Privacy Policy

NAGHEDI™

PRIVACY POLICY

 

Last Updated: August 1, 2023

 

1.                   INTRODUCTION.

 

This Privacy Policy (“Privacy Policy”) governs how Entrelaced, LLC and our parent, subsidiary, and affiliate companies (collectively, “Naghedi”, “we”, “us”, or “our”) use Personal Information (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or “your”) of our website, https://naghedinyc.com/, and of our other affiliated websites, subdomains, mobile versions, applications (including mobile applications), and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Service”), the use of which shall be subject at all times to the Terms of Use. Any terms used but not defined herein are defined in the Terms of Use or Additional Terms, as the case may be.

 

We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, certain government identifiers (e.g., Social Security Numbers), account numbers and log-in credentials, precise geolocation (e.g. physical address), racial or ethnic origin; religious beliefs, contents of a consumer’s mail, email, and text messages, or a consumer’s genetic information (collectively, “Sensitive Personal Information”) that is shared with us in connection with users’ use of the Service. You may choose whether or not to provide or disclose Personal Information in connection with your use of the Service. If you choose not to provide the Personal Information we request, you may still visit and use parts of the Service, but may be unable to access or use certain features, options, programs, and services thereof (including, without limitation, the purchase of Merchandise through the Service). IF YOU DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY AT ANY TIME, YOU SHOULD NOT USE THE SERVICE OR PURCHASE MERCHANDISE THROUGH THE SERVICE.

 

The Service may contain links to or advertisements for websites operated by third parties and, therefore, not owned or controlled by Naghedi. The links to and advertisements concerning third-party websites, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of these third-party websites or for your interactions with them, and you visit them at your own risk. Our inclusion of links to or advertisements for such third-party websites does not imply any endorsement of the material, products, or services provided by such third-party websites or any association with such third-party websites or their owners or operators whatsoever.

 

2.                   CHANGES TO THIS PRIVACY POLICY.

 

We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all the terms and conditions of this Privacy Policy that apply to you, as well as the Service, the Merchandise, and/or any Content. We display the effective date of this Privacy Policy at the top of this page, indicated by the “Last Updated” legend. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING THE “LAST UPDATED” DATE TO THE SERVICE. If you use the affected Service after the changes become effective, it means you are agreeing to be bound by the changes to this Privacy Policy, as the case may be. You should check on a regular and frequent basis and review the terms and conditions of this Privacy Policy that apply to you so you are aware of the current rights and obligations that apply to you.

 

 

3.                   CHILDREN’S PRIVACY.

 

The Service is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might have any information from or about a person under the age of thirteen (13), please contact us at info@naghedinyc.com. Visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting children’s privacy online.

 

4.                   INFORMATION COLLECTED AND HOW WE COLLECT IT.

 

We may receive and/or collect the following categories of Personal Information:

 

        Identifiers, such as your name, email address, postal address, Internet Protocol (IP) address, and phone number;

 

        Transaction Information, such as the form of payment used to purchase Merchandise through the Service and the associated billing address, as well as the shipping address where we (via our third-party carrier) will send the Merchandise;

 

        Account Information, such as your Account password and Transaction Information saved and stored in your Account;

 

        Geolocation information, such as the region in which you are located when you access the Service;

 

        Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding a your interactions with a website, application, or advertisement;

 

        Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes; and

 

        Sensitive Personal Information, such as Account log-in information and geolocation.

 

The sources from which we obtain Personal Information are described below.

 

4.1          Personal Information You Provide To Us Through the Service.

 

If you send us a “Contact Us” request or feedback, set up an Account through the Service, purchase or receive Merchandise or other products or services through the Service, or otherwise enter into a contract with us, or enter or upload information, such as by filling in forms (including, without limitation, those form fields requesting Transaction Information in connection with the purchase of Merchandise through the Service), uploading documents to the Service, or making Postings on public forums or interactive areas the Service, then you may provide us with, and we may collect, certain information that may constitute Personal Information.

 

We generally do not request on or through the Service other information that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport), although we reserve the right to do so when such information is necessary to provide the services offered through the Service and fulfill your requests made through the Service.

