Privacy Policy

Durable Supply Inc. (“Soduro”, “we”, “us” and “our”) respects your privacy and is committed to taking reasonable steps towards protecting your privacy online and managing your information responsibly, in order to best understand the products and services that are most useful to you. This Privacy Policy (“Policy”) is intended to notify you of our online privacy practices, the type and categories of information that may be collected, disclosed and stored, how the information is used, with whom the information may be shared, what choices are available to you regarding the collection, use and distribution of the information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, your rights regarding your Personal Information and who to contact with questions or concerns.

By using our Website, you agree to our collection, storage, use and disclosure of information as described in this Policy. If you disagree with anything in this Policy, please do not use our Website. 

This Policy applies to our Website located at soduro.com, to any phone, fax, and/or mail operations concerning processing of orders and questions about products or services, as well as our marketing contacts with you. This  Policy does not apply to other websites to which we may link, or to other companies or persons who might be listed as third-party contacts or suppliers on the Website, or to whom we may refer you if you call or write us. We may post links on the Website as a way of helping you locate related information and products easily. However, when linking to another website, you must review that website’s privacy notice as other websites may not treat information collected online in the same manner as we do. This Policy also does not apply to information collected when you purchase our products in department and specialty stores, or on other third-party websites where our products are sold. Unless otherwise specified, Personal Information collected from these other channels is not provided to Soduro, and Soduro has no control over how they use the information they collect.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the collection, storage, use and disclosure of Personal Information or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. 

You may also have certain rights regarding the information we collect from or about you. Specifically, California Residents and Virginia Residents may find information on their rights as consumers in the California Consumer Privacy Act and Virginia Consumer Data Protection Act sections below.

A. Children’s Privacy

B. How Do We Collect Your Information

C. What Information Do We Collect

D. How We Use Your Information

E. Disclosure of Your Information

F. International Transfer of Personal Information

G. Data Security

H. Terms of Service

I. Direct marketing

J. Cookies, Analytics, and Tailored Advertising

K. California Consumer Privacy Act Disclosures

L. Consumer Rights under the California Consumer Privacy Act

M. Disclosures and Consumer Rights under the Virginia Consumer Data Protection Act

N. California’s “Shine the Light” Law

O. Nevada Privacy Rights

P. Contact Us

Q. Definitions

(A) Children’s Privacy

Our Website is not directed to children under the age of 13. We do not request or knowingly collect Personal Information from individuals under the age of 13. If you are not 13 or older, you should not visit or use our Website. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected] or by calling +1-840-999-5138. 

(B) How Do We Collect Your Information

Sources of Personal Information: We collect or obtain Personal Information from and about you from the following sources:

· Information you provide to us:We collect Personal Information when you provide it to us (e.g., when you register an account with us; where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you order products from the Website, or subscribe to our newsletters,or when you share your feedback,photos,videos or other contents).

· Data we obtain in person: We obtain Personal Information during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.

· Automatically when you use the Website: We collect or obtain Personal Information when you use any features or resources available on or through our Website.

· Third party information: We collect or obtain Personal Information from third parties who provide it to us (e.g., social media partners (Google or Amazon log-ins); etc.).

We may also create Personal Information about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Information from any of our sites, or services, including where those data are collected from different devices.

(C) What Information Do We Collect

Information You Provide to Us

When you create an account, order products, use our Website, or contact us, we may ask you to provide information. This information includes: 

· Registration information : Information you provide when you register with the Website or log in, including name, email address, nickname (optional),  account password,telephone number (optional),gender (optional),avatar (optional), date of birth (optional), and the account information of third party (e.g.,Google or Amazon log-ins etc) .

· Relationship information: Records and copies of your correspondence (including email addresses, phone numbers, photographs, and videos), if you contact us with feedback.

· Order information: Information you provide when you order products,  including name, e-mail address, shipping address, payment information (e.g., credit card number, PayPal identifier, etc.), and billing address. And information you provide when you need to extend your warranty or need after-sales service,including order ID, product serial number,purchase channel, email address, phone numbers.

· The information you shared:Information related to the content(including your views, comments, photos, pictures, and videos) shared by you in this Website.

· Contact  information:Information you provide when you accept or participate in the  incentives and promotions,want to receive our latest news, or want to get other services that  your contact details is necessary,including email address, telephone number.

· Other information you provide to us: Information you provide when you use other services or participate in other promotions or activities that need your information.

Automatically Collected Information

When you visit the Website, it may use technology to automatically collect.

