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Privacy Policy

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Last updated November 13, 2024

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This Privacy Notice for Karla Courtney ('we', 'us', or 'our'), describes how and why we might access, collect,

store, use, and/or share ('process') your personal information when you use our services ('Services'), including

when you:

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• Visit our website at https:/karlacourtney.com, or any website of ours that links to this Privacy Notice

• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices.

We are responsible for making decisions about how your personal information is processed. If you do not agree

with our policies and practices, please do not use our Services. If you still have any questions or concerns,

please contact us at hello@karlacourtney.com.

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SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any

of these topics by clicking the link following each key point or by using our table of contents below to

find the section you are looking for.

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What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

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Do we process any sensitive personal information?

We do not process sensitive personal information.

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Do we collect any information from third parties?

We do not collect any information from third parties.

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How do we process your information?

We process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

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In what situations and with which types of parties do we share personal information? We may share

information in specific situations and with specific categories of third parties.

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How do we keep your information safe? We have adequate organisational and technical processes and

procedures in place to protect your personal information. However, no electronic transmission over the internet

or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee

that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and

improperly collect, access, steal, or modify your information.

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What are your rights? Depending on where you are located geographically, the applicable privacy law may

mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject

access request, or by contacting us. We will consider and act upon any request in accordance with applicable

data protection laws.

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Want to learn more about what we do with any information we collect? Review the Privacy Notice in full below.

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TABLE OF CONTENTS

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1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO US RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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1. WHAT INFORMATION DO WE COLLECT?

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Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining

information about us or our products and Services, when you participate in activities on the Services, or

otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of

your interactions with us and the Services, the choices you make, and the products and features you use. The

personal information we collect may include the following:

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• phone numbers

• email addresses

• billing addresses

• debit and credit card numbers

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Sensitive Information. We do not process sensitive information.

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Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such

as your payment instrument number, and the security code associated with your payment instrument. All

payment data is handled and stored by Wix Payments and PayPal. You may find their privacy notice link(s) here:

https:/lwww.wix.comlabouUterms-of-payments and https:llwww.paypal.comluk/legalhublprivacy-full.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of

any changes to such personal information.

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Information automatically collected

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In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device

characteristics - is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does

not reveal your specific identity (like your name or contact information) but may include device and usage

information, such as your IP address, browser and device characteristics, operating system, language

preferences, referring URLs, device name, country, location, information about how and when you use our

Services, and other technical information. This information is primarily needed to maintain the security and

operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out

more about this in our Cookie Notice: karlacourtney.comlcookie-policy.

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GoogleAPI

Our use of information received from Google AP ls will adhere to Google API Services User Data Policy, including

the Limited Use requirements.

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2. HOW DO WE PROCESS YOUR INFORMATION?

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In Short: We process your information to provide, improve, and administer our Services, communicate with you,

for security and fraud prevention, and to comply with law. We may also process your information for other

purposes with your consent.

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We process your personal information for a variety of reasons, depending on how you interact with our

Services, including:

• To fulfil and manage your orders. We may process your information to fulfil and manage your orders,

payments, returns, and exchanges made through the Services.

• To save or protect an individual's vital interest. We may process your information when necessary to

save or protect an individual's vital interest, such as to prevent harm.

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3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal

reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you

with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate

business interests. 

 

If you are located in the EU or UK, this section applies to you:

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The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we

rely on in order to process your personal information. As such, we may rely on the following legal bases to

process your personal information:

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• Consent. We may process your information if you have given us permission (i.e. consent) to use your

personal information for a specific purpose. You can withdraw your consent at any time. Learn more

about withdrawing your consent.

• Performance of a Contract. We may process your personal information when we believe it is necessary

to fulfil our contractual obligations to you, including providing our Services or at your request prior to

entering into a contract with you.

• Legal Obligations. We may process your information where we believe it is necessary for compliance

with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency,

exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are

involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital

interests or the vital interests of a third party, such as situations involving potential threats to the safety of

any person.

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If you are located in Canada, this section applies to you:

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We may process your information if you have given us specific permission (i.e. express consent) to use your

personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied

consent). You can withdraw your consent at any time.

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In some exceptional cases, we may be legally permitted under applicable law to process your information without

your consent, including, for example:

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• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an

insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the

accuracy of the information and the collection is reasonable for purposes related to investigating a breach

of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to

the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the

collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

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4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

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In Short: We may share information in specific situations described in this section and/or with the following

categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party

vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf

and require access to such information to do that work. We have contracts in place with our third parties, which

are designed to help safeguard your personal information. This means that they cannot do anything with your

personal information unless we have instructed them to do it. They will also not share your personal information

with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it

for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• Affiliate Marketing Programs

• Data Analytics Services

• Sales & Marketing Tools

• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations

of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to

another company.

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5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

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In Short: We are not responsible for the safety of any information that you share with third parties that we may

link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain

advertisements from third parties that are not affiliated with us and which may link to other websites, services, or

applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be

liable for any loss or damage caused by the use of such third-party websites, services, or applications. The

inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We

cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by

third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security

practices and policies of any third parties, including other websites, services, or applications that may be linked

to or from the Services. You should review the policies of such third parties and contact them directly to respond

to your questions.