 

4.2          Personal Information You Provide to Third Parties Through the Service.

 

Certain of our third-party service providers (including, without limitation, the Payment Processor) and other business partners may collect and use certain Personal Information in performing their services and/or functions, and may share that Personal Information with us for our use, all to enhance your experience and deliver certain services (including, without limitation, the purchase of Merchandise and fulfillment of those orders). Please refer to the Payment Processor’s terms and conditions for information on how they collect and use, and may share with us, Transaction Information in connection with purchases made through the Service, which are available at www.shopify.com.

 

4.3          Information Provided by Third Parties.

 

We may collect information, including Personal Information, about you through non-affiliated third parties (including, without limitation, Third-Party Sellers). For example, you may be able to place purchases of Merchandise through Third-Party Sellers, or you may be able to access the Service through a social networking account owned and operated by Third-Party Social Media Services, in which case you may allow us to have access to certain Personal Information in such social media profile(s). If you access the Service from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information. We may also receive Personal Information from third party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.

 

4.4          Information Collected Automatically.

 

Certain information is collected automatically when you access or use the Service by means of various software tools described below. We have a legitimate interest in using such information for log-in and systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of the Service. Alone or in combination with other information, such automatically collected information may constitute Personal Information.

 

Some of our service providers (described in Section 4.2 above) and business partners may use “cookies” or other methods to gather information regarding your use of the Service. Additional information about cookies is provided in this Section below. Those persons, companies, and entities may use these cookies or other tracking methods for their own purposes by combining information about your use of the Service with any Personal Information about you that they may have. We are not responsible for any third-party use of such information, and we encourage you to review the privacy policies and practices of all such third parties.

 

The following information, some of which may constitute Personal Information, is collected automatically when you access or use the Service:

 

                                                    (1)            Log Files on the Service. The information inside the log files includes IP addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.

 

                                                    (2)            Cookies. When you use or visit the Service, our servers may send a cookie to your computer. Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain information that individually identifies you, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies. We use cookies to make interactions with the Service easy and meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session and disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that, if you disable your web browser’s ability to accept cookies, you will be able to navigate the Service, but you may not be able to successfully use all of the features of the Service. Information regarding how we may use different categories of cookies and your options for managing cookie settings is set forth below.

 

Type of Cookie

Description

Managing Settings

Required Cookies

Required cookies enable you to navigate the Service and use features, such as accessing secure areas of the Service and using our services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into the Service, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into the Service and to process your online transactions and requests.

Because required cookies are essential to operate the Service, there is no option to opt out of these cookies.

Performance Cookies

These cookies collect information about how you use the Service, including which pages you go to most often and whether you receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information collected by these cookies is aggregated and anonymous. They are only used to improve how the Service functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Service. We may also utilize Flash cookies for these purposes.

To learn how to opt out of performance cookies using your browser settings click here.

 

 

Functionality Cookies

Functionality cookies allow the Service to remember information you enter and choices you make (such as your username, language, or your region), and to provide enhanced, more personal features. These cookies also enable you to optimize your use of the Service after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

To learn how to opt out of functionality cookies using your browser settings, visit https://www.aboutcookies.org/.

Targeting or Advertising Cookies

From time to time, we may track and analyze usage and volume statistical information from individuals who visit the Service. We sometimes use our own cookies as well as cookies delivered by third parties to track the performance of advertisements. For example, we may use cookies remember which browsers have used or visited the Service. The information provided from third parties does not include Personal Information, but this information may be re-associated with Personal Information after we receive it. For example, as you browse the Service, cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Service. We also contract with third-party advertising networks and similar partners that collect IP addresses and other information from web beacons (see below) through the Service, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting website navigational information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts. Third parties with whom we partner to provide certain features through the Service or display advertising based upon your web browsing activity use Flash cookies to collect and store information. Flash cookies differ from browser cookies based on the amounts and types of data stored, and the purposes for which data is stored.

To learn more about these and other advertising networks and their opt-out instructions, visit https://optout.networkadvertising.org/.

 

4.5          Other Tracking Technologies.

 

When you use or visit the Service, we may collect your IP address to track and aggregate information. For example, we may use IP addresses to monitor the regions from which you navigate the Service. We may also use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon to compile information about your usage of the Service and interaction with email communications from us and to operate and improve the Service and our email communications. For example, we may place web beacons in Automatic Communications or Voluntary Communications (including, without limitation, marketing emails) that notify us when you click on a link in the email that directs you to the Service.

