Effective Date: January 1, 2019 Hamelin Brands Inc. Privacy Policy This Privacy Policy describes the information privacy practices of Hamelin Brands Inc. (referred to herein as “Hamelin,” “we”, “us”, or “our”). It explains what information we collect about you, how we use and share your information, and your choices regarding our collection and use. If you have any questions or concerns regarding our Privacy Policy or practices, please contact us as provided at the end of this Privacy Policy. 1. Scope of Privacy Policy This Privacy Policy applies to information collected about you by or on behalf of Hamelin Brands when you use our website located at https://hamelin.store or our mobile application (the “Site”). This Privacy Policy also applies to any website or mobile application controlled by us that contains a link to this Privacy Policy. 2. Changes To Our Privacy Policy Hamelin may change this Privacy Policy from time to time to reflect changes in our practices or in applicable law. Such changes will be effective upon posting the revised Privacy Policy, along with the date on which it was most recently updated, on the Site. You will be able to tell when this Privacy Policy was last updated by the “Last Updated” date included at the top of this Privacy Policy. If a change materially affects the use or disclosure of your personally identifiable information, we will provide you with additional notice (such as adding a statement to the homepage on the Site or sending you an email notification). By continuing to use the Site or communicating electronically with us thereafter, you agree to accept such changes to this Privacy Policy. Please contact us as provided at the end of this Privacy Policy if you would like information regarding any changes. 3. Information Collected Hamelin collects information about you from a variety of sources, including (1) information you provide directly to us when you contact us, sign-up for an account, and purchase products from us through the Site, and (2) information we collect about you when you access and use the Site. The information we collect includes both personally identifiable information and other information that cannot be used to personally identifiable you. Information You Provide Us. If you sign-up for an account, purchase products, or contact us through the Site, we collect the requested information that you provide including your name, e-mail, phone number, mailing address, and credit or debit card information. You may choose whether or not to provide such information; however, the information may be required to complete your transaction or respond to your request. Information Collected Automatically. We collect information automatically from you when you visit and use the Site. Such information includes the following: Usage information. We collect information about how you interact with the Site. This includes information such as the dates and times that you visit the Site, the page you view, referring / exit URLs, your browser type, and the number of clicks on the Site. In some cases, we collect this information through cookies and similar technologies. To learn more about these technologies, please see the Cookies and Other Technologies section below. Device Information. We may collect information about the devices you use to access the Site (e.g., computer, tablet, and mobile phone), including your device model, IP address, operating system, unique device identifiers, and mobile network operator information. Transaction Information. We collect transaction details related to your purchases through the Site. Information We Receive From Third Parties. We may receive information about you from third parties. 4. How We Use Your Information Hamelin uses your information, including personally identifiable information, for a variety of business purposes, including: • Providing and improving the Site; • processing and fulfilling your product orders; • creating and managing your account; • communicating with you; • responding to your inquiries and communications; • customer service and technical support, which may include responding to your requests, resolving issues, and/or troubleshooting problems; • For marketing purposes, including developing advertisements more relevant to your interests; • improving and customizing the Site, communications, and advertisements; • for internal operations such as enhancing our offerings and to conduct research and analysis; • to assist in loss prevention and anti-fraud measures; • to enforce our Terms of Use, Terms of Sale, and any other applicable terms and conditions and agreements; • to comply with applicable laws, regulations, and legal processes; and/or • to protect the security and integrity of our business, the Site, the products we sell, our brand, users, customers, and our third party business partners and service providers. 5. How We Share Your Information Hamelin shares and discloses your information, including personally identifiable information, to third parties under the following circumstances: • with third parties that provide a variety of services on our behalf, including the development, hosting, maintenance, and support of the Site; processing your product orders and payments; shipping products to you; data management, storage, and analysis; communications; and marketing; • to comply with law, a court order, or other legal process, or in connection with a legal investigation; • to develop advertisements based on your interests; • as may be necessary to protect the rights and interests of Hamelin, its third party business partners and service providers, and our and their respective employees, customers, visitors, users, or any other person or entity; • to enforce our Terms of Use and Terms of Sale, and any other applicable terms and conditions and other agreements; • in the event of a corporate transaction, including a merger, acquisition, financing, dissolution, transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of Hamelin’s business or assets. In the event of an insolvency, bankruptcy, or receivership, your personally identifiable information may also be transferred as a business asset of Hamelin. If another third party acquires Hamelin or any of it business operations, whether through stock or asset purchase, such third party will possess the information, including personally identifiable information, collected by us and will assume the rights and obligations with respect thereto as described in this Privacy Policy; • in aggregated or other non-personally identifiable form; and/or • in accordance with your consent. We will not provide or sell your personally identifiable information to any third party for their own direct marketing purposes. 6. Cookies and Other Technologies We and our business partners and third party providers use cookies and other technologies such as log files, and analytic tools and services on the Site and in our email communications to collect information automatically from you. Such information includes your IP address, device type, any unique device identification numbers, type of browser (e.g., Google Chrome or Internet Explorer), operating system (e.g., Windows, Vista, Mac, OS, Android, etc.), your browsing activities (e.g., pages viewed and referring / exit URLs), and other usage information. We collect this information for a number of reasons, including optimization of the Site, improving the Site, to enhance your user experience, remembering user preferences and settings, marketing and advertising purposes, security purposes, and analyzing Site traffic and trends. Please see below for more information regarding the technologies that we may use. Cookies. A cookie is a small piece of data stored by your web browser on your computer or mobile device. We use cookies to collect information from you regarding your usage of the Site in order to remember user preferences and settings, personalize your experience with the Site, and for security purposes. Log File Information. Log file information is automatically reported by your browser or mobile device each time you access the Site. The information collected from log files may include your web request, Internet Protocol (IP) address, browser type, referring / exit pages and URLs, number of clicks, landing pages, and pages viewed. Online Analytics. We may use third party analytics tools, such as Google Analytics, to help us measure traffic and usage trends for the Site. These tools collect information sent by your browser or mobile device, including the pages you visit and other usage information. For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. 