Privacy Policy

This Privacy Policy describes how POLICANE CO., LLC, a Delaware limited liability company (“we“, “us“, or “our“) collects, uses, and discloses your personal information when you visit or otherwise communicate with us from or through www.policane.net (the “Site“) or otherwise communicate with us through newsletter, email, social media or other medium or use any services or interfaces on any other website maintained by us (collectively, the “Services“). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services. Changes to This Privacy Policy We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the “Last updated” date and take any other steps required by applicable law. Other Websites You cannot purchase our products on the Site.  You can order our products through our sister website at www.policaneus.com (“Sister Site”), if you are a purchaser (or use a shipping address) within the United States of America.  For sales outside of the United States, please contact us at Contact Us – Policane.  Our Sister Site is subject to its own privacy policy and terms of use.  Please review both prior to interacting with the Sister Site. How We Collect and Use Your Personal Information To provide the Services, we collect and have collected over the past 12 months personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us. In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others. What Personal Information We Collect The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term “personal information”, we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect. Information We Collect Directly from You Information that you directly submit to us through our Services may include:

• Basic contact details including your name, address, phone number, email.
• Order information including your name, billing address, shipping address, payment confirmation, email address, phone number.
• Account information including your username, password, security questions.
• Shopping information including the items you view, put in your cart or add to your wishlist.
• Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.
• Social Media – When you interact with us through social media (including Facebook, Instagram, Twitter, WhatsApp, and Snapchat) we collect personal information, such as your social media profile information and online behavior through this interaction consistent with your settings within the social media service. If you have provided us with your telephone number or email address, we may use this information to send targeted advertisements to you on these social media platforms.
• Sister Site – When you interact with our Sister Site, we collect personal information from you as set forth in the privacy policy for such site.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information We Collect through Cookies We also automatically collect certain information about your interaction with the Services (“Usage Data“). To do this, we may use cookies, pixels and similar technologies (“Cookies“). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services. Information We Obtain from Third Parties Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies who support our Sister Site and Services, such as Shopify.
• Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links. How We Use Your Personal Information

• Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to you account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and to enable you to post reviews.
• Marketing and Advertising. We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites.
• Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Communicating with you. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you.

Cookies Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store at our Sister Site with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites. Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners. How We Disclose Personal Information In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

• With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).
• With business and marketing partners, including Shopify, to provide services and advertise to you.  For example, we do not currently as of the last update, but may in the future use Shopify to support personalized advertising with third-party services. Our business and marketing partners will use your information in accordance with their own privacy notices.
• When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
• With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We have, in the past 12 months disclosed the following categories of personal information and sensitive personal information (denoted by *) about users for the purposes set out above in “How we Collect and Use your Personal Information” and “How we Disclose Personal Information”:

Category	Categories of Recipients
Identifiers such as basic contact details and certain order and account information Commercial information such as order information, shopping information and customer support information Internet or other similar network activity, such as Usage Data	Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners and data analytics providers) Business and marketing partners Affiliates

We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you.     User Generated Content The Services may enable you to post product reviews and other user-generated content. If you choose to submit user generated content to any public area of the Services, this content will be public and accessible by anyone. We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties. Third Party Websites and Links Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. Children’s Data The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted. As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age. Security and Retention of Your Information Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies. Your Rights and Choices Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

• Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
• Right to Delete. You may have a right to request that we delete personal information we maintain about you.
• Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
• Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

• Right to Opt out of Sale or Sharing or Targeted Advertising.  You may have a right to direct us not to “sell” or “share” your personal information or to opt out of the processing of your personal information for purposes considered to be “targeted advertising”, as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the “sale” or “sharing” of information for the device and browser that you use to visit the Site.
• Right to Limit and/or Opt out of Use and Disclosure of Sensitive Personal Information. You may have a right to direct us to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.
• Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
• Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
• Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, You may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law. Through our Sister Site, we may use Shopify’s ad services such as Shopify Audiences to help personalize the advertising you see on third party websites. To restrict Shopify merchants that use these ad services from using your personal information for such services, visit https://privacy.shopify.com/en. Complaints If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority. International Users For sales outside of the United States of America, please contact us at Contact Us – Policane. Please note that we may transfer, store and process your personal information outside the country you live in, including the United States. Your personal information is also processed by staff and third party service providers and partners in these countries. If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission’s Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection. State Specific Disclosures See Schedule 1 to this Privacy Policy for additional terms if you are a resident of California, Colorado, Connecticut, Utah or Virginia. Contact Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at info@policane.net or contact us via mail at Policane Customer Service, 4425 Military Trail Unit 110, Jupiter, FL 33458 USA SCHEDULE 1 STATE SPECIFIC DISCLOSURES This additional state-specific privacy disclosure page (“Disclosure”) supplements our Privacy Policy and is effective as of September 1, 2023.  Our Privacy Policy describes the personal information that we collect, the sources from which we collect it, the purposes for which we use it, the limited circumstances under which we share personal information, and with whom we share it. These additional disclosures, which serve as a Notice at Collection under the California Privacy Rights Act, are required by the California Privacy Rights Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act:  

1. Categories of personal information collected. The personal information that we may collect, or have collected from consumers in the twelve months prior to the effective date of this Disclosure, fall into the following categories established by the California Privacy Rights Act, depending on which Services are used:
   • identifiers such as your name, alias, address, phone numbers, IP address, your account log-in information, or a government-issued identifier (e.g. a social security number, which may be required for tax purposes if you are a re-seller);
   • personal information, such as a credit card number or other payment information;
   • information that may reveal age, gender, race, sexual orientation, or other protected classifications, for example if you post reviews voluntarily self-identifying your racial identity;
   • commercial information, such as purchase and content streaming activity;
   • internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details, and the content of email and text messages;
   • geolocation data, such as the location of your device or computer, which may in some cases constitute precise geolocation information;
   • audio or visual information, such as recordings you post in reviews or comments on the Site;
   • professional information, for example data you may provide about your business if you are a re-seller or distributor;
   • inference data, such as information about your purchase preferences; and
   • health data, such as data you provide in connection with reviews or to communicate your experiences with our products.

