Privacy policy

PRIVACY AND COOKIE POLICY

Your Privacy Rights

Effective Date: November 12, 2025

This Privacy Policy describes the types of information gathered by Kayne, LLC. dba JENNI KAYNE (“Jenni”, the “Company”, “us”, or “we”) in the process of providing our website (www.Jennikayne.com) (the “Site”) and the retail and other services, product information, software, updates, data, and materials we provide (collectively, the “Service”), how we use it, with whom the information may be disclosed, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service.

By using the Service, you consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, available here /policies/terms-of-service, which are incorporated in this Privacy Policy as if fully repeated within it. Any defined terms found, but not defined in this Privacy Policy, shall have the same definition as in the Terms of Service.

Scope. This Privacy Policy applies to the personal information of individuals we collect through the Site and otherwise through the Service. This Privacy Policy does not apply to the personal information of prospective, current, or former employees, contract workers, or any other individuals whose personal information the Company processes in its capacity as an employer.

The term “personal information” (also called “personal data”) as used in this Privacy Policy means, unless specified otherwise, any information related to or about an identified or identifiable natural person.

Territoriality
Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT PERMITTED AND POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

If you are an individual and reside in the United Kingdom, the European Union, Norway, Switzerland or elsewhere in the European Economic Area (collectively, and for the purposes of this Privacy Policy, the “EEA”), then the General Data Protection Regulation or equivalent legislation (collectively, and for purposes of this Privacy Policy, referred to as the "GDPR") will apply to our practices regarding your “Personal Data” and you are considered a “Data Subject” as those terms are defined by the GDPR. For the purposes of the GDPR, we are a data “Controller.” As a Data Subject you have certain protected privacy rights concerning your “Personal Data” (referred to in this Policy as “Personal Information”). We will take commercially reasonable steps to maintain compliance with the requirements of the GDPR.

1. What Information Do We Collect?

A. Personal Information. We collect certain personal information about you, which may be supplied when you sign-up for the Service, place an order, complete a survey, create or update an account (if applicable), when you respond to our advertising, or when you submit any other information to us. We only collect basic personal data about you. The types of personal information we collect and save include:

• Identifiers, such as name, email address, billing address, shipping address, date of birth, username and password if you create an account on the Site, and phone number;
• Commercial Information, such as records of products you purchase from us, warranty registrations, and your purchasing or consuming history;
• Internet or Other Electronic Network Activity Information, such as your Internet Protocol (IP) address, device identifiers, first party cookies (both session and persistent), third party cookies, web beacons, page URL and timestamp, and other information collected through technology, described further in Sections 8 and 9 of this Privacy Policy;
• Geolocation data, for example: certain features in our Site may collect your approximate location based on your IP address, for example, if you request to learn about nearby store locations;
• Inferences, for example, inferences that you may be interested in other products or services based on your purchase history;
• Marketing and Communications Preferences, such as services you are interested in, marketing preferences, and information about your interactions with, and responses to, our marketing communications; and
• Communications, Feedback or Other Information Provided to Us, including the content of correspondence with us through e-mail or text, social media interactions with our social media presence, product reviews posted on our Site, information you input into our live and automated chat features, responses to surveys, or any information you provide to us voluntarily such as through forms you fill in or search terms you input on the Site, or when you contact customer support services.

Although it may appear that the Service collects financial information, it is actually collected and processed through a third-party payment processor (“Payment Processor”) to process payments for the Service. Our Payment Processor may collect information such as banking information or credit card number, name, billing address, CVV code, and/or date of expiration, from you on the Service. We do not hold your financial information. Rather, we receive an electronic token which enables us to confirm orders and process refunds.

B. Non-personal Information. Non-personal information is anonymous or non-personally identifiable information about you, including but not limited to links and materials posted (including anonymous reviews and feedback), information about your web browser, the pages accessed most frequently, how pages are used, search terms entered, and similar non-personal data.

C. Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the date and time of your requests and orders, language preference, type of browser used, location, device information, session information, page views, operating system, referring websites, the website you go to immediately before or after our Site, browser history, traffic sources, and information about conversion from views to sales.

