PRIVACY STATEMENT updated December 19th, 2023

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Venus Walks (“VW” or “we”) is committed to protecting the privacy of all individuals who utilize the www.venuswalks.com website (the “Site”). Please read the following policy to understand how we collect, use and safeguard the information you may provide to us via this Site. This Privacy Policy may be revised from time to time, so please revisit this page often to remain fully informed of our policies.

SECTION 1 – COMPLIANCE WITH SAFE HARBOR FRAMEWORK[(S)]

The United States Department of Commerce and each of the European Commission and Switzerland have agreed on a set of data protection principles regarding the collection, use, and retention of personal information to enable U.S. companies to satisfy European Union (EU) and Swiss law requirements for adequate protection of personal information transferred from the European Economic Area (EEA) [and Switzerland] to the United States (collectively, the “Safe Harbor Privacy Principles”). VW has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view VW’s certification, please visit http://www.export.gov/safeharbor/.

SECTION 1.2 – CCPA COMPLIANCE

In compliance with full consumer rights granted under CCPA, customer information is never sold or distributed. Information may be accessed and/or revoked by a consumer at any time through provided unsubscribe links or contacting Edie Parker customer service via email during business hours Eastern Standard Time. SECTION 1.3 – Third Party Pixels and Cookies When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by selecting the unsubscribe button located at the bottom of our emails.

SECTION 2 - WHAT INFORMATION DO WE COLLECT FROM YOU AND WHAT DO WE DO WITH IT?

Our online store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Accordingly, when you submit personal information in connection with purchases made via the Site, such information is not collected by VW but rather is sent directly to Shopify. When you purchase something from our store, as part of the buying and selling process, Shopify collects the following personal information: your first name, last name, company name, mailing address, phone number, email address and credit card payment information. Please see Section 4 for more information on Shopify’s policies.

The Site allows you to register for an account powered by Shopify, which is completed at checkout, if so desired. An account is not required to make a purchase on the Site. When you register for an account via Shopify, you will be providing Shopify with your first name, last name and email address. Such registration information is used to make the purchase of products quicker and easier.

When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system, and your activity while using the Site. See Section 8 –COOKIES below, for information on technical information we collect as a result of your use of the Site and how we use such information.

SECTION 2.1 MARKETING CONSENT

In addition, the Site permits you to subscribe to our newsletter and automated email and SMS materials (serviced by Klaviyo) via a pop-up sign up unit and static sign up unit at the footer of every page on the Site. By submitting your information you are agreeing to the following terms, which are displayed at the time of sign up, prior to data submission: "By clicking SUBMIT, you agree to receive marketing text messages from Venus Walks at the number provided, including messages sent by autodialer. Consent is not a condition of any purchase. Message and data rates may apply. Message frequency varies. Reply HELP for help or STOP to cancel."

Once your sign up is complete, and with your explicit permission, we may send you emails about our store, new products and other updates. In order to sign up to receive the newsletter, you need only provide us your email address. You may opt out of receiving our newsletter or other communications from us by following the opt-out link provided in any email received or by un-checking the applicable box on the Check Out page hosted by Shopify.

The Site permits you to reach out to various Venus Walks departments through email. Whenever you send us an email, you will be providing us with your email address and any information you choose to provide in the text of your message. For example, you may choose to provide your full name, mailing address or other information necessary or helpful for us to address your query or concern. Your personal information will be used to respond to your communications.

ACCESS TO YOUR INFORMATION/ACCURACY OF INFORMATION

You may obtain from us, by mail or email, your personal information contained in our records. We strive to maintain the accuracy of any personally identifiable information that may be collected from you, and will use our commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, it is your responsibility to ensure that any personal information you provide to us via the Site is accurate, complete and up-to-date. If you wish to make any changes to any personal information you have provided to us, you may do so at any time by submitting an enquiry through the Contact Us page.

SECTION 3 - CONSENT

How do you get my consent?

By using the Site and voluntarily providing us (or Shopify) with your personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, subscribe to our newsletter or contact us via an email link on the Site or for other purposes, you consent to the collection and use of such personal information as described in this Privacy Policy (including, when you purchase products via the Site, consent to the collection and use of your information by Shopify in accordance with Shopify’s privacy policies).