7. Your Choices Hamelin provides you with the opportunity to update certain personally identifiable information and to opt-out of having information collected for certain purposes. For example, you may • update your account information; • close your account; • choose whether to receive promotions and offers from us; • change your preferences for certain communications; and • request access to your personally identifiable information. You may exercise your choices by contacting us via the Contact Us information provided below or following the instructions provided in the electronic communications sent to you. Because we plan our communications in advance, it may take several weeks for your request to become effective. If you continue to receive our communications after expressing an opt-out preference, please let us know so that we can investigate the situation. We will, however, continue to send transaction-based emails if you engage in a transaction, request customer support, or make similar requests. In some cases, if you choose not to provide us with the requested information, we may not be able to complete your transaction. Cookies and Other Technologies. You may opt-out of the automatic collection of some information by referring to your web browser’s or mobile device’s options or settings menu. However, doing so may disable many of the portions, features, or functionality of the Site. For example, most web browsers automatically accept cookies, but you have the choice to set your browser to accept or reject cookies. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences or visit http://www.allaboutcookies.org for more information. Google Analytics. Google provides users choice on how their data is collected by Google Analytics by developing an Opt-out Browser Add-on which can be located at: http://tools.google.com/dlpage/gaoptout?hl=en. By installing this Add-on, no information is being sent to Google. 8. Information Security Hamelin implements reasonable physical, electronic, and administrative safeguards to help us protect your personally identifiable information from unauthorized access, use, and disclosure. If you choose a direct payment gateway to complete your purchase, your credit card data is encrypted through the Payment Card Industry Data Security Standard (“PCI-DSS”). All direct payment gateways 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 credit card information by the Site and our service providers. However, no method of electronically transmitting or storing data is ever completely secure, and therefore, we cannot guarantee that your personally identifiable information will never be accessed, used, or disclosed in a manner that is inconsistent with this Privacy Policy. 9. Reviews; User Content The Site may allow you to post product reviews and other content (“Submissions”). You are responsible for all actions resulting from any information, including personally identifiable information, which you include in your Submissions. Please remember that any information you submit in a Submission is not subject to this Privacy Policy, and Hamelin is not responsible for use of such information by other users or third parties. 10. Links and Third Party Websites The Site contains links to third party websites and social media pages (“Linked Sites”). We are not responsible for the privacy practices, policies, or content of any Linked Sites, even if you link to them from the Site or communications. This Privacy Policy does not apply to any Linked Sites. We have no control over the collection or use of your information on any Linked Site. We encourage you to read and understand the privacy practices of any Linked Sites that you visit. 11. California Residents’ Privacy Rights Residents of the State of California may request a list of all third parties to which we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us via the Contact Us information provided below. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information. Please allow 30 days for a response. If you are a registered user of the our Site and reside in California, you can contact us in connection with requests to delete personal information that we have collected from you, including content or information that you have posted on our Site or other Services in connection with your use of the Hamelin’s Services. To make such a request, please contact us by sending an e-mail to contactus@hamelinbrands.com. Please note that Hamelin is not obligated to remove such information or content in the following circumstances: (a) the information is necessary to complete the sales transaction or otherwise meet you reasonable expectations relating to a transaction, (b) the information is necessary to detect or investigate a security breach or related incident, (c) any applicable federal or state law or regulation requires us or a third party to maintain the content or information on our Site or related services; (d) such content or information was stored on or posted on our Site or other related service by a third party other than you, including any content or information posted by you that was stored, republished, or reposted by the third party; (d) we have anonymized such content or information so that you cannot be individually identified; (e) you have not followed the instructions described in this Section for requesting removal; or (f) you have received compensation or other consideration for providing such posted content or information. 12. Do Not Track Notice At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, like many other websites and online services, the Site are currently unable to respond to Do Not Track Signals. To find out more about “Do Not Track”, you may wish to visit http://www.allaboutdnt.com. 13. Users Outside the United States The Site is provided from within the United States, and our products sold through the Site and shipped from the United States, and are subject to the applicable state and federal laws of the United States. If you use the Site from outside the United States, please be aware that your information may be transferred to, stored, or processed in the United States where our servers are located and our database is operated. The data protections and other laws of the United States may not be as comprehensive as those in your country. 14. Children’s Privacy We do not knowingly solicit or collect personally identifiable information online from children under the age of 13 without verified parental or guardian consent. Please contact us as provided below in the Contact Us section if you believe we may have collected such information without parental or guardian consent. 15. Email Security “Phishing” is a scam designed to steal your personally identifiable information. If you receive an e-mail that looks like it is from Hamelin asking you for your personally identifiable information, including account information, please notify us as provided below. 16. Contact Us If you have any questions about this Privacy Policy or Hamelin’ information privacy practices, please contact us at contactus@hamelinbrands.com.
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