2. Where Do We Collect Your Information From?

We may collect personal information about you from the following sources:

• Directly from you, for example, when you use our Site, request information, order, or use our products or services, or otherwise communicate directly with us.
• Service providers, for example, payment processors, analytics providers, IT, customer support, and system administration services.
• Automated technologies, for example, browsing activity collected by automated technologies on the Site, described further in Sections 8 and 9 of this Privacy Policy, below.
• Third parties, for example, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Public sources, for example, public databases or social media.
• Surveillance/recording technologies, for example, with voicemail or through audio recording technologies with consent to the extent required by law.
• Government or administrative agencies, for example, law enforcement, public health officials, and other government authorities.

3. Why Is My Information Being Collected?

We accept and gather information in an effort to provide the Service to you. We need to collect your personal information so that we may, among other things, respond to your requests for information, add you to our e-mail and text lists, and generally allow the Service to operate and orders to be fulfilled and shipped. Our Payment Processor collects your payment information to process order payment and any refunds or credits. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide products and services to you.

4. How Do We Use the Information We Collect?

A. We use the personal information you provide for the following purposes:

• Providing the Service. For instance, to operate and administer our Site and the Service, fulfill product orders, to evaluate and improve our products and your experience on our Site and with the Service, and other core business functions such as internal process management, quality control, managing your account on the Site, and authentication.
• Paying For Goods Ordered. Our Payment Processor uses your personal information to process your payments for goods ordered through the Service.
• Sending Orders and Information to You. We use your personal information to ship products to you at the address you provided. This is done via a third-party carrier such as the United States Postal Service, UPS, or FedEx, with whom we disclose your personal information. The carriers use this information to coordinate and deliver items to you.
• Communicating With You About Services and Products. We may use your personal information to provide you with customer assistance and support, resolve disputes, process warranty claims, provide automated chat functions and search features administered by our third-party service providers, and to send you information about new services, discounts, products, loyalty/rewards benefits, and other items that may be of interest to you.
• Sending Administrative, Marketing, and Promotional E-mails. We may use your personal information to send you e-mails and other communications to: (a) create and maintain an account for you so that you may more easily use the Service and make purchases of products; (b) confirm your account information, if applicable, and your other personal information; (c) process your orders; (d) provide you with information regarding the Service; (e) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; or (f) provide you with information on, and promotions related to, the Service, and other services and products, that we and/or our business partners offer (subject to Section 5 below). To opt-out of marketing or promotional e-mails, simply follow the ‘unsubscribe’ link in any of those e-mails or respond STOP to text messages.
• Marketing and Advertising. We may use your personal information, along with our third-party marketing and advertising partners, to administer our marketing and advertising functions, send you marketing information about our products and the Service, and to serve you advertisements with the Service that are targeted to your interests.
• Complying with Legal Obligations. We may use your personal information to comply with applicable legal, regulatory and professional obligations, including cooperating with regulatory bodies and government authorities, to detect and prevent fraud and misuse, to exercise and defend ours, yours, or applicable third parties’ legal rights.
• Other Uses. We may use your personal information to provide you with rewards (if you have registered for our rewards program), respond to your inquiries, to fulfill your requests for information, track usage trends, develop, improve, and tailor the Service and other offerings, perform market and technical research and analytics.

B. We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you additional programs or services.

C. We do not use the personal information we collect for automated decision-making, including profiling, that produces legal effects or similarly significantly affects individuals.

