposes including our shopping cart, to remember users’ settings, and for authentication.

Functional cookies are necessary to enable portions of our Services and features to work as intended. For example, we use cookies to help recognize and remember you when you are logged into our Services so we can maintain your settings and preferences. These cookies may also help CLO provide the services you requested. These cookies do not track your browsing activity on non-CLO websites.

You may disable cookies by adjusting individual browser settings. However, your ability to use some features or areas of our Services may be limited.

Analytics

We use cookies and similar tracking technologies to help us understand how you use our website, our mobile app, our desktop clients, and our browser extensions. By providing us with information about how you interact with our Services, these tools help us analyze and learn how to make our Services better and customize our communications with you. The following analytics technologies are in use: Google Analytics.

Ad Serving

Some of our Services employ ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies like identifiers to deliver offers to you. Some of these technologies can sync or connect behavior across different websites, mobile apps and devices. The ads can be tailored to your interests. These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to identifiers, this information includes:

  1. Advertisements served and the location of the ad;
  2. Length of time an advertisement was visible;
  3. Domain type, IP address, size of the advertisement; and
  4. Advertisement response.

Third party advertising companies may combine the information collected in the context of delivering an ad to you via our Services with other information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. To learn more about some of these ad networks' practices, or to opt out of third party targeted advertising, you can visit www.networkadvertising.org, www.aboutads.info/choices, youradchoices.ca, or www.youronlinechoices.eu. Note that opting out does not mean you won't see ads; it just means that the advertising you see may be less relevant to your interests.

5. SAFEGUARDS

CLO maintains appropriate safeguards that ensure the security, integrity, and privacy of the personal information we collect and store about our account holders. Personal information collected by CLO is stored in secure operating environments that are not available to the public and that are only accessible by authorized employees. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control (i.e., maintain data quality). Before we allow web users to access their personal information, for example, we verify their identity by requesting that they submit information such as their username and password.

However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Services cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party.

6. LINKS TO THIRD PARTY SITES OR SERVICES

You should be aware that our Services may from time to time contain links to third-party sites, products or services. CLO is not responsible for the privacy practices or the content of such sites or services. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site or service to which you link before you submit any personal information.

7. YOUR RIGHTS RELATED TO PERSONAL INFORMATION

You have certain rights regarding your personal information, subject to local data protection laws. These may include the following rights:

  1. to access your personal information held by us (right to access);
  2. to rectify inaccurate personal information and ensure it is complete (right to rectification);
  3. to erase/delete your personal information to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
  4. to restrict our processing of your personal information (right to restriction of processing);
  5. to transfer your personal information to another controller to the extent possible (right to data portability);
  6. to object to any processing of your personal information carried out on the basis of our legitimate interests (right to object). Where we process your personal information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
  7. not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites; and
  8. to the extent we base the collection, processing and sharing of your personal information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise your rights, please contact us in accordance with the “Inquiries” section below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.

CLO enables you to review, update or correct your personal information in our possession. In order to do so, please log into your account or contact our Privacy Policy Administrator at support@marvelousdesigner.com. If you contact us, we will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.

8. RETENTION; DEACTIVATED OR TERMINATED ACCOUNTS

When you sign up for an account with CLO, CLO retains personal information you store on our Services for as long as your account is in existence or as long as we need it to provide you our Services. If you delete your account, we will initiate deletion of this information after 30 days, but please note: (1) there might be some latency in deleting this information from our servers and back-up storage; (2) a request to delete and/or terminate your account will not result in the removal of information collected and already put in aggregate form; (3) we are not able nor are we obligated to remove any of your information from a third party provider or platform; and (3) we may retain your information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

9. MARKETING COMMUNICATIONS PREFERENCES

If we process your personal information for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails, by replying or texting ‘STOP’ if you receive SMS communications, or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe on my-page or by contacting us using the information in the “Inquiries" section below. Note that opting-out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions, service announcements or security information.

10. OPTING OUT

If at any time you wish to opt out of having your personal information shared with third parties and/or receiving information from CLO (via e-mail or postal mail) about new products, services, or promotions, you can do so by adjusting your account settings or emailing us at support@marvelousdesigner.com.

11.INTERNATIONAL PRIVACY PRACTICES

Personal information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which CLO, its parents, subsidiaries, or third party agents operate. By using or accessing our Services, residents and citizens of countries and jurisdictions outside of the United States agree and consent to the transfer, storage and processing of your information on servers located in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

12. INQUIRIES

If you have any questions regarding the data CLO collects or how we use it, please feel free to e-mail us at support@marvelousdesigner.com or in writing to CLO Virtual Fashion, LLC, 79 Madison Ave, 2nd Floor, New York, NY 10016.

13. CLO’S DATA PROTECTION OFFICER

CLO’s Data Protection Officer is responsible for matters relating to privacy and data protection. The Data Protection Officer can be reached at CLO Virtual Fashion, LLC, Attn: Data Protection Officer, 79 Madison Ave, 2nd Floor, New York, NY 10016.