 

4.6          Analytics Software Tools.

 

We use analytics software, such as Google Analytics and/or Adobe Analytics, to help us analyze the traffic through the Service. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/. You can opt out of Google Analytics at http://www.google.com/ads/preferences/plug-in/.

 

5.                   THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION.

 

If you submit or we collect Personal Information through the Service or as otherwise described above, we may use such Personal Information for the following general purposes:

 

        To comply with our obligations under Applicable Law;

 

        To provide, analyze, administer, improve, and personalize the Service;

 

        To communicate with you in connection with the Service, Merchandise you have purchased, and other products, services, events, or offerings made available through the Service;

 

        To send you updates and promotional materials pertaining to Naghedi, the Service, or Merchandise;

 

        To provide personalized advertising to you;

 

        To identify and authenticate your access to the parts of the Service that you are authorized to access;

 

        For recruiting and human resources administration purposes;

 

        For research and development relating to the Service and the products and services we offer and/or provide to you;

 

        For advertising purposes;

 

        For electronic direct marketing in compliance with Applicable Law;

 

        To protect our rights and/or our property and to ensure the technical functionality and security of the Service;

 

        For the performance of our contract with you (including, without limitation, the purchase agreement contained in the Merchandise Purchase Policy in connection with Merchandise you have purchased through the Service) or to take steps at your request before entering into a contract; and

 

        Where you have given actual or constructive consent (including, without limitation, by placing an order for Merchandise through the Service).

 

6.                   HOW WE DISCLOSE PERSONAL INFORMATION.

 

We do not sell, lease, rent, or otherwise disclose the Personal Information collected on or through the Service to third parties unless otherwise stated below or with your consent.

 

6.1          Our Third-Party Providers.

 

We transfer Personal Information to our third-party service providers and business partners (including, without limitation, the Payment Processor) to perform tasks on our behalf and to assist us in providing the Service, as discussed in Section 4.2. above. We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party service providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-party service providers and business partners to comply with Applicable Law and their respective privacy policies in connection therewith and we take no responsibility for their privacy practices and compliance.

 

6.2          Our Joint Promotion Partners.

 

From time to time, we may partner with other companies (including, without limitation, Third-Party Sellers) to jointly offer products or services or to improve existing products or services (collectively, “Joint Promotion Partners”). If you purchase or specifically express interest in a jointly-offered product or service from us, we may share Personal Information collected in connection with your purchase or expression of interest with the relevant Joint Promotion Partner(s). We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with Joint Promotion Partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those Joint Promotion Partners to comply with Applicable Law and their respective privacy policies in connection therewith and we take no responsibility for their privacy practices and compliance.

 

6.3          In the Event of Merger, Sale, or Change of Control.

 

Naghedi may assign or transfer its rights and/or delegate its obligations under this Privacy Policy and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Naghedi, or is merged with or into Naghedi, as part of a merger, acquisition, sale, or other change of control.

 

6.4          Social Media Plug-Ins.

 

To the extent the Service uses social media plug-ins made available by Third-Party Social Media Services (collectively, “Social Media Plug-Ins”) to enable you to easily share information with others, the operator of the Social Media Plug-Ins can place a cookie on your device when you use or visit the Service, enabling that operator to recognize individuals who have previously used or visited the Service. If you are logged into a Third-Party Social Media Service for its Social Media Plug-In while using or browsing the Service, that Social Media Plug-In allow that Third-Party Social Media Service to share information, including Personal Information, about your activities through the Service with other users of their product or service. For example, Facebook Social Plug-Ins would allow Facebook to show your “Likes” and comments on our pages to your Facebook friends and allow you to see your friends’ Facebook activity through the Service. We do not control or take responsibility for any content used by Social Media Plug-Ins or their corresponding Third-Party Social Media Service or their compliance with Applicable Law and their respective privacy policies. For additional information about Social Media Plug-Ins, please refer to their corresponding Third-Party Social Media Service’s privacy and data/information sharing statements/policies.

 

6.5          Other Disclosures.

 

We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to (i) comply with legal process, (ii) enforce the Terms of Use, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of Naghedi, the Payment Processor, Third-Party Sellers, other Service users, and the public.