· Usage Details: When you visit the Website, we may automatically collect certain details of your access to and use of the Website, including traffic data, logs, communication data and the resources that you access and use on or through the Website.

· IP Address (only be used but not be stored): In order to make you easily use our services, we may recommend you to visit the  website suitable for you according to your IP address.

· Location Data(not precise geolocation): When you share your content(including pictures,photos,videos) in Soduro LIfe and wish to show your location, we may collect your location data.

(D)How We Use Your Information

We use information that we collect about you or that you provide to us for a variety of business purposes, including to:

· Provide you with the Website and its contents, and any other information, products or services that you request from us.

· Maintain or service customer accounts.

· Process or fulfill orders, transactions, and payments.

· Verify customer information.

· Fulfill any other purpose for which you provide it.

· Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

· Notify you of changes to any products or services we offer or provide.

· Analyze Website performance, calculate usage level, and help diagnose issues.

· Communicate with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested.

· Manage operations of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

· Detect, investigate and prevent breaches of policy, and criminal offences, in accordance with applicable law.

· Comply with our legal and regulatory obligations under applicable law.

· Debug information technology assets to address impairments to operational functionality and detect security incidents.

· Manage of legal claims; establish facts and legal claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defend legal rights and claims, including formal legal proceedings.

(E) Disclosure of Your Information

We disclose Personal Information to other entities within the Soduro group and affiliates, for legitimate business purposes and the operation of our Website, or to provide services to you, in accordance with applicable law. In addition, we disclose your information to:

· you and, where appropriate, your appointed representatives;

· legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

· accountants, auditors, consultants, lawyers and other outside professional advisors to Soduro, subject to binding contractual obligations of confidentiality;

· third party service providers, including cloud-based providers (such as email service providers; analytics service providers, marketing service providers; venue operators; payment processors; postal carriers; etc.), located anywhere in the world;

· any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;

· any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

· any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a merger, acquisition, sale, reorganization, dissolution or liquidation);

· any relevant third party provider, where our Website uses third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Information may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

(F) International Transfer of Personal Information

Because of the international nature of our business, we transfer Personal Information within the Soduro group, and to third parties as noted in the section above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Information to other countries that may have different laws and data protection compliance requirements than those that apply in the country in which you are located, including China.

(G) Data security

We have implemented commercially reasonable technical and organizational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

(H) Term of Service

The use of our Website is subject to our Terms of Service and we recommend that you review it regularly, in order to review any changes we might make from time to time.

(I) Direct marketing

We may use your Personal Information to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding our products or services that may be of interest to you. We may also use your Personal Information for the purposes of displaying content tailored to your use of our Website or services. If you use the Website or our services, we may send or display information to you regarding our products or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means.

From time to time, we may request information from you via surveys, contests and other promotions. Participation in these surveys, contests or promotions is voluntary and therefore you have a choice whether or not to disclose this information. If you choose to participate, we may ask you for additional information, which may include contact information (e.g., name, email and shipping address) and/or demographic information (e.g., postal code, and age), to provide better services and options to you. We use the information you provide to administer our contests, sweepstakes and other promotions, in addition to the purposes set forth herein. If your information, gathered via a survey, will be used in a manner different from that described in this Policy, such use will be detailed in the survey instructions. For example, the instructions will alert you if the information will be shared with anyone in addition to those identified in this Policy, such as a third-party sponsoring the survey.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send.After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of providing the services you have requested.

 (J) Cookies, Analytics, and Tailored Advertising

When you use our Website, we will typically place cookies onto your device, or read cookies already on your device, in accordance with applicable law. We may collect Personal Information through cookies and similar technologies, in accordance with applicable laws.

Cookies are bits of electronic information that a website may transfer to a visitor’s computer to identify specific information about the visitor’s visits to the website. The Website uses a browser feature known as a cookie, which assigns a unique identification to your computer. Cookies are typically stored on your computer’s hard drive and are used to help track clicks as you go through the pages within our Website. We may also use cookies to tell us whether you have previously visited the Website. Certain cookies may be stored on your device by third parties when you use our Website. We have no control over these cookies or how the third parties use them. These cookies allow third parties to provide us with a service, for example, analytics about the effectiveness of our marketing activities and user behavior.

