Aquis, LLC

Last Updated on January 06, 2023

Your privacy is important to us. This Privacy Policy (“Policy”) describes how Aquis, LLC and its affiliates and subsidiaries (“we”, “us”, “our” or “AQUIS”) collect, use, and share personal information in connection with the AQUIS websites we provide which link to this privacy policy (collectively, the “Sites”), our AQUIS services, events, offerings, and digital products, our AQUIS social media pages, and our AQUIS email and other electronic communications (collectively, the “Services”), and the choices you have with respect to your personal information.

We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by posting a new Policy to this page, and/or by sending notice to the primary email address specified in your account or other means. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use, and sharing of your information is subject to the updated Policy.

1. Scope and Applicability

This Policy does not apply to brands operated by our affiliated companies that have a separate privacy policy, or to websites, apps, products, or services that we do not own or control, such as third party websites and/or applications linked on the Services. Information you provide to third parties is governed by their respective privacy policies, which we encourage you to review for more information about their practices. In addition, our products and services may be made available to you through salons, other retailer’s stores, and/or other channels. The collection and use of your information by such third parties is subject to the policies and practices of those third parties, for which AQUIS is not responsible. We encourage you to read the privacy policy of every site or channel you visit or order from.

We also work with a number of trusted distributors to make certain AQUIS products available in the United States and select international markets. Customers placing an order through a AQUIS distributor will be subject to the distributor’s terms and conditions of sale and privacy policies and practices, and the distributor is responsible for order fulfillment. Personal information about customers who place an order with one of our distributors may be shared among AQUIS and its distributors. We encourage you to carefully review any distributor’s privacy policies and practices before placing an order with them, and contact the relevant distributor for more information about their privacy practices.

With respect to the personal information described in this Policy, our lawful bases of processing such information could vary based upon the applicable jurisdiction, but may include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the products or services you have requested), compliance with law and other legal obligations, and/or our legitimate interests.

Residents of California can view important privacy information in the section below titled “Information for California Residents – Your California Privacy Rights.” European users can view important data protection information in the section below titled “Information for European Users.”

2. Personal Information We Collect

We may obtain personal information about you from a variety of sources depending on our relationship with you.

Personal Information You Provide

We collect personal information from you when you submit that information to us or otherwise provide it in connection with the Services. For example, some of the personal information that you may provide includes the following:

Activity	Examples of Personal Information Collected	Primary Purpose for Collection and Use
Accounts	When you create an account, we may collect your contact information (such as your first and last name and email address), demographic information (such as your birthday and zip code), your communication/marketing preferences, and other information that you provide during the account registration or sign-up process. We may also collect profile and other information that you choose to save in your account, including to use for future purchases, such as your shipping addresses and payment information (“Card on File”). When you add a Card on File to your account, we collect your payment information details (such as billing address, phone number, and zip code). AQUIS hair professionals may provide additional details when registering and/or using their account, including professional information (such as occupation, salon name, and license details), social media handles/profiles, and other details.	To create, maintain, and monitor your account, including offering functionalities such as easy checkout and the ability to save user preferences and transaction history.
Newsletter	When you sign-up or choose to receive our newsletter, we collect the personal information you provide, such as your name, the month and day of your birthday, phone number, e-mail address, and mailing address.	To send content that may be interesting or useful to you.
Communications With Us	When you communicate with us, including contacting us for support, to provide feedback or comments, to participate in a virtual consultation, survey, or event, to contact our customer service team, or to make a request or other inquiry, we may collect your name and contact information (such as e-mail address or phone number), as well as any other information that you choose to provide to us. In some cases, we may record customer service calls for quality assurance.	To respond to and/or follow-up on your issues or feedback, and to provide information in response to your requests and inquiries.
Posting in Public Forums	If you choose to submit or post information in a public space on our websites or on our social media pages, such as creating a public profile, rating our products, submitting content as part of our online community, or leaving a testimonial, we may collect the information you share.	To understand your opinions and to provide a forum for discussion, asking questions, posting photos and reviews, and sharing experiences.
Promotional Communications	When you sign up to receive promotional communications from us, such as email communications, mobile messages (including text and/or push notifications), and postal mailings, we collect your contact information. We may also collect certain information about how you interact with the emails and promotional messages we send you.	To communicate with you and send promotional materials such as trend alerts, promotions, new product launches, and event invitations. We also use this information to understand how you interact with our communications with you.
Purchasing Online	When you place an order for a product or service on our websites, we collect information needed to process your order, such as your name, shipping address, payment information, billing address, order details, and subscription information.	To fulfill your orders for products or services, and to process your payments for such products or services. We also use this information to provide you receipts and order updates.
Sweepstakes, Contests, and Promotions	When you participate in a sweepstakes, contests, or other similar campaigns or promotions, we collect information that you provide such as your name, contact information, and in some cases limited demographic information and content generated by participants. Some campaigns and promotions have a social networking component where you can choose to submit additional information such as social media profiles and handles, photographs, and other content.	To administer our sweepstakes, contests, and other similar promotions, and for marketing and advertising purposes. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes.
Referrals	You may have the opportunity to refer friends, colleagues, or other contacts to us and share their contact information with us. Please do not provide us with someone’s contact information unless you have their permission to do so.	To operate our referral programs and promote our business.
Surveys	If you choose to participate in one of our surveys, we will collect the personal information that you provide, such as product preferences, gender, age, occupation, household information, marital status, income, ethnicity, education, and other information you may choose to provide.	To assess the popularity of our products and services and for other research and development purposes.
AQUIS Pro Programs	AQUIS hair professionals may provide various types of personal information when participating in our pro features and programs. Personal information varies but may include name, contact information, salon information, license or certification number, application data, training program enrollment status and results, driver’s license details, and education information.	To provide training, partnership opportunities, support, and other products, services, and features to AQUIS hair professionals, including to promote you publicly on our website as an AQUIS provider or salon.
Distribution Programs	We may collect personal information from our distribution partners such as name, contact information, business information, and financial information (such as bank account details).	To manage and support our relationship with distribution partners and monitor your activity as a AQUIS distributor.
Aquis Affiliate Programs	If you are an Aquis hair professional and sign up for one of our affiliate programs, we may collect tax ID, bank account details for payments (such as account number and routing number), or other information necessary for the affiliate program.	To provide our affiliate programs and facilitate payments to members.

