ACCESS79’ INC.’S PRIVACY POLICY

Last Updated May 13, 2019

Access79, Inc. ( “we”, “us”, or “our”) is committed to protecting your privacy. Access79 is a jewelry retailer that blends expert styling, technology and unique product to deliver a convenient, enjoyable, personalized shopping experience. We have prepared this Privacy Policy (“Privacy Policy”) to describe to you our practices regarding the personal information we collect from users on our website, located at www.access79.com (the “Site”), our mobile application (the “App”), our Email Correspondence (“Emails”), our Text Correspondence (“Text”), and Telephonic Communication (“Phone”) and the services offered through the Site and App, and any orders that you place (collectively, the “Services”).

This Policy includes and hereby incorporates by reference the Terms of Service between you and the Company and governs your access to and use of the Service.

Information Collected

Information You Provide to Us. When you sign up for an account for our Services (an “Account”), you provide us your name, email address, and password to register with us. In addition, we collect information via phone, e-mail, and the Site as part of your Jewelry Style Profile, such as your date of birth, as well as sizing, taste, and style preference information. If you transmit a photo to us via email or we will collect that photo.

When you receive a shipment, we record what you keep and what you return. If you provide us feedback or contact us via Email, Phone, Text, or through the Services, we will collect your name and e-mail address, as well as any other content included in the message.

If you provide us feedback or contact us via Email, Text, Phone, or through the Services, we will collect your name and Email address, as well as any other content included therein, in order to send you a reply.

When you place an order for the Services or when you order products through the Services, we or our third party payment provider will collect payment, shipping, and billing information in order to process the transaction.

When you post content (text, images, photographs, videos, messages, comments or any other kind of content) on our Services, the information contained in your posting will be stored in our servers and other users of the Services will be able to see it if you post it in an area made public, such as comments on our blogs.

We retain information on your behalf, such as messages you send (including the content of the message and the recipient data) using Services.

When you participate in one of our surveys, we may collect additional profile information.

We may collect the unique device id number of the mobile device on which you use the App.

If you participate in a sweepstakes, contest or giveaway on our Services, we may ask you for your email address and/or home phone number,to notify you if you win. We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary.

We may also collect personal information at other points in our Services that state that personal information is being collected.

For online payments, we use a third-party payment service. We do not process, record or maintain your credit card or bank account information. Information Collected from Third Party Companies.

We may receive information about you from other sources. We may add this information to the information we have already collected from you via our Services in order to improve the Services.

Information Collected Automatically.

Generally. When you use our Services, some information is automatically collected. For example, when you use our Services, your geographic location, how you use the Services, information about the type of device you use, your mobile network information, your Open Device Identification Number (“ODIN”), date/time stamps for your visit, your unique device identifier (“UDID”), and your browser type, operating system, Internet Protocol (IP) address, and domain name are all collected. This information is generally used to help us deliver the most relevant information to you and administer and improve the Services. In addition, in the event our App crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App.

Log Files.  As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to maintain and improve the performance of the Services.

Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We and some third parties may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services and to market the Services or other products.

Marketing Companies. We work with a number of companies that assist in marketing our services to you on third party websites. These companies may collect information about online activities conducted on a particular computer, browser or device over time and across third-party websites or online services for the purpose of delivering advertising that is likely to be of greater interest to you, on our sites and apps and those of third parties. While not a comprehensive list, some of these companies we work with are Conversant, Facebook, Twitter, Pinterest, Google AdWords, Yahoo, Outbrain, Taboola, and Kenshoo.



Analytics Companies. We may work with a number of third party analytics companies that collect information anonymously and report website trends without identifying individual visitors. These services allow us to view a variety of reports about how visitors interact with the Services so we can improve our website and understand how people find and navigate it. Currently, we work with the following analytics companies: Google Analytics. This is not intended to be a comprehensive list and we may stop working with these companies and work with others without notice. You can learn more about how these companies collect, use and share information about you by visiting their respective websites.

Use of Your Personal information

General Use. In general, personal information you submit to us is used either to respond to requests that you make, aid us in serving you better, or market our Services. We use your personal information in the following ways:

  • to choose and deliver your shipment;
  • respond to comments, requests and questions and provide customer service;
  • facilitate the creation of and secure your Account on our network;
  • identify you as a user in our system;
  • provide, process and deliver the Services you request;
  • improve the quality of experience when you interact with our Services, including the testing of different page designs to see which performs better;
  • send you administrative e-mail notifications, such as security or support and maintenance advisories;
  • resolve disputes and/or troubleshoot problems;
  • develop, improve, and deliver marketing and advertising for the Services; process and deliver orders;
  • respond to your inquiries related to employment opportunities or other requests; and
  • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes.