You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies which may have been placed onto your computer. However, please be aware that the Website requires cookies to operate correctly. For example, if you turn off cookies or refuse them, you will not be able to make purchases on the Website. We will not use shared local objects (commonly referred to as “FLASH cookies”) in a manner inconsistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service. FLASH cookies are cookies that are placed on your computer that are not removed through normal browser management tools.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may opt-out of targeted advertising utilizing the Digital Advertising Alliance (“DAA”) AdChoices Program at optout.aboutads.info. For more information on the DAA AdChoices Program at visit www.youradchoices.com. In addition, the Network Advertising Initiative (“NAI”) has developed a tool that allows consumers to opt out of certain Tailored Advertising delivered by NAI members’ advertising networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see https://optout.networkadvertising.org.

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, we do not respond to “do not track” signals. Consequently, third parties may indeed track and collect information about your online activities over time while navigating to, from and on our online services, notwithstanding any “do not track” signals we may receive.

(K) California Consumer Privacy Act Disclosures

Under the California Consumer Privacy Act (“CCPA”) (as amended by the California Privacy Rights Act), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents (“Consumers”). Consumers are also afforded additional rights with regard to the Personal Information we collect about them that include the rights of access, deletion, correction, opt-out of the sale and sharing of Personal Information, and to be free from discrimination. This section of our Privacy Policy includes the disclosures and the Consumer Rights required by the CCPA. We also describe the methods by which a Consumer may exercise these rights and some of the statutory exceptions that may apply.

Collection of Personal Information

In the preceding 12 months, we have collected and will collect the following general categories of Personal Information about Consumers: 

· Personal identifiers, including names, postal addresses, unique personal identifiers, social media details, and email addresses;

· Categories of Personal Information enumerated in Cal. Civ. Code § 1798.80(e), including telephone numbers;

· Commercial information, including products or Services you have purchased, and your purchasing history;

· Internet or other electronic network activity information; and

· Inferences for use in creating a consumer profile.

Use of Personal Information

We may use the categories of Personal Information described above for the following business or commercial purposes: 

· Advance our commercial or economic business interests;

· Maintain or service customer accounts;

· Provide customer service;

· Process or fulfill orders, transactions, and warranties;

· Process payments;

· Verify customer information;

· Provide financing;

· Participate in sweepstakes;

· Provide direct marketing services;

· Provide analytic services;

· Ensure the quality and safety of services or Website;

· Improve the quality and safety of services or Website;

· Debugging to address impairments to operational functionality;

· Detect security incidents;

· Comply with applicable law and law enforcement requirements;

· Protect against malicious, deceptive, fraudulent or illegal activity;

· Prosecute those responsible for malicious, deceptive, fraudulent or illegal activity; and

· Defend against or bring legal action, claims and other liabilities.

Collection of Sensitive Personal Information

We do not seek to collect or otherwise Process Sensitive Personal Information.

Categories of Sources of Personal Information

We collect or obtain Personal Information about you from the following sources:

· Information you provide to us:We collect Personal Information when you provide it to us (e.g., when you register an account with us; where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you subscribe to our newsletter,or when you share your feedback,photos,videos or other contents).

· Automatically when you use the Website:We collect or obtain Personal Information when you use any features or resources available on or through our Website.

· Third party information:We collect or obtain Personal Information from third parties who provide it to us (e.g., social media partners (Google or Amazon log-ins); etc.).

Selling and Sharing of Personal Information

While we do not sell your Personal Information in exchange for money, some of the ways described in Section J in which we may disclose your information to third parties or use analytics or online advertising tools, that result in the disclosure of your information to third parties for a commercial purpose may be subject to this opt out right. If you would like to opt out of sharing your Personal Information for cross-contextual behavioral advertising or out of “selling” your information as that term is defined under the CCPA, you may submit a request by clicking below [PLEASE CREATE WEBPAGE FOR CONSUMERS TO OPT OUT AND INSERT LINK HERE] or sending an e-mail to [email protected].

Disclosure of Personal Information

In the preceding 12 months, we have disclosed the following categories of Personal Information to the following categories of recipients:

Retention of Personal Information

We take every reasonable step to ensure that your Personal Information is Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain each category of Personal Information collected are as follows:

 (L)Consumer Rights under the California Consumer Privacy Act

If you are a Consumer, the CCPA grants you the following rights regarding your Personal Information. Generally, in order to verify your requests to exercise your rights, we will compare the Personal Information we have about you to pieces of Personal Information we will request in the course of processing your request. The Personal Information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable consumer request. To exercise your rights under the CCPA, please follow the instructions described in this section.