We use the personal information that you provide for the primary purposes identified in the table above, as well as for the other purposes described in this Policy or at the time of collection.

Personal Information from Third Party Sources

We may collect personal information about you from third parties, such as our affiliated companies, distributors, salon and retail partners, service providers, social media platforms, advertising partners, public sources, and other sources. We may use this information and combine it with other personal information that we have already collected about you, including to supplement or update our records, improve the quality or personalization of our communications to you, help prevent or detect fraud, and for the other purposes described in this Policy. In addition, you may have the opportunity to link or otherwise connect to a third-party platform through the Services, such as when creating an account or purchasing a product on our Site. If you choose to connect with a third-party platform, they will provide us with certain personal information about you, such as to facilitate the registration and maintenance of your account or process your order.

Personal Information Automatically Collected

We, our service providers, and our advertising partners may automatically collect certain types of information about you, your device, and your activity over time on our Services and across other sites and online services. This information helps us to make our Services work more efficiently, evaluate use of our Services, support our website analytics and marketing campaigns, and the other purposes described in this Policy. Here are some of the types of information that may be automatically collected:

Services Metadata: When a user interacts with the Services, metadata is generated that provides additional context about the way you interact with the Services.
Log Data: Our servers may automatically collect information about your visit to our Services, including IP addresses and associated information, visit history, browser type and settings, the date and time the Services were accessed and used, information about browser configuration and plugins, language preferences.
Device Information: Information about your device (e.g. hardware model and manufacturer, operating system and version, unique device identifiers, browser type, screen resolution, IP address, and mobile network information) when you access Services.
Location Information: We may receive information from you that helps approximate your location, such as using an IP address received from your browser to determine an approximate location.
Online activity information: Information about your online activity, such as the website you visited before browsing to the Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

We use cookies and similar tracking technologies to collect some of this information, as described further below in this Policy.

Sensitive Personal Information

Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.

3. How We Use Personal Information

We may use personal information for the purposes described below and as otherwise described in this Policy or at the time of collection.

To Provide the Services

We may use your personal information to provide the Services, such as to:

Deliver and operate the Services and our business.
Monitor and improve your experience on the Services.
Provide you with the products and services you request, process your transactions, and monitor and store information about your orders.
Identify you when you visit our Services and/or confirm a person’s authority as a representative or agent.
Create, manage, monitor, and maintain your account on the Services.
Determine your eligibility for and administer any benefits related to your professional stylist account.
To respond to your comments and questions and provide customer service.
To send you information including order confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

Research and Development

We may use your information for research and development purposes, including to study and improve the Services and our business, to understand and analyze the usage trends and preferences of our users, and to develop new features, functionality, products, and services. As part of these activities, we may link or combine user information with other information and create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.