 

7.                   RETENTION OF PERSONAL INFORMATION.

 

We will keep your Personal Information while you have an Account with us or while we are providing Merchandise or other products and/or services to you. Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:

 

        To fulfill the purposes described in Section 5 above (“The Purposes For Which We Use Personal Information”), including, without limitation, to comply with Applicable Law and to fulfill purchases of Merchandise you make through the Service; or

 

        To respond to any questions, complaints, or claims made by our or on your behalf.

 

We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Policy.

 

8.                   YOUR RIGHTS.

 

8.1          Rights Relating to Personal Information.

 

If you have an Account, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your Account on each of our supported domains. We also permit you to:

 

        Delete all content browsing information and opt-out of further participation in data associated with the current device you use to use or browse the Service; and

 

        Delete all information related to email/newsletter subscriptions. To exercise this right, please email info@naghedinyc.com.

 

        Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability), object to the processing of Personal Information collected in and through the Service, or withdraw your consent (as applicable), you may submit a request to Naghedi’s Privacy Officer either by email at info@naghedinyc.com or by mail at 88 Lexington Avenue, TH2, New York, New York 10016, United States of America, or submit a request to whichever of our specific domains you have made use of. Because our internal systems only make use of first-party cookies and cannot associate user data between the domains we control, you must submit any such request to whichever domain you have used. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have a right to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at info@naghedinyc.com so we have an opportunity to address your concerns directly before you do so.

 

8.2          Opting Out of Promotional Emails.

 

You may choose not to receive future Voluntary Communications or other promotional or advertising emails from us by clicking the unsubscribe link at the bottom of each email that you receive from us, or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to info@naghedinyc.com. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request, as well as Automatic Communications, such as administrative, maintenance, and operational emails (for example, in connection with a password reset request).

 

If you receive and want to opt-out of Voluntary Communications or other promotional or advertising emails from us, then you can click the unsubscribe link at the bottom of the relevant email or contact us; Naghedi is not responsible for promotional or advertising emails from Third-Party Sellers.

 

9.                   DATA SECURITY.

 

The security of Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information from unlawful use, unauthorized access, or disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.

 

10.               TRANSFERS OF PERSONAL INFORMATION FROM THE EUROPEAN UNION (EU) OR EUROPEAN ECONOMIC AREA (EEA), THE UNITED KINGDOM (UK), OR SWITZERLAND TO THE UNITED STATES OF AMERICA.

 

In order to communicate with you or provide the Service, the information (including Personal Information) that we collect from you may be transferred to, stored, used, and processed by Naghedi in the United States of America or one of our service providers based inside or outside of the United States of America. Such entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.

 

If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individual States, please note that you are transferring your Personal Information to the United States of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in this Privacy Policy. When you provide Personal Information to us or our service providers or business partners (including, without limitation, the Payment Processor and Third-Party Sellers), you consent to the processing of your information in the United States of America as the Service is offered from the United States of America. We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Policy, and that all information you provide to us is stored on our secure servers or those of our service providers and business partners (including, without limitation, the Payment Processor and Third-Party Sellers).

 

YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES OF AMERICA AND ITS INDIVIDUAL STATES TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES OF AMERICA, YOU SHOULD NOT SHARE YOUR INFORMATION WITH US, OR MAKE USE OF THE SERVICE.

 

TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISDICTION OTHER THAN THE UNITED STATES OF AMERICA. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION OR THE BROADER EUROPEAN ECONOMIC AREA. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.

 

11.               HOW WE RESPOND TO DO NOT TRACK SIGNALS.

 

As explained above in Section 4.4, the technologies used through the Service may be used to track Service users’ activity through the Service. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Service may not respond to Do Not Track signals at this time.

 

12.               NOTICE TO CALIFORNIA RESIDENTS.

 

California Residents: Pursuant to the California Consumer Privacy Act of 2019 and the California Privacy Rights Act of 2020 (each as may be amended from time to time, the “CCPA” and “CPRA,” respectively, and together, the “California Privacy Laws”), you have certain rights with respect to your Personal Information. For the purposes of this Section, Personal Information is used as defined in the CCPA. Naghedi reserves the right to verify all requests made pursuant to the California Privacy Laws.