We may store and process your personal information in the United States and other countries.

User Feedback. We may post user feedback on the Services from time to time. If you make any comments on a blog, wall or forum associated with the Service, you should be aware that any information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the information you choose to submit in these blogs and forums.

Creation of Anonymous Data. We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site and App navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.

Disclosure of Your Personal information

We disclose your personal information as described below and as described elsewhere in this Privacy Policy.

Third Parties Designated by You. When you use the Services, the personal information you provide will be shared with the third parties that you authorize to receive such information.

Third Party Service Providers.We may share your personal information with third party service providers to: provide you with the Services that we offer you through our Services; conduct quality assurance testing; facilitate the creation of accounts; to provide technical support; market the Services; and/or to provide other services to Access79.

Business Partners. In order to facilitate your purchase of items from third party partners, we may disclose certain Personal Information about you when you ask us to do so.

Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

Other Disclosures. Regardless of any choices you make regarding your Personal information (as described below), Access79 may disclose Personal information if it believes in good faith that such disclosure is necessary: (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Access79; (iii) to protect or defend the rights or property of Access79 or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.







THIRD PARTY WEBSITES

Our Site or App may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site, App or Services and go to another site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and are not responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website and App you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

YOUR CHOICES REGARDING INFORMATION

You have several choices regarding the use of information on our Services:

Choices. We offer you choices regarding the collection, use, and sharing of your personal information. We will periodically send you newsletters and e-mails that directly promote the use of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms and Conditions or Privacy Policy.

Cookies. If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.

Changes to Personal Information. You may change your personal information in your Account by editing your profile within your Account. You may request that we delete your personal information in your Account, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud prevention or similar purposes.

While we and others give you the choices to control the information collected and used as described in this Privacy Policy, there are many web browser signals and other similar mechanisms that can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism.

Information Disclosed to Third Parties. This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Services. If you disclose information to others, or authorize us to do the same under this Privacy Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Services.

TPCA CONSENT & PRIVACY

Notwithstanding any current or prior election to opt in or opt out of receiving telemarketing calls or SMS messages (including text messages) from us, our agents, representatives, affiliates, or anyone calling on our behalf, you expressly consent to be contacted by us, our agents, representatives, affiliates, or anyone calling on our behalf for any and all purposes arising out of or relating to your loan and/or account, at any telephone number, or physical or electronic address you provide or at which you may be reached. You agree we may contact you in any way, including SMS messages (including text messages), calls using pre-recorded messages or artificial voice, and calls and messages delivered using auto telephone dialing system or an automatic texting system. Automated messages may be played when the telephone is answered, whether by you or someone else. In the event that an agent or representative calls, he or she may also leave a message on your answering machine, voice mail, or send one via text.You consent to receive SMS messages (including text messages), calls and messages (including prerecorded and artificial voice and autodialed) from us, our agents, representatives, affiliates or anyone calling on our behalf at the specific number(s) you have provided to us, or numbers we can reasonably associate with your account (through skip trace, caller ID capture or other means), with information or questions about your application, loan and/or account. You certify, warrant and represent that the telephone numbers that you have provided to us are your contact numbers. You represent that you are permitted to receive calls at each of the telephone numbers you have provided to us. You agree to promptly alert us whenever you stop using a particular telephone number.Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You also agree that we may contact you by e-mail, using any email address you have provided to us or that you provide to us in the future. We may listen to and/or record phone calls between you and our representatives without notice to you as permitted by applicable law. For example, we listen to and record calls for quality monitoring purposes.

USERS OUTSIDE OF THE UNITED STATES

If you are a non U.S. user of the Services, by using the Services and/or providing us with information, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your information, you consent to such transfer.

CHILDREN'S PRIVACY.

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at hello@access79.com.

CONTACT INFORMATION

We welcome your comments or questions about this Privacy Policy. You may contact us at hello@access79.com.

CHANGES TO THIS PRIVACY POLICY

We may change this Policy from time to time, so please review it periodically. If we make any changes, we will change the Last Updated date above. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of the Service after any modification to this Policy will constitute your acceptance of such modification.