Right to Know About Personal Information. Consumers have the right to submit a verifiable consumer request that we disclose the following in a readily useable format, covering the 12 month period preceding the verifiable consumer request:

· The categories of Personal Information we collected about you.

· The categories of sources for the Personal Information we collected about you.

· The categories of third parties to whom we disclose Personal Information.

· Our business or commercial purpose for collecting, selling, or sharing Personal Information.

· The specific pieces of Personal Information we collected about you.

· The categories of Personal Information that we shared, and for each category identified, the categories of third parties to whom we shared that particular category of Personal Information.

· The categories of Personal Information we have disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Information.

Verifiable consumer requests to know may be submitted through email at: [email protected] or by calling +1-840-999-5138. 

Right to Request Deletion of Personal Information. Consumers have the right to request that we delete any Personal Information that we have collected from them. However, we are not required to comply with a request to delete where it is necessary for us to retain the Personal Information in order to:

· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

· Help to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes.

· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

· Debug products to identify and repair errors that impair existing intended functionality.

· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

· Comply with legal obligations.

· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Verifiable consumer requests to delete may be submitted through email at:  [email protected] or by calling +1-840-999-5138. 

Right to Correct. Consumers have the right to request that we correct inaccurate Personal Information maintained about them. However, we are not required to comply with a request to correct where we have a good-faith, reasonable, and documented belief that a request is fraudulent or abusive, or if we have determined based on the totality of the circumstances, that the contested Personal Information held by us is more likely than not accurate and therefore does not require correction. In assessing the totality of the circumstances, we will consider: (a) the nature of the Personal Information; (b) how we obtained the contested information; and (c) documentation relating to the accuracy of the information, whether provided by you, by us, or another source.

We will accept and consider any documentation that you provide in connection with a request to correct. We may require you to provide documentation supporting a request to correct depending on: (a) the nature of the Personal Information at issue; (b) the nature of the documentation upon which we consider the Personal Information to be accurate (e.g., whether the documentation is from a trusted source or is otherwise verifiable); (c) the purpose for which we collect, maintain, or use the Personal Information (e.g., if the Personal Information is essential to the functioning of the Website, we may require more documentation); and (d) the impact on you. We will only use such documentation provided for the purpose of correcting your Personal Information and to comply with our record-keeping obligations for consumer requests.

Verifiable consumer requests to correct may be submitted through email at:  [email protected] or by calling +1-840-999-5138.

Right to Opt-Out of Selling or Sharing Personal Information. Consumers have the right, at any time, to direct a business that shares or sells Personal Information about the consumer to third parties not to share or sell the consumer’s Personal Information. As described above, we share your Personal Information, as defined in the CCPA.

You may submit a request to opt-out of the sharing of your Personal Information below by clicking below [PLEASE CREATE WEBPAGE FOR CONSUMERS TO OPT OUT AND INSERT LINK HERE]

Alternatively, you may opt-out of the sharing of Personal Information through the following methods:

· email at:  [email protected] 

· toll-free phone number: +1-840-999-5138

Right to Non-Discrimination. Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:

1. Deny you goods or services.

2. Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.

3. Provide you a different level of quality of goods or services.

4. Suggest that you may receive a different rate for goods or services or a difference level or quality of goods or services.

5. Retaliate against an employee, applicant for employment or independent contractor for exercising their rights.

Notice of Financial Incentive.  We offer various financial incentives. For example, the financial incentives we may provide include:

· Customized discounts, coupons and special offers via email when you sign up for our email list, participate in a marketing promotion or sweepstakes, or create an Account.

· Discounts when you refer a friend using your personalized link and they make a purchase.

You may opt-in to the financial incentive program by accepting the offer and submitting the requested Personal Information on the financial incentive offer page (e.g., refer a friend promotion). In order to participate in some of these financial incentives, you may be asked to provide Personal Information. Participation in any financial incentive program is optional and participants may withdraw at any time. To opt-out of the program and forgo any ongoing incentives, you may unsubscribe from our emails (for email-based incentives), or you may submit a request via email to [email protected] with the subject line “Financial Incentive Opt-Out” and include the Personal Information you submitted and the name of the applicable program or promotion.

The financial incentives we offer to consumers are reasonably related to the value of the consumer’s data to our business, based on our reasonable but sole determination. We estimate the value of consumers’ Personal Information by considering the expenses incurred by the business related to the collection, storage and retention of consumers’ Personal Information in the context of the financial incentive offered and the expenses related to the provision of the financial incentive and our products. From time to time, we may provide additional terms that apply to a particular financial incentive, which will be presented to you at the time you sign up for the financial incentive.