Direct Marketing

We may send you AQUIS-related or other direct marketing communications as permitted by law, including through email, text messages, and other forms of communication. You may opt-out of our marketing communications as described in the “Your Choices” section below.

Interest-Based Advertising

We work with third-party advertising companies and social media platforms to help us advertise our business and to display ads for our products and services. These companies may use cookies and similar technologies to collect information about you (including the types of information described above in the section called “Personal Information Automatically Collected”) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.

To Comply with Laws and Regulations

We will use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

Compliance, Fraud Prevention, and Safety

We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Services, products and services, business, databases, and technology assets; (b) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With Your Consent

In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

4. How We Share Personal Information

In addition to the sharing discussed elsewhere in this Policy or disclosed at the time of collection, we may disclose personal information to the entities and individuals listed below.

Our corporate affiliates, including our parent company and other related companies within our group of companies.
Service providers, including third parties that perform services to support our core business functions and internal operations, such as service providers that help us perform website hosting, maintenance, database management, cloud storage, web analytics, billing, shipping, email/text messaging services, payment processing, marketing, advertising, and other purposes.
Distribution partners, including the trusted partners that we work with to market and sell AQUIS products.
AQUIS hair professionals, such as the stylists and salons whose consultations and services use AQUIS products.
Advertising and joint marketing partners, such as third parties that we have partnered with to operate campaigns and other advertising activities or to jointly create and offer a product, service, event, or joint promotion.
Professional advisors, such as the individuals, companies, or professional firms that provide us with advice and consulting and support our audit, compliance, accounting, administrative, legal, tax, financial, and corporate governance functions.
Business transaction participants, in connection with any business transaction (or potential transaction) involving a change of ownership or control of all or part of our business or other form of transaction, such as a merger, acquisition, reorganization, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
Law Enforcement, authorities, and private parties, if we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect or protect against fraud or security issues and for the other purposes described above in the section titled “Compliance, Fraud Prevention, and Safety.” We may also disclose personal information to these parties if required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, in response to a request from law enforcement or other public authorities, or as otherwise described above in the section titled “To Comply with Laws and Regulations.”
Other parties, with your consent or at your direction.

5. How We Use Cookies and Similar Tracking Technologies

We collect personal information automatically through the use of cookies and similar tracking technologies, such as:

Log files, which track actions occurring on the Services, and collect data such as your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

Cookies, which are small files placed on your device when visiting the Sites. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety, among other things. For more information, please visit our Cookie Policy.

Web beacons, also known as pixel tags or clear GIFs, may be used to track the traffic patterns of users from one page to another, including to determine whether webpage or email was accessed or opened or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns. For example, web beacons allow us to know what pages on our Services have been visited, what emails have been opened, and if our banner ads have been effective.

Our third-party advertising service providers may also use cookies and similar tracking technologies to recognize you when you visit the Services, to help determine how you found the Services, to collect information about your visit and your interaction with our ads, and for the other interest-advertising purposes described in Policy. For more information about your choices in connection with these technologies and their use in connection with interest-based advertising, see the section below titled “Your Choices.”

6. How We Retain and Secure Your Information

We will retain your personal data for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. We strive to take reasonable steps designed to protect your personal information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. As a result, the security measures and other steps we have taken do not guarantee that your personal information will not be accessed, disclosed, altered or destroyed by breach of our security system or via transmission over the internet. By using the Services, you acknowledge that you understand and agree to assume these risks.

The safety and security of your personal information also depends on you. If you have an account with us, you are responsible for keeping your membership details confidential. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use.

7. Your Choices

In this section, we describe the rights and choices available to all users with respect to their personal information. For your protection, we may only share, update, and/or delete the personal information associated with the specific personal information (such as your email address) that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner.

Reviewing, Changing or Deleting Your Personal Information

All users may review and update the personal information furnished by a user in their user account by logging into their user account. You may also review, update, correct, or delete your personal information by contacting us at privacy@aquis.com. If you wish to cancel your account, you may do so through your account page, and any personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. If you completely and permanently delete all of your personal information, then your user account may become deactivated. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Opting Out of Marketing Communications

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new features, products, events, or other opportunities. If you wish to stop receiving these communications by email, please click "Unsubscribe" (or similar opt-out language) in the email communications you receive. For text message communications, you can text back “STOP” to opt out. Please note, we may send you a text message to confirm that you have been unsubscribed. You can also contact us at hello@aquis.com to opt out. Despite your indicated email preferences, we may still send you service-related communications after you have opted-out, such as notices of updates to our terms of service or privacy policy.