If we ask for your personal information for a secondary reason, like marketing, or for a purpose incompatible with the purpose for which it was originally collected, we will either ask you directly for your expressed consent, or provide you with an opportunity to say “no.”

How do I withdraw my consent?

In instances where you have opted-in to VW’s use of your personal information, if you change your mind, you may withdraw your consent for us to contact you and for the continued collection, use, or disclosure of your information for those purposes, at any time, by submitting your request through the Contact Us page.

SECTION 4 - SHOPIFY

Your data is stored through Shopify’s data storage, databases and the general Shopify application. The information Shopify collects from you is governed by Shopify’s privacy policy and other policies. (See: http://www.shopify.com/data-processing/privacy-policy ). According to such policies, Shopify protects credit card information according to the Payment Card Industry Data Security Standard (PCI-DSS), a set of security requirements managed by the PCI Security Standards Council, which is a joint effort of the payment brands, including Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by merchants and service providers. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. The description above is qualified in its entirety by the terms and conditions of Shopify’s privacy policies, and you should review the policies posted on Shopify’s site to be fully informed.

SECTION 6 – THIRD PARTY SERVICES; SHARING YOUR INFORMATION

We do not sell or rent your personally identifiable information to third parties. We share your information only with our affiliates and service providers or as otherwise described herein in order to provide you with our products and services. In general, our agreements with third party providers used by us require that they only use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

Once you leave our Site or are redirected to a third party website or application, you are no longer governed by this Privacy Policy or our Site’s Terms of Service. For example, as noted above, you may be redirected to the sites of certain third party service providers, such as Shopify and/or other payment gateways or payment transaction processors in order to complete your product purchases. Such third party websites have their own privacy policies with respect to the information required for your purchase-related transactions and under no circumstances is VW responsible or liable for the third party’s compliance therewith.

The Site may also reference or provide links to other third party websites, such as advertisers. For these third parties, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. We may share aggregated, non-personally identifiable information gathered by us with then-current or potential business partners and/or advertisers to provide them with information about our Site, our visitors and our customers. In addition, we may disclose your personal information if we are required by law to do so, or may disclose such information in response to a request from a law enforcement agency or authority or any regulatory authority. We may also disclose your personal information (i) to protect the integrity or security of the Site or the interests, rights, or property of VW; or (ii) to enforce the Site’s Terms of Use.

SECTION 7 - SECURITY

To protect your personal information, we take reasonable precautions and follow common industry practices to guard against such information being lost, misused, accessed, disclosed, altered or destroyed. Please be aware, however, that Internet data transmission and computer networks are not always secure and we cannot and do not guarantee that information you transmit utilizing the Site is secure.

SECTION 8 - COOKIES

In order to personalize and enhance your experience on the Site, we may also collect information through “cookies.” Cookies are small strings of text that are sent by the Site to your browser and then stored by your browser on your computer’s hard drive. We use cookies to help diagnose problems with our servers and to administer the Site. We also use cookies to gather broad demographic information and to help identify you in respect to visits to the Site so that we may improve your user experience, and to determine whether you visited the Site from a particular Internet link or advertisement. While a code in the cookie file enables the Site to label you as a particular user, including identifying you by name or other personally identifiable information, such cookie files are encrypted in order to protect your information. Most web browsers automatically accept cookies, but it is possible to change your browser setup so that it does not accept cookies. However, rejecting cookies may prevent you from taking advantage of certain portions of the Site. To help you determine whether you want to opt-out of cookies or not, below is a list of certain cookies that, as of the date of this Privacy Policy, we use. However, this list is subject to change.

Some cookies are necessary to allow you to browse our website, use its features, and access secure areas. The use of these cookies is essential for the website to work. For example, we use user-input cookies for the duration of a session to keep track of a user’s input when filling in forms that span several pages.

We also use functional cookies to remember choices you’ve made or information you’ve provided, such as your username, language, or the region you are in. This allows us to tailor your website experience specifically to your preferences. For example, authentication cookies are functional cookies that are used for the duration of a session (or persistent, if you agree to the “remember me” function) to allow users to authenticate themselves on subsequent visits or to gain access to authorized content across pages. The functional cookies we use include:

- User-centric security cookies to detect authentication abuses for a limited persistent duration, like repeated failed login attempts. These cookies are set for the specific task of increasing thesecurity of the service.

