COSTWAY PRIVACY POLICY

Last Updated: December 15th, 2021

This Privacy Policy explains how Costway.com, Inc. and its subsidiaries (“Costway,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), engage with us on social media, or otherwise interact with us online.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.


CONTENTS

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics

Your Choices

Your California Privacy Rights

Contact Us


COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, submit or post content through our Services, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, postal address, phone number, payment information, and any other information you choose to provide.


Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

• Activity Information:We collect information about your activity on our Services, such as the products you viewed, the comments you authored and the pictures you uploaded.

• Transactional Information:When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.

• Device and Usage Information:We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.

• Location Information:In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).

• Information Collected by Cookies and Similar Tracking Technologies:We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.


Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from orders sent to you from friends who made such orders on our website or refer-a-friend type submissions made on our website. Additionally, if you create or log into your Costway account through a third-party platform (such as Google or Facebook), we will have access to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.


Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.


USE OF INFORMATION

We use the information we collect to manage and fulfill purchases, orders, payments, returns and refunds.

We also use the information we collect to:

• Provide, maintain, and improve our products and services;

• Send you related information, including confirmations, receipts, invoices, customer experience surveys, coupons and recall notices;

• Personalize and improve your experience on our Services;

• Send you technical notices, security alerts, and support and administrative messages;

• Respond to your comments, reviews and questions and provide customer service;

• Communicate with you about products, services, and events offered by Costway and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);

• Provide and administer our coupon and discount programs;

• Monitor and analyze trends, usage, and activities in connection with our Services;

• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);

• Facilitate contests, sweepstakes, and promotions (e.g., “Spin to Win”) and process and deliver entries and rewards;

• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Costway and others;

• Debug to identify and repair errors in our Services;

• Comply with our legal and financial obligations;

• Carry out any other purpose described to you at the time the information was collected or to which you consent.


SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

• We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.

• If you submit a product review or post content in another public area of our Services, we share this information publicly on our Services.

• If you choose to use integrations we offer on our Services, such as sharing your location through our Google Maps integration, we may share certain information with the integration partners.

• We may also share with and collect and process information for third parties, such as Klarna and/or payment plan or payment providers you select, who will process your information independently in accordance with their own privacy notices.

• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

• We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Costway, our users, the public, or others.

• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

• We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

• Personal information is shared between and among Costway and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.

• We share personal information with your consent or at your direction.

We also use and share aggregated or de-identified information that cannot reasonably be used to identify you.


ADVERTISING AND ANALYTICS

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. With your consent or at your direction, these entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Costway and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.


Do Not Track

Our Site does not support Do Not Track (DNT) at this time. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit www.donottrack.us.


YOUR CHOICES

Account Information

You may update and correct certain account information at any time by emailing us at [email protected] or by accessing your account settings in our mobile app. If you wish to deactivate your account, please email us at [email protected] or access your account settings in our mobile app, but note that we may retain certain information as required by law or for our legitimate business purposes.


Location Information

When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device. If you stop our collection of this location information, our Services may no longer function properly.


Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. We use the following third parties and services to engage in targeted advertising, but only with your consent or at your direction:

Rakuten

Rakuten may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes.

For more information about the collection, use and sale of your personal data and your rights, please use the below links:

https://rakutenadvertising.com/legal-notices/services-privacy-policy/

https://rakutenadvertising.com/legal-notices/services-privacy-rightsrequest-form/


Pinterest

We partner with Pinterest for targeted advertising. Pinterest’s mission is to bring users the inspiration to create the life they love through targeted advertisements that are thoughtful, respectful and relevant. Pinterest may also use the data we share with them in order to improve the safety and security on Pinterest and to generate aggregated and anonymous measurements about use of Pinterest’s ad services.


TikTok

We cooperate with TikTok for targeted advertising. TikTok is one of the most popular apps in the world and it provides companies with the opportunity to reach a large community of users who prioritize entertainment and authenticity. Targeted advertising with TikTok enables us to optimize ad delivery and measure campaign performance, among other purposes.


