1. Protecting Your Information

Cornily is committed to protecting your information and handling it in accordance with our legal obligations. This Privacy Policy is designed to help you understand how we handle your data, and also explains your rights and choices. This Policy applies to the following services (referred to as the “Platform” in this Policy): the Cornily website and online store, our mobile applications, our social media pages, our retail locations, and any other places where we collect information about you and refer to this Policy. How we handle your information depends on which Platform services you use and how you use them. This Policy is organized into the following sections:

  • About Us and This Policy;
  • Information We Collect;
  • How We Use Information, including for Advertising Purposes;
  • When We Disclose Information to Other Parties, including for Advertising Purposes; and
  • Your Rights and Control Over Your Information.

We encourage you to read this Policy carefully. If you have questions, please contact us.

2. About Us and This Policy

(a) Who We Are — Cornily, LLC operates this Platform and is referred to in this Policy as “Cornily,” “we,” “us,” or “our.” This Policy supplements and is subject to our Terms of Service. Capitalized terms used but not defined in this Policy have the meanings given to them in our Terms of Service. The Terms of Service describe the general operation of the Platform, including the security measures we use to protect our systems and the information described in this Policy.

(b) When This Policy Applies — This Policy applies to you when you use the Platform as of the “Last Updated” date above. By using or accessing the Platform, you acknowledge that you have read, understood, and agree to be bound by this Policy and the Terms of Service.

If you are a current or former employee or contractor of ours, this Policy does not apply to you. You may contact us at [email protected] to learn about our privacy practices and your rights.

If we receive your information as a service provider to another business, our agreement with that business will govern our use of your information. We will refer any questions or concerns you have to that business.

Because the Platform changes frequently, this Policy may be adjusted from time to time. Whenever we modify the Policy, we will post the revised version on the Platform and update the “Last Updated” date above. If you have provided us with contact information, we will notify you before any material changes take effect so that you have time to review them.

(c) Region-Specific Provisions — This Platform is operated from the United States, but this Policy applies globally. Our practices generally do not vary by region, but your rights and choices depend in part on the laws of where you reside. For example, you may have rights under: (1) “GDPR” – the UK Data Protection Act 2018 and the implementation of the General Data Protection Regulation (EU) 2016/679; or (2) “CCPA” – the California Consumer Privacy Act, as amended. Accordingly, certain sections of this Policy apply only if you reside in a particular region:

  • California residents should review the “Rights Under California Law” section.
  • Residents of jurisdictions where GDPR applies (such as the UK, EU, and Switzerland) should review the “Rights Under GDPR” and “International Data Transfers” sections.

If these sections apply to you, they will override any contrary description elsewhere in this Policy with respect to you. If you have questions about your rights under other data privacy laws, please contact us.

3. Information We Collect

(a) Information You Provide — You can use most features of the Platform without providing any personal information. However, to use certain features of the Platform, we need your information, such as when you:

  • Create an account
  • Purchase products or services
  • Contact us or communicate with us
  • Subscribe to or opt in to receive our newsletters, alerts, or other communications
  • Enter a contest or promotion or redeem a prize

When you submit information through the Platform, whether to enable services or through product reviews, you agree to the collection, use, and disclosure of that information in accordance with this Policy. The information you provide to us may include personal identifiers. Please note that if you provide us with sensitive personal information, we use it only for our operational business purposes and do not disclose it to others for any other purpose. We try to limit the amount of sensitive personal information we collect. For example, when making a purchase through our Platform, your payment information (such as your full credit card number and any payment-related security information) is collected and processed solely by our payment processing partners.

(b) Information Collected When You Use the Platform — When you use the Platform, the Cookies and other technologies we use generate technical data about which features you use, how you use them, and the device you use to access our services. This information may include:

  • “Commercial information” about products or services you order from us and your interactions with store products.
  • “Device information” related to the device you use to access the Platform, such as your IP address, advertising ID (a randomly generated number that can be reset through device settings, such as Apple IDFA or Android advertising ID), browser and operating system, internet service provider and its settings.
  • “Internet activity” related to your use of the Platform, such as the pages you visit, the websites you use before and after visiting our site, your actions within the Platform, content or ads you interact with, general geolocation information, timestamps, and performance logs and reports.

(i) Cookies and Other Technologies — We and third-party partners use Cookies, pixel tags, or similar technologies to collect personal information on the Platform. Our third-party partners (such as analytics and advertising partners) may use these technologies to collect information about your online activities across different services. We may use session Cookies (which are deleted from your device when you log out of the Platform) and persistent Cookies (which remain on your device for a longer period or until you manually delete them). Session Cookies disappear after you close your browser. Persistent Cookies remain after you close your browser and may be used by your browser on your subsequent visits to our services. If you choose to receive our emails or text messages, Cookies may be used to personalize your experience (for example, by sending you personalized text messages such as cart reminders).