5. Do We Disclose Your Personal Information?

We do not generally disclose your personal information outside of limited circumstances in accordance with the purposes described in Section 4 above, to the following categories of recipients:

• Service providers. We may disclose your personal information to service providers under contract with us to provide services on our behalf, assist with providing the Service, and help meet our business needs and legal obligations. For example, we use service providers to power our online store and process payments, to ship products, to provide automated chat functions and search features on the Site, and to provide IT services. Service providers will be permitted to process your personal information only for the purpose(s) for which it was disclosed to them and in accordance with the Company’s instructions.
• Professional advisers and related third parties. For example, we may disclose personal information to lawyers to assist us with legal compliance, and to auditors, accountants, consultants, to assist us in providing the Service or in otherwise conducting our business.
• Affiliate companies. Your personal information may be disclosed to our corporate affiliates, for example, to assist in providing the Service, or to provide you with information about their products and services.
• Marketing partners. We may disclose your personal information to our marketing and analytics partners, including social media platforms, to help us market and advertise our products, perform data analytics regarding your interactions with the Company, and in the course of using cookies, social media plugins, and other automated technologies on the Site.
• Aggregated data. We may also disclose aggregated and/or anonymized information with third parties, in such a manner that the information would not be able to identify you.
• Other third parties. We may disclose your personal information to other third parties:
  • With your consent, or at your direction.
  • When required by law. For example, when we respond to subpoenas, court orders, legal process, or discovery requests in civil litigation.
  • To protect rights, property or safety. If we believe that your actions violate applicable law, or threaten the rights, property, or safety of the Company, our customers, or others.

6. How Can You Access And Control Your Information?

After becoming a user of the Service, you may review, revise, and/or edit your information through your account, if applicable, or by sending an e-mail to [email protected]. For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an e-mail to [email protected]. We will also stop using your information and remove it from our servers and database promptly after receiving such an e-mail request sent to [email protected]. You may opt-out of, or otherwise withdraw consent to, certain uses or disclosures of your personal information that is not strictly necessary for the Service to function including, but not limited to, the use of your personal information by the Service to send you promotional and/or marketing e-mails, by using the unsubscribe feature in the e-mail or by sending us an e-mail to [email protected] with “Opt-Out” in the subject line.

7. How Do We Protect Your Information And How Long Do We Retain It?

A. We take steps to store the personal information we receive in a secure manner, and we have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Examples of some of the steps we take to protect your information are encrypting your data while storing it and when transferring it, and limiting internal access to your personal information to those that need it to perform a specific task or to deliver the Service to you. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.

B. If you are visiting the Site from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.

C. Our retention periods for personal information are based on business needs and legal requirements. We will retain your personal information for as long as is necessary for the purpose(s) for which it was collected and any other permitted, linked purpose, including in accordance with our data retention policies. If you request that we delete your personal information, or where it is otherwise no longer needed or kept in accordance with our retention policies, we either irreversibly anonymize the data (in which case we may further retain and use the anonymized data) or securely destroy the data. In some jurisdictions, personal information may be retained for a longer period if you consent to the retention or if retention is necessary for compliance with a legal obligation.

8. How Do We Use Network Technologies?

A. To enhance your online experience with us, our web page(s) may use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your email address or other personal information. Once you choose to provide personal information, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of cookies through your device or browser, certain features of the Services may not function properly without the aid of cookies. Please see Section 9 for more information.

B. Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

C. We and/or our service providers and/or social media platforms that we use (such as Meta and TikTok) may also use "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags"). A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of our Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. We use Pixel Tags in connection with some of our Site and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. When used in HTML-formatted e-mail messages, Pixel Tags can inform the sender of the e-mail whether and when the email has been opened.

D. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as "clickstream data”, can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site.

E. Do Not Track. Like many websites, the Site does not specifically respond to browser “do-not-track” signals. However, our Site honors Global Privacy Control (GPC) signals from your browser. You can learn more about the GPC online. If you choose to use the GPC signal, you will need to download and turn it on for each supported browser or browser extension you use.

9. Cookie Policy: How Do We Use Cookies and Third Party Technologies?

A. Types of Cookies. The types of cookies that we may use on the Site include the following:

1. Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.

2. Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us improve the way our Site works, for example, by assisting users in finding merchandise or other items or information.

3. Functionality cookies. These cookies are used to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by name and remember your preferences.

4. Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We may use this information to make our Site and the information displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

B. Our Use of Cookies. Our Site is powered by Shopify. You can find more information about the individual cookies we use on the Site and the purposes for which we use them in the tables provided at https://www.shopify.com/legal/cookies. In addition, we use the following cookie:

Cookie Name	Purpose
_fbp	This cookie is used by Facebook to connect us to their advertisement products such as real time bidding for our advertisements so that we can present relevant advertising on Facebook.com.