 

2. Categories of personal information disclosed for a business purpose. The personal information that we disclosed to the third parties identified in the “How Do We Disclose Personal Information” section of the Privacy Notice about consumers for a business purpose in the twelve months prior to the effective date of this Disclosure falls into the following categories established by the California Privacy Rights Act, depending on which Service is used:
   • identifiers such as your name, address, phone numbers, IP address, or a government identifier, for example if we use a third-party carrier to deliver your order, or if we use a third-party service to verify your identity;
   • personal information, such as a credit card number or other payment information, for example if we use a third-party payment processor;
   • information that may reveal age, gender, race, sexual orientation, or other protected classifications, for example if you choose to participate in a survey;
   • commercial information, such as the details of a product or service you purchased if a third-party service provider is assisting to provide that product or service to you;
   • internet or other electronic network activity information, such as if we use a service provider to help us gather crash reports for analyzing the health of our devices and services;
   • geolocation data, which may constitute precise geolocation data, such as providing a delivery partner the location of your garage in order to deliver a package;
   • audio or visual information, for example if a service provider reviews recordings of customer service phone calls for quality assurance purposes;
   • professional information, for example if we provide your account details to a service provider for verification as part of enrollment for a business or re-seller account; and
   • inference data, for example if we use a service provider to help us optimize the accuracy of your shipping address to make sure your order reaches you.

 

3. Advertising. As explained in the “Third Party Websites and Links” section in our Privacy Notice, we share limited information intended to provide your receipt of more useful and relevant ads and to measure their effectiveness.  Any personal information we may have shared for the purpose of cross-context behavioral advertising, as that term is defined by the California Privacy Rights Act, in the twelve months prior to the effective date of this Disclosure falls into the following categories:

 

1. • identifiers such as a cookie, a device identifier, or a code derived from applying irreversible cryptography to other information like an email address; we never share your name or other information that directly identifies you.
   • internet or other electronic network activity information, such as whether you downloaded an app or other measures of ad effectiveness;
   • inference data; while we do not share your specific shopping actions like purchases, product views, or searches with ad companies, we may share an advertising identifier and an estimate of the value of the ads they show you on our behalf so they can serve you with more effective ads for our products.

  The categories of third parties with whom We may share personal information for the purpose of cross-context behavioral advertising are identified in the “How Do We Disclose Personal Information” and” Third Party Websites and Links” sections of the Privacy Notice. We also process personal information for the purposes of targeted advertising as that term is defined under the Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, and Utah Consumer Privacy Act.  

4. Your Data Rights: You may have certain data rights under state privacy laws, including to request information about the collection of your personal information by us, to access your personal information in a portable format, and to correct or delete your personal information. If you wish to do any of these things, please contact us (See “Contact” section of the Privacy Notice).   Additionally, you may have the right to opt out of the processing of your personal data for targeted advertising, as defined by the Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act, or the sharing of your personal information for cross-context behavioral advertising, as defined by the California Privacy Rights Act. To do so, please visit contact us (See “Contact” section of the Privacy Notice).   If you enact the Global Privacy Control (GPC) opt-out signal on your browser, we will honor your opt-out preference accordingly. Customers under 16 years-old must opt in to receive cross-context behavioral advertising. We do not serve cross-context behavioral ads in customers’ child profiles.

  You may also have the right to appeal the denial of any of these rights by submitting a form that will be provided to you if we deny a data request. Depending on your data choices, certain services may be limited or unavailable. To ensure the security of your account, we will generally ask you to verify your request using the contact information you have already provided. If you do not have an account, or if you are an authorized agent under applicable state law, contact us (See “Contact” section of the Privacy Notice).  

5. No sale of personal information. In the twelve months prior to the effective date of this Disclosure, We have not sold any personal information of consumers, as those terms are defined under the California Privacy Rights Act.

 

6. California Privacy Rights Act Sensitive Personal Information Disclosure. The categories of data that we collect and disclose for a business purpose include “sensitive personal information” as defined under the California Privacy Rights Act. We do not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.

 

7. California Privacy Rights Act Retention Disclosure.  We keep your personal information to enable your continued use of our Services, for as long as it is required in order to fulfill the relevant purposes described in the Privacy Notice, as permitted or as may be required by law, or as otherwise communicated to you. For example, we retain your transaction history so that you can review past purchases (and repeat orders if desired) and what addresses you have shipped orders to, and to improve the relevance of products and content we recommend.

 

8. California Privacy Rights Act Non-discrimination Statement. We will not discriminate against any consumer for exercising their rights under the California Privacy Rights Act.

 

9. California Privacy Rights Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act De-identified Data Disclosure. We may use de-identified data in some instances. We either maintain such data without attempting to re-identify it or treat such data as personal data subject to applicable law.

 

10. Colorado Privacy Act Profiling Disclosure. We do not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act.

 

11. Annual Reporting for 2022.   Our Sites and Services were not available in 2022.  As a result, no customers initiated the data action process.  Through the Effective Date, no customers have initiated a data action process.