Criteo

We also cooperate with Criteo for retargeting. Criteo specializes in creating personalized advertisements through “Criteo Dynamic Retargeting” and “Criteo Sponsored Products”. Criteo builds advertisements for users who visit our website or mobile application and with publishers to display personalized advertisements. The aim is to deliver advertisements by displaying products that you might be interested in, based on your recent browsing behavior or search.

Example of a “Criteo Dynamic Retargeting” Product ad: if you visit and browse on website/mobile application A, on a subsequent online visit to website/mobile application B, you will see ads personalized by your browsing history on website/mobile application A.

Example of a “Criteo Sponsored Products” Product ad: if you make search on our website (“Criteo Sponsored Products”), you will see ads personalized by your search on that website. With Criteo service, you should receive personalized ads that are more relevant for you than the standard advertising you would receive without Criteo.


Google Ads

We use Google Adwords remarketing services to show advertisements on third party websites (including Google) to previous visitors of Costway. This might mean we show advertisements to visitors who, for instance, have not yet successfully completed the order process. The advertisements may be text based, or they may be display ads within the Google Display Network.

All collected data is used in accordance with our privacy policy, as well as Google’s. You can set up your preferences regarding advertisements through the Google Ad Preference page or opt out of Google’s use of cookies by visiting Google’s Ads Settings.


Social Media

When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain social media account information (e.g., name, username, email address, gender) as determined by the settings of the social media services to deliver the content or as part of the operation of the website, plug-in or application. Social media platforms may collect information about your use of our services and may notify other users of the platform about your activities on our website and device applications. Social media services may also use cookies or other technologies to provide services or track your online activities over time and across multiple websites and device applications. Your interactions with social media features are governed by the respective privacy policies of the companies providing the features.


Communications Preferences

You may opt out of receiving text messages or promotional emails from Costway by choosing to unsubscribe when receiving such SMS or emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.


Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.


YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.


California Consumer Privacy Act

In the preceding 12 months, we have collected the following categories of personal information through your online and offline interactions with us: identifiers, commercial information, internet or other electronic network activity information and geolocation data. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:


Category of Personal Information Categories of Recipients
Identifiers Advertising networks
Logistics companies
Payment and risk control companies
Operating platform
Commercial information Advertising networks
Logistics companies
Payment and risk control companies
Operating platform
Internet or other electronic network activity information Advertising networks
Data analytics providers
Payment and risk control companies
Operating platform
Geolocation data Advertising networks
Data analytics providers
Payment and risk control companies
Sensory Information Audio recordings of customer service calls or messages.

Costway does not sell your personal information. We do allow our advertising partners at your direction to collect certain device identifiers and electronic network activity via our Services to show ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the Advertising and Analytics section above.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) not be discriminated against for exercising these rights. You may make these requests by emailing us at [email protected] or calling us at 1-213-401-2666. We will verify your request by asking you to provide information related to your recent interactions with us, such as purchase order, information related to your favorite products and information related to your recently viewed products. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

Notice on Financial Incentives

We provide coupons and discounts to prospective and current consumers of Costway. Through our coupons and discounts, some consumers provide us with some personal information (e.g., email addresses) when they opt-in to our coupon or discount programs. As such, under the CCPA, our coupon and discount programs may be considered a financial incentive provided in exchange for the collection and retention of personal information.

We offer these programs to enhance our relationship with you so you can enjoy more of our products at a lower price. There is no obligation to opt-in and consumers may opt-out at any time. The details of each program are contained in each such program offering.

The consumer data received in exchange for your participation is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings and whether and to what extent you opt out of any offerings, but is roughly equivalent to the value of the coupon or discount offered.

Our coupons and discounts are voluntary, and you can opt-in to, or opt-out of, our programs at any time through the same means they are offered, or by contacting us at [email protected]


CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected]

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