 

C. Third Party Tools. In addition to the service providers mentioned in Section 5 above, our Site may use third party tools. These companies may collect your personal data from us, or from you when you interact with our digital property.

D. Acceptance and Management of Cookies. By clicking “Accept” on the cookie consent box on our interactive banner when you first access our Site and by continuing to access and use our Site, you accept our use of the cookies described above. If you do not accept such use, please do not use our Site.

However, you may manage, disable and remove cookies from your computer using the following methods by modifying your browser settings: Please follow the instructions provided by your browser to manage, disable or remove cookies.

Please be careful in making your choices. By blocking the receipt of all cookies indiscriminately, including the technical ones, without providing a specific exception for the Site, you may no longer be able to surf the Site or to benefit, in whole or in part, from its functionalities. Furthermore, removing the technical cookies could remove the preferences set up by using the Site so that you could no longer find products or services you expect to see.

In order to disable third parties’ cookies or identifiers, please see the privacy policies of those third parties.

10. Collection of Information by Others

Our Site may include links to, and plug-ins from, websites or applications operated by third parties (“Third-Party Sites”). We do not control any Third-Party Sites, and are not responsible for any personal information they may collect. Please check the privacy policies of these Third-Party Sites to learn how they collect, use, store and share information that you may submit to them or that they collect.

11. SMS and Other Text Messaging

Certain Services utilize SMS or other text messaging. For example, we may use text messaging to send promotional messages. When you use these services you may be subject to messaging and data charges from your wireless carrier, depending on your wireless data plan and rates. Please note that carriers are not liable for delayed or undelivered messages, and we also disclaim any liability and will not be responsible for damages resulting from such delays or undeliverable messages.

To cancel receipt of text messages from us, you may reply STOP to any message you receive.

12. Additional Information for European Residents

A. Your Legal Rights

If you are an EEA/Switzerland/UK resident, under the data protection laws that apply to you and subject to any applicable limitations and exceptions, you may contact us at [email protected] to exercise your rights to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request corrections of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of any new data you provide to us.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons of which we will notify you, if applicable, at the time of your request.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party), and you object to this processing as you feel it impacts your fundamental rights and freedoms. You may also object to our processing your personal information for direct marketing purposes. In some cases, we may deny your objection if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal information. You may request us to suspend the processing your Personal Data in the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal information to you or to a third party. Upon request, we will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially consented for us to use, or that we used in performing our obligations under a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal information. This withdrawal will not, however, affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Make a complaint to a regulator. You have the right to make a complaint at any time to your local supervisory authority with regard to data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority, so please contact us in the first instance.

B. Purposes / Legal Basis For Which We Will Use Your Personal Information

For EEA/Swiss/UK residents, data protection laws require us to explain to you our legal basis for using your personal information. Most commonly, we will use your personal information under the following legal bases:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to perform our obligations under a contract we are about to enter into, or have entered into with you; and
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at [email protected].

Purpose/Activity	Type of Personal Information	Lawful basis for processing
To process your payment to purchase goods or services	Credit/debit card details	Performance of a contract between you and us
To register you as a new customer and to create and maintain your account	Name, email address, address, username, password, date of birth, and phone number	Performance of a contract between you and us
To process and deliver your order for our goods including: (a) Manage payments, fees and charges; and (b) Collect and recover money owed to us	Name, email address, address, phone number, date of birth, credit/debit card details and transaction history.	Performance of a contract between you and us Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Asking you to provide feedback	Name, username, email address and transaction history.	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To deal with any enquiries, correspondence, concerns or complaints you have raised	Name, username, email address, and information about the issue raised	Legitimate interests – to allow us to respond and deal with any queries, correspondence, concerns or complaints raised by you
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Name, username, email address, standard web log entries that contain your IP address, page URL, browser plug-in types and versions, device information and identifier, operating system information, and timestamp	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Name, username, email address, standard web log entries that contain your IP address, page URL, browser plug-in types and versions, device information and identifier, operating system information, and timestamp	Consent, when required Necessary for our legitimate interests in providing our website and promoting our business
To use data analytics to improve our Site, goods and services, marketing, customer relationships and experiences	Name, username, email address, standard web log entries that contain your IP address, page URL, browser plug-in types and versions, device information and identifier, operating system information, and timestamp	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you	Your name and email address	Consent, when required Necessary for our legitimate interests in providing our Site and promoting our business