Cookies

Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Sites may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also view our Cookie Policy.

Advertising Choices

You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the Digital Advertising Alliance (optout.aboutads.info), and the European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/). Some of the companies we work with may offer their own opt-out mechanisms that are not specifically listed here.

Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Declining to Provide Information

We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

Other Choices

Depending on your location, you may have additional rights and choices depending on applicable law in your jurisdiction. Please view the additional jurisdiction-specific sections below for more information if these sections apply to you.

8. Children

The Services are not directed to individuals who are under the age of eighteen (18). If you believe that we have collected any personal information from a minor under the age of eighteen (18), please contact us at privacy@aquis.com.

9. How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

10. Transfer of Personal Information

AQUIS is headquartered in the United States and we have service providers in the United States and other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.

European users can see additional information about data transfers in the section below titled “Information for European Users.”

11. Information for California Residents

This section applies only to California residents. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act (“CCPA”) but does not include information exempted from the scope of the CCPA. The CCPA provides California consumers with several individual rights with respect to personal information. Note that these rights apply to individual consumers, not to companies. This section describes those rights in detail and provides information on how to exercise those rights and other disclosures relevant for California residents.

Your California Privacy Rights

California law provides California residents with the rights listed below:

Access/Know. You have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

Categories of personal information we have collected about you.
The specific pieces of personal information we have collected about you.
Categories of sources from which we collected personal information about you.
Our business or commercial purpose for collecting, selling, or sharing your personal information.
Categories of third parties with which we disclose your personal information.

Correct. You can ask us to correct inaccurate personal information that we maintain about you.
Delete. You have the right to request that we delete personal information about you that we have collected from you, subject to certain exceptions. You may also access, edit, or delete certain of your personal information through your account settings. Please review the section above in our Policy titled “Your Choices” for more details.
Opt Out of Sales or Sharing. If we “sell” or “share” your personal information, you can opt out. In addition, if you direct us not to sell your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
Non-Discrimination. You are entitled to exercise the rights described above free from discriminatory treatment.

Please note, these rights are not absolute and in some cases we may not be able to respond your request, such as when a legal exemption applies or if we are not able to verify your identity.

Exercising Your California Privacy Rights

You can request to exercise your access, correction, and deletion rights by clicking here, calling us at 877-438-0948, or emailing us at privacy@aquis.com.

You can request to opt-out of the “sale” or "sharing" of your personal information by emailing us at privacy@aquis.com or clicking here: Do Not Sell My Personal Information. You may also broadcast the Global Privacy Control (GPC) signal. Please note that broadcasting the GPC signal will only opt-out “sales” or “sharing” relating to information that may be collected through cookies and similar technologies on our Site. To opt-out of other “sales” or “sharing,” we need to collect some identifying information. Please follow the instructions provided at the link above to exercise your opt-out rights. Please note, due to technological limitations, if you visit our Services from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to the link above to select your preferences and/or rebroadcast the GPC signal.

If you contact us by phone or email to exercise your rights, please include (i) a complete description of your request, including the specific right(s) you wish to exercise and (ii) sufficient information about you so we can confirm that your request is a verifiable customer request, including at a minimum your name and email address. Regardless of how you submit your request, we may need to collect additional information from you to help us confirm identity. This is a security measure to help ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You may also designate an authorized agent to make a request on your behalf. If you do so, we may require the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

Personal Information Collectedand Purposes of Collection and Use

The chart below describes the category of personal information we may collect and have collected in the preceding 12 months by reference to the statutory categories specified under California law along with non-exhaustive examples of the types of information we may collect in that category:

Category	Examples:
Identifiers	Email address, full name (real/alias), full address, phone number, unique personal identifier, online identifier, IP address, account name, license/certification number, driver’s license number, and other similar identifiers
Physical Characteristics or Description	Hair type, color, concerns, and other characteristics or descriptions
Financial Information	Credit card number or other form of online payment for goods and services rendered, billing details, subscription information, bank account details
Protected Classification Characteristics	Gender, age groups, marital status, # of adults in household, presence of children, child age, generations in household, household composition, ethnicity, education, occupation
Commercial Information	Records of products/services purchased by you on the Services, account and profile information, order history, marketing and other preferences, and other information about purchasing histories or tendencies
Internet or Other Network Activity	Browsing history, search history, information about your interaction with a website, application, or advertisement, and the other information described in the section above titled “Personal Information Automatically Collected”
Audio, Electronic, Visual, or Similar Information	Audio recordings of customer service phone calls, images and other content submitted to the Services (including for product reviews and other public areas of the Services)
Professional or Employment-Related Information	Title, employer/salon information, business contact information, licensing/certification details, application data, student and education information, and other professional or employment-related information
Inferences	Customer profiles and other information derived from the categories of personal information described in this Policy
Sensitive Personal Information	Driver’s license number, financial account information, credit or debit card information, racial or ethnic origin

