Thank you for visiting our website.

This privacy policy applies only to www.ontoefy.com. This privacy policy does not pertain to information that is collected offline. Ontoefy can ensure that our privacy policy comply to either GDPR or Cap. it does not address or govern any information gathering, use, or dissemination practices related to information collected from the visitor (sometimes referred to as “you” or “your”) other than directly through or from the Site, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media. This Privacy Statement is incorporated into Ontoefy.com’s Statement of Use by reference, as if set forth fully therein, which must be reviewed and accepted by you.

1.WHAT INFORMATION WE COLLECT

Information you provide to us

We collect the personal information you provide to us when you purchase our products or visit our website.The categories of information we may collect include:

• Personal Identifiers, including name, email address, postal address, and telephone number

• Commercial and Financial Information, including purchases, credit card or debit card number, and bank or other financial account number

• Physical and Audio Data, including physical characteristics or descriptions

• Inferences, including inferences from other data

To the extent we process deidentified personal information, we will make no attempt to reidentify such data.

We collect personal information about you automatically when you

• Log data. Our servers automatically record certain information sent by your browser, such as your web page or resource request, your IP address or domain names of the computers you use, your referring/exit URLs, your browser type and operating system, and the date and time of your request, and other parameters concerning your operating system and computer environment. We also collect your search criteria and shopping history.

• Cookie data. We use cookies and similar tools to enable the functionality of our Site and Services, to assess and improve our Site and Services, and to deliver more tailored content to you. For more information on cookies, see the section below titled “What Cookies We Use And Why”.

Information from other sources

We may collect personal information about you from third-party sources, including Data Analytics Providers and Other consumers (e.g., referrals).

How long we keep your data

We do not retain data for any longer than is necessary for the purposes described in this Policy.We generally retain data according to the guidelines below.

(1)Type of Data

• Cookies and online data we collect while you use our website, including Online Identifiers, Internet Activity, Inferences from other data.

• Data we collect in order to process and ship orders you place with us, including Bank or other financial account number, Name, Email address, Postal address, Telephone number, Purchases, Credit card or debit card number.

• Data we collect when you contact us for customer support and other inquiries, including Bank or other financial account number, Online Identifiers, Internet Activity, Name, Email address, Postal address, Telephone number, Purchases, Credit card or debit card number.

• Data we collect when you sign up for promotional and marketing communications, including Email address, Telephone number.

• Data we collect when you review our products, answer surveys, or send feedback, including Name, Email address, Postal address, Telephone number, Purchases.

• Data we collect in connection with privacy requests, including Name, Email address, Postal address, Telephone number, Purchases.

• Data we collect for security purposes, including Bank or other financial account number, Email address, Credit card or debit card number.

(2)Retention Period

• We delete or anonymize data concerning your use of our website within 5 years of collecting it.

• We keep personal information related to products and services you purchase for as long as the personal data is required for us to fulfill our contract with you, and for 5 years from your last purchase with us. We may keep data beyond this period in anonymized form.

• We keep customer feedback and correspondence with our customer service for up to 2 years to help us respond to any questions or complaints. We may keep data beyond this period in anonymized form.

• Where you have signed up to receive promotional and marketing communications from us, we will retain any data collected until you opt out or request its deletion. We may keep data beyond this period in anonymized form. We will further retain a record of any opt-outs in order to prevent sending you future communications.

• We retain review, survey, and feedback data for up to 5 years following your last contact with us. We may keep data beyond this period in anonymized form to help improve our products and services.

• We retain records related to privacy requests for a minimum of 24 months following the completion of the request.

• We retain security-related data as long as necessary to comply with our legal obligations and to maintain and improve our information security measures.

2. HOW WE USE YOUR INFORMATION

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). And we use your personally identifiable information that is collected on the Site primarily for the following purposes:

• Measure and provide you with optimized targeted advertising

• Conduct data analytics

• Improve our Services

• Provide you with an optimized customer experience

• Inform you of our new products and offers and conduct direct marketing activities

• Safeguard against fraudulent purchasing activity

• Communicate with you regarding gifts and special offers

• Communicate with you concerning your questions, comments, or concerns

• Troubleshoot where necessary, diagnose technical and service problems, and address any issues you have with our Site or Services

• Provide personalized Client Services support

• Complete a transaction or service requested by you

• Maintain your purchase history and style preferences

• Administer our Site and improve our Site usability

• Track user movements on our Site

• Gather broad demographic data for aggregate use for benchmarking and marketing

In the processing of your personal information, we may also use your personal information to defend our rights and the rights of others, to efficiently maintain our business, to comply with the law as, and for other limited circumstances as described in How We Share Your Information.

3.HOW WE SHARE AND DISCLOSE INFORMATION

We may disclose the following personal information about you when you purchase our products or visit our website:

Personal Information Disclosed and Categories of Parties Disclosed To

• Personal Identifiers: Ad Networks, Business Operations Tool, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, Sales & Marketing Tools, Shipping Services, and Web Hosting Services

• Online Identifiers: Ad Networks, Cybersecurity Providers, Data Analytics Providers, Governance, Risk & Compliance Software, Payment Processors, and Sales & Marketing Tools

• Internet Activity: Ad Networks, Data Analytics Providers and Sales & Marketing Tools

• Commercial and Financial Information: Ad Networks, Business Operations Tool, Commerce Software Tools, IT Infrastructure Services, Payment Processors, and Shipping Services

• Inferences: Ad Networks

General sharing

• Advertising partners. We may share your identifiers, commercial information, internet activity, and inferences regarding the described categories with our advertising partners. We share this information so that we may:

• Deliver more relevant ads and promotional messages to you

• Understand your interests and preferences so that we can deliver relevant advertisements to you.