- Multimedia content player session cookies (flash cookies) are used for the duration of a session to store technical data needed to play back video or audio content (e.g. image quality, network link speed, and buffering parameters).

- Load balancing session cookies are used for the duration of the session to identify the same server in the pool in order for the load balancer to redirect user requests appropriately. User interface customization persistent cookies are used to store a user’s preference regarding a service across web pages.

Shopify is dedicated to user experience and we use many tools to help us improve our website and our commerce platform. To this end, we use reporting and analytics cookies to collect information about how you use our website or our merchants’ storefronts, and how often. These cookies only gather information for statistical purposes and only use pseudonymous cookie identifiers that do not directly identify you. The performance cookies we use include:

- First party analytics cookies - We use these cookies to estimate the number of unique visitors, to improve our websites and our merchants’ websites, and to detect the most searched for words in search engines that lead to a webpage. These cookies are not used to target you with online marketing. We use these cookies to learn how our websites and our merchants’ websites are performing and make relevant improvements to improve your browsing experience.

- Third party analytics cookies - We also use Google Analytics and other third-party analytics providers listed below to help measure how users interact with our website content. These cookies “remember” what our users have done on previous pages and how they’ve interacted with the website. For more information on Google Analytics, visit Google’s information page. For instructions on how to opt out of Google Analytics, see below.

Advertising cookies are used on our website to tailor marketing to you and your interests and provide you with a more personalized service in the future. These cookies remember that you visited our website and we may share this information with third-parties, such as advertisers. Although these cookies can track your device’s visits to our website and other sites, they typically cannot personally identify you. Without these cookies, the advertisements that you see may be less relevant and interesting to you. Read more about how companies use cookies to conduct targeted or retargeted advertising here. We do not set advertising cookies through our merchants’ storefronts ourselves, though merchants may choose to do so independently.

Finally, Social and Content cookies are placed by many social media plugins (for example the Facebook ’like’ button), and other tools meant to provide or improve the content on a website (for example services that allow the playing of video files, or that create comments sections). We integrate these modules into our platform to improve the experience of browsing and interacting with our websites. Please note that some of these third party services place cookies that are also used for things like behavioural advertising, analytics, and/or market research.

SECTION 9 – TRACKING

VW keeps track of the web pages our users visit within the Site, in order to determine what VW products are the most popular. Please note, however, we do not engage in the collection of personal information about your online activities over time and across third party websites or online services. Accordingly, we do not currently process or comply with any web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third party websites. Further, we have not knowingly authorized third parties to collect personally identifiable information about your online activities over time and across different websites when you use the Site.

SECTION 10 - AGE OF CONSENT

In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501-06 and 16 C.F.R. §§ 312.1-312.12, we do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register with us. If you are under 13, please do not attempt to register with the Site or send any information about yourself to us, including your name, address, mobile device number, or email address. By using this Site, you represent that (i) you are not under 13 years of age, and (ii) you are at least the age of majority in your state or province of residence.

SECTION 11 – EFFECTIVENESS; CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of December 19th, 2023. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this policy, we will provide a special notice on our Site for a certain period of time so that you have the opportunity to educate yourself as to what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

SECTION 12 - BUSINESS TRANSFER

Please note that if we are acquired or merged with another company, your personal information and/or technical information that we obtain from you via the Site may be disclosed to any potential or actual purchasers and/or may be transferred to the new owners so that we may continue to sell products to you.

SECTION 13 – UNRESOLVED PRIVACY COMPLAINTS

VW uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and accessible and in conformity with the Safe Harbor Privacy Principles. In compliance with the Safe Harbor Privacy Principles, we endeavor to resolve all complaints about privacy and the collection or use of customer information. If you have questions about our participation in the Safe Harbor Program or have a complaint, please submit your enquiry through the form located on the Contact Us page.

Under the Safe Harbor Program, any unresolved privacy complaints can be referred to an independent dispute resolution mechanism. We use the ICDR/AAA Safe Harbor Program, which is operated by the International Centre for Dispute Resolutions, the International Division of the American Arbitration Association. If you feel that we have not satisfactorily addressed your complaint, you can visit the ICDR/AAA Safe Harbor Program website at https://apps.adr.org/webfile for more information on how to file a complaint.