For information about:

the categories of sources of this personal information, see the section above titled “Personal Information We Collect;”
the business and/or commercial purposes for which we collect and use this personal information, see the section above titled “How We Use Personal Information;” and

To the extent that we may collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under California privacy laws (e.g., to perform the Services, detect security incidents and prevent fraud, and to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

Personal Information Disclosed for Business Purposes, “Sold,” or “Shared”

Each category of personal information listed above may be disclosed, and have in the preceding 12 months been disclosed for the business purposes described in this Policy to the third parties listed in the section above titled “How We Share Personal Information,” such as to provide our Services or for research and development.

In addition, when we share some of those categories of personal information with certain third parties (such as our advertising partners like Google and Facebook), that disclosure may be considered a “sale” or “sharing” of personal information under California privacy laws. The CCPA defines a “sale” as disclosing a California resident’s personal information to a third party for monetary or other valuable consideration. Where such disclosure is for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under the CCPA. We may “sell” or “share,” and in the preceding twelve months may have “sold” or “shared,” the following categories of personal information for purposes of advertising our Services, identifying new customers or potential customers, and the other purposes described above under the section titled “How We Use Personal Information.:

Identifiers
Commercial information
Internet or other network activity
Professional or employment-related information
Inferences

Each of these categories may be, or have in the preceding 12 months been “sold” or “shared” to the following categories of third parties: our corporate affiliates, distribution partners, licensees, retail partners, or advertising and joint marketing partners.

We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.

California Notice of Financial Incentive

We may offer certain financial incentive programs that can result in different prices, rates, or quality levels, provided that such programs are reasonably related to the value of your personal information to us. For example, we may offer a coupon to consumers who sign up for our mailing list, a loyalty program that provides consumers with benefits associated with repeat purchases, or giveaways, sweepstakes, contests, or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number).

We offer these programs because, among other things, the value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program. This value is based on the expense related to offering those products, services, and benefits to Program participants, along with other factors such as whether and to what extent you take advantage of (or opt-out from) any offerings and whether we are able to use the data we collect from you in connection with the Program.

When we offer any Program, there is no obligation to opt-in, and you may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program rules or in the “Contact Us” section at the bottom of this Policy. Please review the Program offering and/or terms of each Program to view full details, including how to join.

12. Information for European Users

The information provided in this section applies only to individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”) (collectively, “Europe”).

Except as otherwise specified, references to “personal information” in this Policy are equivalent to “personal data” governed by European data protection legislation.

Controller

The controller of your personal information covered by this Policy for purposes of European data protection legislation is Aquis, LLC., 621 Sansome St. San Francisco, California 94111, USA.

Legal Bases for Processing

The legal bases of our processing of your personal information as described in this Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at privacy@aquis.com.

Processing Purpose (as described above in the “How We Use Personal Information” section)	Legal Basis
To Provide the Services	Processing is necessary to perform the contract governing our operation of the Services, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.
Research and Development	Processing is based on our legitimate interests in performing research and development as described in this Policy.
Direct Marketing	Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or in the Services. Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.
Interest-Based Advertising
To Comply with Laws and Regulations	Processing is necessary to comply with our legal obligations.
Compliance, Fraud Prevention, and Safety	Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.
With Your Consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.

Use for New Purposes

We may use your personal information for reasons not described in this Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Your Rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Port. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time, but this will not affect any processing of your personal information that has already taken place. If you exercise this right, we may keep minimum information about you as necessary for our and your legitimate interest to ensure your opt-out choices are respected in the future and to comply with data protection laws.

To exercise your rights please click here or contact us at privacy@aquis.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request, and we may not be able to provide some or all of the Services without some necessary data collected from you.

If you believe that our processing of your personal information infringes upon your rights under European data protection legislation, you may contact us or lodge a complaint with the data protection authority in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

Cross-Border Data Transfer

If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us using the information below for further information about any such transfers or the specific safeguards applied.

13. Information for Nevada Residents

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy.

14. Contact Us

For any questions relating to this Policy or to contact us please email us at privacy@aquis.com or write to us using the information below:

Aquis, LLC
Attn: Privacy Policy
621 Sansome St. San Francisco
California 94111, USA