 

12.1        Requests to Know.

 

You have the right to request that we disclose:

 

        The categories of Personal Information we have collected about you;

 

        The categories of sources from which we have collected Personal Information about you;

 

        Our use of the Personal Information we have collected about you;

 

        The categories of Personal Information about you we have sold or disclosed for a business purpose;

 

        The business or commercial purposes for selling or collecting Personal Information about you;

 

        The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and

 

        The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date of your request.

 

The delivery of our response to your request to know may take place electronically or by mail. We are not required to respond to requests to know more than twice in a twelve (12)-month period.

 

12.2        Requests to Delete.

 

You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:

 

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

 

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

 

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

 

        Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by Applicable Law;

 

        Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.), as may be amended from time to time;

 

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

 

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

 

        Comply with an obligation under Applicable Law; and/or

 

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

 

12.3        Right to Opt Out of the Sale of Personal Information.

 

You have a right to opt out of the sale of Personal Information. You may, at any time, direct us to not sell Personal Information about you to third parties. If you exercise your right to opt out of the sale of Personal Information about you, we will not sell Personal Information about you. Any Personal Information collected in connection with your request to opt-out of the sale of Personal Information about you will be used only to facilitate that request. You may submit opt-out requests by emailing us at info@naghedinyc.com.

 

12.4        Requests to Correct Inaccurate Personal Information.

 

You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.

 

12.5        Authorized Agents.

 

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to California Probate Code Sections 4000-4465, as may be amended from time to time, may submit a request on your behalf. You may also make a verifiable consumer request on behalf of your minor child.

 

12.6        Methods for Submitting Consumer Requests and Our Response to Requests.

 

To make a request pursuant to your California Privacy Laws rights, you must contact Naghedi’s Privacy Officer either by email at info@naghedinyc.com or by mail at 88 Lexington Avenue, TH2, New York, New York 10016, United States of America.

 

Upon receipt of such request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five (45) days of receipt. In order to protect your privacy and the security of Personal Information about you, we verify your request by requesting for additional identifying information that will only be used to verify your identity and for no other purpose.

 

12.7        Categories of Personal Information We Have Sold in the Last Twelve (12) Months.

 

We have sold the following categories of Personal Information during the last twelve (12) months:

 

        Identifiers;

 

        Commercial information, including records of Merchandise and other products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;

 

        Internet or other electronic network activity information, a consumer’s interaction with an Internet website or advertisement;

 

        Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes; and

 

        Sensitive Personal Information.

 

For information on how to opt out of the sale of your Personal Information, see Section 12.3 above.

 

12.8        Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months.

 

We have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months:

 

        Identifiers;

 

        Commercial information, including records of Merchandise and other products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;

 

        Internet or other electronic network activity information, a consumer’s interaction with an Internet website or advertisement;

 

        Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes; and

 

        Sensitive Personal Information.

 

12.9        The Right to Non-Discrimination.

 

You have the right not to be discriminated against for the exercise of your California Privacy Laws rights described above. Unless permitted by the California Privacy Laws, we will not:

 

        Deny you Merchandise or other goods or services;

 

        Charge you different prices or rates for Merchandise or other goods or services, including through granting discounts or other benefits, or imposing penalties;

 

        Provide you a different level or quality of Merchandise or other goods or services; or

 

        Suggest that you may receive a different price or rate for Merchandise or other goods or services or a different level or quality of Merchandise or other goods or services.

 

12.10     Shine the Light Law.

 

California’s “Shine the Light” law allows California residents to obtain a list of third parties to whom a business has disclosed Personal Information for their direct marketing purposes. However, if a business adopts and discloses in its privacy policy a policy of not disclosing customers’ Personal Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personal Information and by providing a cost-free means to exercise that right.

 

Personal Information submitted will only be used for marketing and promotional purposes. Whenever you agree to allow us to collect Personal Information, we provide you with an option to prevent such information from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time by sending an email to info@naghedinyc.com.

 

Because we include a comprehensive Privacy Policy and provide you with details on how you may opt out of the use of your Personal Information by third parties for direct marketing purposes, we are not required to provide you with the third-party list.

 

13.               CONTACT US.

 

If you have any questions about this Privacy Policy, please contact Naghedi by email at info@naghedinyc.com.

 

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