Authorized Agent. Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

(M) Disclosures and Consumer Rights under the Virginia Consumer Data Protection Act

Under the Virginia Consumer Data Protection Act (“VCDPA”), we, the data Controller, must disclose our practices regarding the collection, use, and disclosure of the Personal Data of Virginia Residents (“Virginia Consumers”). Virginia Consumers are also afforded additional rights with regard to the Personal Data we collect about them that include the rights of access, deletion, and correction. This section of our Privacy Policy directs you to the disclosures required by the VCDPA and describes the rights afforded to Virginia Consumers. We also describe the methods by which a Virginia Consumer may exercise these rights.

VCDPA Disclosures

· For the categories of Personal Data we (the Controller) Process, please see Section (K) of this privacy policy.

· For a description of the purposes for Processing Personal Data, please see Section (K) of this privacy policy.

· For the categories of Personal Data that we share with third parties, please see Section (K) of this privacy policy.

· For categories of third parties with whom we share Personal Data, please see Section (K) of this privacy policy.

Virginia Consumer Rights under the VCDPA

Consumer Requests: Under the VCPDA, we are a Controller of your Personal Data. If you are a Virginia Consumer, the VCDPA grants you the following rights, and to exercise them, please follow the instructions described in this section.

Right to Access Personal Data: Virginia Consumers have the right to confirm whether or not we are Processing their Personal Data and to access such Personal Data.

Verifiable consumer requests to confirm and access may be submitted through email at: [email protected] .

Right to Correct Personal Data: Virginia Consumers have the right to correct inaccuracies in the consumer’s Personal Data, taking into account the nature of the Personal Data and the purposes of the Processing of the consumer’s Personal Data.

 Verifiable consumer requests to correct may be submitted through email at: [email protected] .

Right to Delete Personal Data: Virginia Consumers have the right to delete Personal Data provided by or obtained about the consumer.

Verifiable consumer requests to delete may be submitted through email at: [email protected] .

Right to Data Portability: Virginia Consumers have the right to obtain a copy of their Personal Data that they previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the Processing is carried out by automated means.

Verifiable consumer requests for data portability may be submitted through email at: [email protected] .

Right to Opt-Out: Virginia Consumers have the right to opt-out of the Processing of the Personal Data for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling.

Verifiable consumer requests to opt-out may be submitted through email at: [email protected] .

If we are unable to authenticate your request using commercially reasonable efforts, we may request that you provide additional information, such as name, email address, phone number, or postal address, to authenticate your request. We will deliver a response to you within 45 days of receiving your verifiable consumer request.

Process to Appeal Declined Requests: If we decline to take action on your request, we will notify you within 45 days of receipt of your request. In the event we decline to take action on your request, you may submit an appeal within 30 days of receiving such notice. You may submit an appeal through email at: [email protected] . Within 30 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Virginia Attorney General to submit a complaint.

(N) California’s “Shine the Light” Law

Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of Personal Information Soduro shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this notice, please submit a written request to [email protected] .

(O) Nevada Privacy Rights

We do not currently sell Personal Information as defined by applicable law in Nevada.

 (P) Contact Us

If you have questions or concerns with respect to our Policy, you may contact us at [email protected] or by calling +1-840-999-5138.

(Q) Definitions

“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

“Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:

(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

(B) Any personal information described in subdivision (e) of Section 1798.80.

(C) Characteristics of protected classifications under California or federal law.

(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

(E) Biometric information.

(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.

(G) Geolocation data.

(H) Audio, electronic, visual, thermal, olfactory, or similar information.

(I) Professional or employment-related information.

(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

(L) Sensitive personal information

“Process”, “Processing” or “Processed” means any operation or set of operations that are performed on Personal Information or Personal Data, whether or not by automated means, such as the collection, use, storage, disclosure, analysis, deletion, or modification of Personal Information or Personal Data.

“Sell,” “selling,” “sale,” or “sold,’’ means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration.

“Sensitive personal information” means:

(1) Personal information that reveals:

(A) A consumer’s social security, driver’s license, state identification card, or passport number.

(B) A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

(C) A consumer’s precise geolocation.

(D) A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.

(E) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.

(F) A consumer’s genetic data.

(2)   (A) The processing of biometric information for the purpose of uniquely identifying a consumer.

(B) Personal information collected and analyzed concerning a consumer’s health.

(C) Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

“Website” means all webpages and subpages of Soduro.com.