 

13. Children and Young People’s Information

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the GDPR and the Children's Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about our Site(s), wish to find out if your child has accessed our services, or wish to remove your child's personal information from our servers, please contact us at [email protected]. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. If we discover that a child under the age of 13 has provided personal information to us, we will make efforts to delete the child’s information in accordance with COPPA. If you believe that your child under 13 has gained access to our Site(s) without your permission, please contact us at [email protected] with “COPPA” in the subject line.

14. Additional Information for Residents of Certain States

This Section provides additional information for individuals who reside in U.S. states with comprehensive data protection laws (collectively, “Applicable State Privacy Laws”), to the extent that our collection and handling of personal information is subject to these laws. These include residents of California, Texas, Nebraska, and other states with similar laws and regulations, as enacted or amended from time-to-time.

A. Notice at Collection for California Residents: We collect the categories of personal information identified in Section 1 (What Information Do We Collect), above, for the purposes identified in Section 4 (How Do We Use The Information We Collect), above, and retain personal information for the period described in Section 7 (How Do We Protect Your Information And How Long Do We Retain It), above. We may “sell” or “share” your personal information, as the California law defines those terms. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you. To the extent you provide the Company with personal information about other California residents, you are responsible for providing this notice to them.

B. Additional Information About Disclosures of Personal Information

We may disclose your personal information to third parties for the following “business purposes” as that term is defined under Applicable State Privacy Laws and as a supplement to the disclosure described in Section 5 (Do We Disclose Your Personal Information), above:

• Service Providers: We may disclose any of the categories of personal information listed above to service providers for the business purpose of performing services on our behalf, as well as (a) helping to ensure security and integrity, (b) debugging, (c) short-term transient use, (d) internal research, and (e) activities to maintain or improve the quality or safety of a service or device.
• Professional Advisers and Related Third Parties: We may disclose any of the categories of personal information listed above to the professional services providers listed in Section 5 (Do We Disclose Your Personal Information), above, for the business purpose of auditing compliance with policies and applicable laws in addition to performing services on the Company’s behalf.
• Affiliated Companies: We may disclose any of the categories of personal information listed above to other companies within our corporate group for the business purposes of: (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.

C. Sales and Targeted Advertising

We do not “sell” your personal information as most people would understand that term, meaning that we do not disclose your personal information to any third party in exchange for a monetary payment. However, as is common practice among businesses operating online, we may allow third parties to receive information about you via cookies for purposes of analyzing and optimizing our services, to personalize your online experience by providing advertisements that are more relevant to you, and for statistical research and analytics. These activities may be defined as “sale” of personal information or use of personal information for targeted advertising (or “sharing” for cross-context behavioral advertising).

In the last 12 months, we have disclosed Internet or Other Electronic Network Activity Information, to our marketing partners (marketing and analytics partners, advertisers, and social media platforms). We disclose this personal information in order to deliver marketing messages, tailor advertising on the Site and in other interactions that you have with us while online, and to help us understand the effectiveness of those marketing and advertising efforts. We have no actual knowledge that we have sold or “shared” the personal information of children under 16 in the last 12 months and we have no intention to do so.

We understand that targeted advertising isn’t for everybody, and you have options. You may modify your cookies settings as described above in Section 9 of this Policy, or opt-out of this type of activity using the methods described further below.