• Within the Ontoefy.com corporate group. We may share your identifiers, commercial information, internet activity information, and inferences regarding the described categories of information within our corporate family, such as our subsidiaries or affiliates to the extent permitted by law. The legal basis for this is our legitimate interest in carrying out or business operations efficiently. If you register with the Ontoefy.com client database, your personal information will be managed by Ontoefy.com, an entity in the same corporate group.

• Service Providers. We may share your identifiers, financial information, internet activity information, commercial information, and inferences regarding the described categories of information, with our service providers (including our website developers, IT services, email marketing platforms, social media reporting tools, financial institutions, and distribution and delivery services) to perform services for or on our behalf. We share this information in order to perform marketing activities and back in stock notifications, conduct surveys, validate your employment application, deliver your order, notify you with updates regarding your order, and trouble shooting. The legal basis for this sharing is our legitimate interest in providing the Services more efficiently.

• Corporate Reorganization. In the event we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, your personal information would be part of the assets shared with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. If we undergo bankruptcy or liquidation, personal information would be part of the liquidation assets and we would share it with third parties in the course of such proceedings. The legal basis for this is our legitimate interest in carrying out our business operations.

• For legal purposes. We will share personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal processes; to establish, protect, or exercise our legal rights or contractual obligations; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law. The legal basis for this processing is compliance with a legal obligation applicable to us, our legitimate interest in compliance with other laws applicable to Ontoefy.com, and our legitimate interest in the protection of the rights of others.

• With Your Consent. Apart from the reasons identified above, we may request your permission to use or share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information, or before the personal information you have already provided is used or shared for such purpose. You can revoke your consent at any time.

Business and Commercial Purposes for Collection

We collect personal information for the following business purposes:

- Conducting Surveys

- Creating Customer Profiles

- Data Storage

- Delivering Targeted Ads

- Fulfilling Customer Orders

- Improving our Products & Services

- Internal Business Operations

- Marketing Our Products & Services

- Meeting Compliance & Legal Requirements

- Operating our Website or Mobile Apps

- Organizing & Managing Data

- Preventing Fraud

- Processing Payments

- Providing Customer Support

- Providing Cybersecurity

- Sending Promotional Communications

- Tracking Purchases & Customer Data

4.HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION

- We make all reasonable efforts to ensure that your personal information is stored securely, both in electronic and physical form, and otherwise protect it from misuse, interference and loss caused by unauthorized access, modification or disclosure with security measures such as access controls. Our employees and agents are obliged to treat any personal information held by us confidentially.

- Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure, therefore, we cannot guarantee absolute security. If you have any security questions, please contact us at the Contact Information below.

5.CHILDREN’S PRIVACY

This Site and our Services are not intended for individuals under the age of thirteen years. Accordingly, we do not knowingly collect or share information from children. If we learn that we have collected or received personal information from individuals under the age of thirteen (13), we will delete the personal information. If you believe we have personal information on individuals under the age of thirteen (13), please contact us at the contact information provided below.

6. YOUR RIGHTS

Right to Know

You have the right to request to know the following about the personal information we have collected about you in the past 12 months:

- the categories and specific pieces of personal information we have collected about you

- the categories of sources from which we collect personal information about you

- the business and commercial purposes for which we collect personal information

- the categories of third parties with whom we share the information

- the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose

The information we would provide to you in response to a Request to Know Categories is contained in this Privacy Notice. To access the specific personal information we have about you, submit a Request to Know via the link above. If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.

Right to Delete

You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.

We consider information to be necessary for our business operations if it is used to:

- Complete an obligation to you that you have requested

- Detect and resolve issues related to security or functionality

- Comply with legal obligations

- Enable solely internal uses

Right to Non-Discrimination

If you exercise your CCPA consumer rights:

- We will not deny goods or services to you

- We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties

- We will not provide a different level or quality of goods or services to you

Right to Opt-Out

You have the right to opt-out of any selling and sharing of your personal information.

You may exercise your right to opt-out here.

Opt-Out Preference Signals. Your browser settings may allow you to automatically transmit the Global Privacy Control (GPC) signal to online services you visit. When we detect such signal, we place a U.S. Privacy String setting in your browser so that any third party who respects that signal will not track your activity on our website. GPC is supported by certain internet browsers or as a browser extension. You can find out how to enable GPC here.

Right to Correct

You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.

7. INTERNATIONAL DATA TRANSFERS

If you choose to provide us with personally identifiable information, Ontoefy may transfer that information to its affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personally identifiable information to the United States which does not have the same data protection laws as the EU and by providing your personally identifiable information you consent to:

• the use of your personally identifiable information for the uses identified above in accordance with this privacy policy;

• the transfer of your personally identifiable information to the United States as indicated above.

8.CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated and changed from time to time. We will post the new Policy on the Site and will indicate the date it goes into effect. If the changes materially affect your rights, our Site will contain a special notice about the changes and, if required by law, will prompt you for your consent for certain changes. Each version of this Privacy Policy will be identified by its effective date, which you can find at the bottom of this Policy.

9.CONTACT US

If you have any privacy-related questions, please send them to service@ontoefy.com