4. How We Use Information

Below is a detailed explanation of the various reasons we use your information and practical examples:

To Provide You with Our Content, Services, and Products

  • Create and manage your account
  • Provide you with customer support and respond to your requests
  • Fulfill your orders
  • Communicate with you about our services

To Manage Your Account or Fulfill Product Orders

  • Register you on the service to allow you to purchase goods or services
  • Manage your account on new features and applications

To Improve Our Services and Develop New Services

  • Manage focus groups, market research, and surveys
  • Review interactions with customer teams to improve our service quality
  • Develop new content and services

To Operate Advertising and Marketing Campaigns

  • Administer sweepstakes, contests, discounts, or other offers
  • Send you text messages with your consent (until you withdraw consent), including personalized offers
  • Customize ads for you based on technical data and de-identified or hashed, non-human-readable information about you
  • Execute and measure the advertising effectiveness of our services and marketing activities outside the Platform
  • Communicate with you about products or services we believe may interest you

To Prevent, Detect, and Combat Fraud and Other Illegal or Unauthorized Activities

  • Detect and address ongoing, suspected, or alleged violations of our Terms of Service
  • Better understand and design responses to violations of the Terms of Service
  • Retain data related to violations of the Terms of Service to prevent recurrence
  • Enforce or exercise our rights, such as those in the Terms of Service

To Ensure Legal Compliance

  • Verify copyright or intellectual property claims
  • Comply with legal requirements
  • Assist law enforcement

(a) Purposes — We rely on the following purposes to collect and use the information described in this Policy:

  • Commercial Purposes: We process your information for purposes 1, 2, 3, and 4 above to advance your economic interests or our economic interests. These purposes include performing the contract between you and us (as reflected in our Terms of Service and your orders), which advances our and your economic interests. For example, if you order products from us, we use your information to complete your payment and deliver the products to you.
  • Business Purposes: We process your information for operational reasons in a reasonably necessary and proportionate manner for purposes 1, 2, 5, and 6 above (i.e., business purposes under CCPA). For example, we analyze user behavior on the service to continuously improve our products, we recommend offers we believe may interest you and promote our own services, we process information to help protect user safety, and we process data when necessary to enforce our rights, assist law enforcement, and enable us to defend ourselves in legal proceedings.
  • Compliance with Applicable Laws and Regulations: We process your information for purpose 6 above when necessary to comply with applicable laws and regulations and to demonstrate our compliance with applicable laws and regulations. For example, we retain traffic data and transaction data in accordance with accounting, tax, and other statutory data retention obligations, and we are able to respond to valid access requests from law enforcement.
  • Consent: We may from time to time seek your consent to collect specific information (such as your precise geolocation) or to use your information for specific reasons (such as providing your email address or phone number for direct marketing purposes). Generally, you can withdraw your consent by changing your settings (such as browser or device settings) or by following the instructions in communications sent based on your consent (such as replying “STOP” to a text message). You can withdraw your consent at any time – just contact us.

5. Disclosure of Information

Because our goal is to help you discover quality products and services, the primary reason we disclose your information is to maintain and improve your experience using the Platform. This section describes how and why we exchange personal information with contractors and third parties, as well as exchanges for specific purposes (such as legal reasons and direct marketing with consent). We also disclose de-identified and/or anonymized data for these purposes.

(a) Functional Disclosures — In addition to the use of trackers described above, we contract with companies or individuals to provide specific services related to the Platform’s functionality, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and the administration of contests and other promotional activities. We refer to them as “Contractors.” We may disclose information about you to Contractors as needed for them to perform their services, such as personal identifiers, commercial information, internet activity, and device information. Contractors are not permitted to use information about you for any other purpose. In the past twelve (12) months, we have disclosed these types of information to the following types of Contractors:

  • Analytics Providers, such as Google Analytics, which report to us on the Platform’s operation, such as which parts attract visitors’ interest and how long they visit before leaving. They may receive data such as your IP address.
  • Various Hosting Services and Data Processors that provide the Platform’s infrastructure, such as Cloudflare, which ensure traffic comes from real users rather than computers. They may receive data such as your IP address.
  • Payment Providers, such as ShopPay, Amazon Pay, PayPal, and Catch (as applicable), which process payments between you and us, such as subscriptions or products. These providers receive your order information to associate your payment process with your order. We do not receive all information you may provide to them in this process (for example, we do not receive full payment account numbers).
  • Support Providers, such as Gorgeous and AwesomeOS, which assist you when you request help. They are able to retrieve information relevant and necessary to your request, such as account information and order details.

(b) Legal Reasons — Finally, we may disclose personal information in the following circumstances:

  • In response to a subpoena, court order, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or available right.
  • When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and to enforce our Terms of Service and other agreements.
  • In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the highly unlikely event of bankruptcy.

(c) With Your Consent or at Your Request — We may periodically seek your consent to disclose your information to third parties. Whenever we seek your consent for this reason, we will outline the purpose and scope of the disclosure. For example, if you agree to join our mailing list or participate in a promotion involving direct marketing communications, we may offer you a discount. In such cases, the Platform will display a checkbox near the email submission button stating that clicking the button means you consent to sharing your email with the content provider.

6. Information Retention Period

We retain your information only as long as we need it for the purposes described in the “How We Use Information” section, unless our compliance policies and applicable laws, tax, accounting, and regulatory requirements require a longer retention period. The length of time we need information for these purposes varies by category and even within categories. These retention decisions always take into account the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve these purposes without using the personal information. For example, we delete certain internet activity immediately when you log out of the Platform, while we may retain your order records for several years based on legal or contractual requirements (such as agreements with payment processors or accounting standards).

7. Use by Minors

This Platform is intended for adult users. We do not knowingly collect information from anyone under the age of 16, nor do we share or sell information from anyone under 16 without explicit authorization. If we learn that we have collected information from a child under 16, we will delete that information as soon as possible.

  • If you are under 16: Please leave this Platform. If you have sent us information, please contact us first so that we can delete it.
  • If you are a parent or guardian of a child under 16 and believe your child has provided us with information, please contact us.

8. Contact Us

If you have questions or comments about this Privacy Policy, please contact us:

Email: [email protected].

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