D. Your Privacy Rights

Subject to any applicable limitations and exceptions, you have the following rights under Applicable State Privacy Laws:

• Right to Access/to Know: You have the right to request information about whether we process your personal information, to access that information, and certain details about how we use it. If you are a resident of California, you have the right to information about whether we process your personal information, and our collection, use, and disclosure of categories of your personal information. In addition, in lieu of a right to access, you have the right to submit a verifiable request to know specific pieces of your personal information obtained from or about you.
• Right to Know Disclosures: Residents of certain states have the right to obtain, at the Company’s option, a list of specific third parties to which we have disclosed either your personal information, or any personal information.
• Right to Delete: You have the right to submit a verifiable request to delete personal information that we have collected from or about you.
• Right to Correct: You have the right to submit a verifiable request to correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of processing the personal information.
• Data Portability: You have the right to request that we provide you, or send to a third party, a copy of your personal information in electronic form that you provided to us.
• Non-Discrimination: You have the right not to be discriminated against for exercising any of your privacy rights under Applicable State Privacy Laws. To be clear, we do not tolerate unlawful discrimination of any kind.
• Right to Opt Out of Sale/Targeted Advertising: You have the right to opt out of the sale of your personal information and the disclosure of your personal information for targeted advertising (or “sharing” for cross-context behavioral advertising). You may also implement a browser setting or extension to communicate your selling and sharing preferences automatically to the websites you visit.

We honor your right to opt out of the sale and sharing of your personal information as signaled by a universal opt out signal or Global Privacy Control (“GPC”). To enable GPC, you can visit the Global Privacy Control page at https://globalprivacycontrol.org. If you download a supported browser or extension and exercise your privacy rights with GPC, we will turn off certain third-party cookies on our website after our website detects a GPC signal. However, if you visit our Site from a different device or from a different browser on the same device, you will need to opt-out or use an opt-out preference signal for that browser and/or device.

E. How to Exercise Your Privacy Rights

We will respond to requests in accordance with Applicable State Privacy Laws, if we can verify the identity of the requestor. You can exercise these rights in the following ways:

• Emailing us at [email protected]

You may also have the right to appeal any decision we make in response to a request to exercise privacy rights, by using the methods listed above. We will inform you of any action taken in response to an appeal, along with a written explanation of the reasons for our decision(s), in accordance with Applicable State Privacy Laws.

F. Notice of Right To Opt Out of Sale/Targeted Advertising

To opt out of the sale of your personal information or its use for targeted advertising (“sharing”), you may modify your cookies settings or use an opt-out preference signal, such as the Global Privacy Control (GPC). We process these opt-out preference signals in a frictionless manner. This means that if you enable the GPC, we will automatically be notified that you have opted out of sale of your personal information or its use for targeted advertising, and we will automatically process the opt-out preference signal to opt you out of the sale of your personal information or its use for targeted advertising.

To enable the GPC:

1. Go to Global Privacy Control — Take Control Of Your Privacy.
2. Click on “Get Started”.
3. Click on “View All Downloads”.
4. Under “Browsers + Extensions”, select a participating company and click “Download”.
5. Follow the instructions provided by the selected company for installing its browser.

If you have enabled the GPC, we will not be able to track your activity through the web. This may affect our ability to personalize ads according to your preferences. However, if you visit our Site from a different device or from a different browser on the same device, you will need to opt-out of sale/sharing using any interactive form we make available or use an opt-out preference signal for that browser and/or device.

G. How We Will Verify Your Request

If you submit a request, we verify your identity by matching personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

H. Authorized Agents

You may designate an authorized agent to exercise your rights. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity. You can obtain an “Authorized Agent Designation” form by contacting us at [email protected]. Alternatively, you can provide a power of attorney compliant with applicable law.

I. California’s “Shine the Light” Law

California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personal information. To make such a request, please contact us at [email protected] with "Request for Privacy Information" in the subject line, or complete an online form which we may make available. Please include enough detail for us to locate your file; at a minimum, your name, e-mail, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

15. Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future we plan to use your personal information in a way that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a change to our Privacy Policy, we will email the updated policy to the email address that you provided to us. Your continued use of the Service following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

16. Our Contact Information

If you have any questions or concerns about this Privacy Policy you may contact us at

Kayne LLC
1727 Berkeley St.
Studio 1
Santa Monica, CA 90404
[email protected]