This Global Privacy Policy (the "Policy") describes how Volonic, an American company with registered office at Newport Beach, CA and/or its affiliates, each in their quality of controller, process personal information about its clients and prospects in order to provide you with the best possible service.

Volonic, as described in this Policy (hereinafter: "We", "Our", or "Us") collects, stores, processes, uses and discloses personal information about you in connection with your use of Volonic websites, Volonic apps, your use of our connected products (if and when available), or when you visit our social media pages.

1. WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?

   1. Contact information: may include your name, address, telephone number or e-mail address. For example, we might collect this information if you sign up for an online account or participate in an event. We might also collect contact information if you fill out a customer information card.
   2. Payment information: may include your credit card number, billing and shipping address which you provide when you buy merchandise on our Platform.
   3. Submitted or posted information: may include information you post in a public space on our Platform, such as when you leave a product review. We may also collect information when you send us a message through the “Contact” page, live chat or similar features on our Platform or when you enter a promotion.
   4. Social Media information: may include content you post on social media, your social media profile information and information posted on your page.
   5. Demographic information: may include your birthdate, age, gender and zip code. We may also collect information that could identify you and relates to your hobbies, interests and
   6. Purchase information: may include information about the purchases you make online or in stores. This could include the products you purchased and their prices.
   7. Device information: may include type of device used to access our Platform. We may also collect your device identifier, IP address or mobile operating system.
   8. Location information: may include precise location information from your device. We may also collect this information in the background when our mobile applications are not in use. For more information about your options related to the collection of your location information, see the Choices section below.
   9. Other information: if you use our website, we may collect information about the browser you’re using. We might look at what site you came from, or what site you visit when you leave us. We might look at how often you use the app and where you downloaded it. We collect this information using the tracking tools described. To learn about our tracking practices, please scroll down to the "Tracking" section at the bottom of this page.

2. HOW DO WE COLLECT INFORMATION?

   1. Directly from you: if you create an account or make a purchase on our Platform, we collect your information. We may also collect your information if you sign up for promotional emails or interact with our social media sites.
   2. Passively from you: we collect information about users over time and across different websites, apps and devices when you use the Platform. Third parties also collect personal information this way on our Platform. For example, this may include when you install and use our mobile app or visit and navigate our Platform on any device. This may also include when you enable location-based features on our Platform or click on sponsored links or third-party advertisements.
   3. From third parties: for example, our business partners may give us information about you.
   4. From combined sources: for example, we may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform. We may also combine information we get from third parties with information we already have about you.

3. HOW DO WE USE YOUR INFORMATION?

   We use the information described above for the purposes specified at the time of collection or hereafter in this Policy:

   1. To improve our understanding of your interests and concerns: to make our Platform, products, and services better. We may use your information to customize your experience with us and to tailor our marketing activities to fit your needs and interests.
   2. To process your order and respond to your requests or questions: to process your order and ship items. Or, we may use your information to send you information you request. In addition, we may use your information to provide you with our Connected Product services.
   3. For security and legal purposes: to protect our company, our customers, our associates, and our Platform. We also use information to collect and enforce accounts and to protect against fraud.
   4. For marketing purposes: to contact you about new products and special offers we think you'll find valuable. These might be third party offers or products we think you might find interesting. We and our partners may engage in interest-based advertising using information gathered across multiple websites, devices, or other platforms. We may call you, or send you emails or text messages. We may also use other means as they are developed.
   5. To communicate with you about your account or our relationship: to contact you about changes to our Platform or about service updates. We may also contact you about feedback or about this Policy or our Platform Terms.
   6. For other purposes: to maintain transaction and other business records. We will do this for as long as we deem necessary. We also use information for internal purposes. This includes administrative and audit purposes. We also use information to meet legal, insurance and processing requirements. We will also use information as otherwise allowed by law, including if we have notified you. In some circumstances, we may seek your permission, for example, if we are legally required to do so.

4. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

   We do not disclose or otherwise share your personal information We collect, except:

   1. With third parties who perform services on our behalf, such as vendors who send emails for us. We may also share personal information with service providers that help us operate our Platform or run promotions.
   2. With our parent and affiliated companies, for reasons including internal audit, management, billing or administrative purposes and to provide you with the same level of services around the world. This includes future subsidiaries or affiliates.
   3. With our business partners, such as third parties who jointly sponsor an event or promotion with us.
   4. With any successor to all or part of our business, including merges of all or part of our business or assets are transferred, assigned or sold. Your personal information will be disclosed to our successor or assign in these circumstances who can use and disclose your information for substantially the same purpose as set out in this Policy.
   5. If required by law or to protect ourselves. This includes compliance with laws outside of the US that might apply to us. For example, we will share information to respond to a court order or subpoena. We may share it if a government agency or investigatory body requests. We might share information when we are investigating potential fraud. This might include fraud we think has happened during a sweepstakes or promotion.
   6. We do not and will not sell your information to third parties. We may share information to third parties as disclosed in this Privacy Policy, but we do not, and will not sell your personal information to third parties.

5. WHAT CHOICES DO YOU HAVE ABOUT YOUR INFORMATION?

   You have certain choices about how we use your information. Certain choices you make are browser and device specific.

   • Marketing Communications: You can opt out of receiving our marketing communications. You can opt-out of receiving our promotional emails or text messages by following the instructions included with the communication. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.
   • Cookies and Tracking Tools: To learn how to manage how we – and our vendors – use cookies and other tracking tools, and to read our Do Not Track Policy, please scroll down to the "Tracking" section at the bottom of this page.

6. WHAT TRACKING TOOLS DO WE USE?

   We may collect certain information through cookies, web beacons and other automated means. A cookie is a text file which is stored in a dedicated area of your device’s hard drive, for instance when you visit online service, when you read an email or while installing or using a mobile app. A cookie allows its sender to identify the device on which it is stored during the period of validity of consent, which does not exceed 13 months.
   

   What type of cookies do we use?

   • Some cookies may be functional to collect information which will allow Us to facilitate your browsing such as languages preferences, memorizing log-in, or saving the content of your shopping basket or wish list.
   • Other cookies also collect information on your behavior by collecting referring URLS (where our visitors come from, which banners they clicked on and which directed them to our website), pages accessed, times of websites visits. Such information will allow Us to enhance our web sites and apps, have a better understanding of the products and services you would prefer, and offer you more personalized communications and/or more personalized content on our website or our applications.
   • We also use cookies for web analytics to measure the web sites activity and determine the areas of the web sites which are the most visited, hence improving visibility of our content.
   • We use cookies to ensure security of online transactions/purchases through device fingerprinting, which allows to identify certain aspects of the equipment used to place an order.
   • Our websites or apps may contain third party cookies (delivered by advertising agencies, analytics providers, etc.) enabling them to collect browsing information on your Devices, including to measure the efficiency of our advertising campaigns on third party websites. Third party cookies are subject to said third party privacy policies. We hereby inform you about the purpose of these cookies and how you can manage them, to the extent we are aware thereof.
   • We may include in our website or apps the possibility to share content with third parties or to let other persons know you browsed our website. Such is the case for instance of “Like” and “Share” functionalities offered by social network platforms (“Facebook”, “Twitter”, etc) .
   • Social networks which offer these functionalities may identify you even though you do not use these functionalities on our website. Indeed, such functionalities allow social network platforms to track information about your browsing on our website whenever your social network account is active while browsing our website.
   • We do not control how these platforms collect your personal data while you are browsing our website. We invite you to read the Privacy policies of these social networks to find out how they use information they collect (including for advertising purposes) through these buttons. These Privacy policies should provide you information about how to manage your preferences on your social networks account.

   How to accept or reject cookies?

   Except for functional or security cookies, the use of cookie on a Device depends on the user’s choice, which can be made and modified freely and at any time. You can manage cookies either through our website (LINK TO MANAGE COOKIES) or by setting your browser to accept or reject cookies on your Device, either globally or cookie by cookie. Settings that you make may change your internet browsing capacity and may sometimes alter your ability to access certain services that require the use of cookies.

   Such is also the case if we or one of our business partners can no longer recognize the type of browser your Device is using such as language, display settings or country / region of connection. We cannot be held liable for the minimized access to our services as a result of cookies you previously deleted or rejected.

   How to manage cookie settings in your browser?

   Each browser has its own cookie management system, as described in the “Help” menu of your browser, where you will be provided with all necessary information about how to set your preferences.

7. HOW DO WE TRANSFER YOUR PERSONAL INFORMATION?

   Your information may be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this policy. We rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States and other countries.

8. FOR HOW LONG DO WE RETAIN YOUR INFORMATION?

   Your personal information will not be kept in a form that allows you to be identified for any longer than is reasonably considered necessary by Volonic for achieving the purposes for which it was collected or processed or as it is established in the applicable laws related to data retention periods. The data retention term of Your personal data collected by Us is determined per purpose of data processing according to the following criteria:

   • Data collected will be stored only:

     • For three (3) years since our last contact, if You are a prospect (i.e. you have not made any purchase with Us but You are interested in Volonic
     • For the duration of your commercial relationship with Volonic and 10 years thereafter, if You are a client (ie You have made a purchase of Our products or services)
     • Your personal data will then be archived to be used: in the event of a litigation or dispute for the statute of limitation term applicable to the related purpose;
     • If a judicial action is initiated, the personal information may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived aspermitted by applicable law;

   Your personal data are then anonymized or deleted.

9. WHAT ARE YOUR RIGHTS WHEN IT COMES TO YOUR INFORMATION?

   You may request access to the personal information we maintain about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address:

   Email: concierge@volonic.com

   We want to make sure that your personal information is accurate and up to date. You may ask us to correct or to remove information you think is inaccurate.

10. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

    We will provide an adequate level of protection for your personal data and make sure that appropriate technical and organizational security measures are in place to protect your personal information (including education and training of relevant personnel) against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

    However, to the extent that the Internet is not completely secure, we cannot guarantee that any of your personal information stored or sent to us will be completely safe. We encourage you to use caution when using internet to access our websites, apps or social media.

11. CHILDREN

    Our websites and apps are not directed to children. We do not knowingly collect personally identifiable information from children without permission from a parent or guardian, unless permitted by applicable law.

    You must be at least sixteen years old to provide Us with your personal information and eighteen years old to engage in transactions on our store or websites, or apps. By engaging in transactions with us, you affirm that you are at least eighteen years old and are fully able to enter into and be legally bound by such transactions.

    If we are notified (by contacting Us at "Contact Us") or learn that a minor has submitted personal data to us through our media or otherwise, we will delete such personal information.

12. THIRD PARTY SITES

    We may link to third party sites or services We do not control, and which are governed by their own privacy policy. This Policy does not apply to those third-party sites. We strongly advise you to check the privacy policies of all third-party sites you visit to find out how they are treating your personal information.

13. CHANGES TO THIS POLICY

    Our Policy may change from time to time to reflect changes in Our processing of your personal information. We will notify you of any material changes as required by law. We will post an updated copy on the Site. Please check this page for updates.

14. CONTACT US

    If you would like Us to update the information, We have about you or your preferences, or if you have any questions about the protection of your personal information please contact Us at concierge@volonic.com or 1-833-VOLO-100.