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6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

In Short: We may use cookies and other tracking technologies to collect and store your information.

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We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when

you interact with our Services. Some online tracking technologies help us maintain the security of our Services,

prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

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We also permit third parties and service providers to use online tracking technologies on our Services for

analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your

interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The

third parties and service providers use their technology to provide advertising about products and services

tailored to your interests which may appear either on our Services or on other websites.

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To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted

advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these

online tracking technologies by submitting a request as described below under section 'DO UNITED STATES

RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'

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Specific information about how we use such technologies and how you can refuse certain cookies is set out in

our Cookie Notice: karlacourtney.com/cookie-policy.

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Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of

being tracked by Google Analytics across the Services, visit https://tools.google.comldlpagelgaoptout. For more

information on the privacy practices of Google, please visit the Google Privacy & Terms page.

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7. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice

unless otherwise required by law.

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We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy

Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal

requirements).

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When we have no ongoing legitimate business need to process your personal information, we will either delete

or anonymise such information, or, if this is not possible (for example, because your personal information has

been stored in backup archives), then we will securely store your personal information and isolate it from any

further processing until deletion is possible.

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8. HOW DO WE KEEP YOUR INFORMATION SAFE?

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In Short: We aim to protect your personal information through a system of organisational and technical security

measures.

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We have implemented appropriate and reasonable technical and organisational security measures designed to

protect the security of any personal information we process. However, despite our safeguards and efforts to

secure your information, no electronic transmission over the Internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other

unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify

your information. Although we will do our best to protect your personal information, transmission of personal

information to and from our Services is at your own risk. You should only access the Services within a secure

environment.

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9. DO WE COLLECT INFORMATION FROM MINORS?

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In Short: We do not knowingly collect data from or market to children under 18 years of age.

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We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly

sell such personal information. By using the Services, you represent that you are at least 18 or that you are the

parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that

personal information from users less than 18 years of age has been collected, we will deactivate the account and

take reasonable measures to promptly delete such data from our records. If you become aware of any data we

may have collected from children under age 18, please contact us at hello@karlacourtney.com.

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10. WHAT ARE YOUR PRIVACY RIGHTS?

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In Short: Depending on your state of residence in the US or in some regions, such as the European Economic

Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to

and control over your personal information. You may review, change, or terminate your account at any time,

depending on your country, province, or state of residence.

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In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data

protection laws. These may include the right (i) to request access and obtain a copy of your personal information,

(ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable,

to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may

also have the right to object to the processing of your personal information. You can make such a request by

contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS

NOTICE?' below.

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We will consider and act upon any request in accordance with applicable data protection laws.

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If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you

also have the right to complain to your Member State data protection authority or UK data protection authority.

If vou are located in Switzerland. vou may contact the Federal Data Protection and Information Commissioner

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Withdrawing_your consent: If we are relying on your consent to process your personal information, which may

be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent

at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in

the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when

applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful

processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and

promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by

contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

below. You will then be removed from the marketing lists. However, we may still communicate with you - for

example, to send you service-related messages that are necessary for the administration and use of your

account, to respond to service requests, or for other non-marketing purposes

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Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you

can usuatly choose to set your browser to remove cookies and to reject cookies. If you choose to remove

cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of

interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice:

karlacourtney.com/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at hello@karlacourtney.com.

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11. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT')

feature or setting you can activate to signal your privacy preference not to have data about your online browsing

activities monitored and collected. At this stage, no uniform technology standard for recognising and

implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or

any other mechanism that automatically communicates your choice not to be tracked online. If a standard for

online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised

version of this Privacy Notice.

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California law requires us to let you know how we respond to web browser DNT signals. Because there currently

is not an industry or legal standard for recognising or honouring DNTsignals, we do not respond to them at this

time.

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12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

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In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, lndiana, Iowa, Kentucky,

Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you

may have the right to request access to and receive details about the personal information we maintain about

you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You

may also have the right to withdraw your consent to our processing of your personal information. These rights

may be limited in some circumstances by applicable law. More information is provided below.

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Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

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Screen Shot 2024-11-13 at 3.49.58 PM.png

We may also collect other personal information outside of these categories through instances where you interact

with us in person, online, or by phone or mail in the context of:

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• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

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We will use and retain the collected personal information as needed to provide the Services or for:

• Category A -As long as the user subscribes

• Category B - As long as the user subscribes to my emails

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Sources of Personal Information

Learn more about the sources of personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR

INFORMATION?'

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We collect and share your personal information through:

• Targeting cookies/Marketing cookies

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us

and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN

AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

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We may use your personal information for our own business purposes, such as for undertaking internal research

for technological development and demonstration. This is not considered to be 'selling' of your personal

information.

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We have not sold or shared any personal information to third parties for a business or commercial purpose in the

preceding twelve (12) months. We have disclosed the following categories of personal information to third parties

for a business or commercial purpose in the preceding twelve (12) months:

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• Category F. Internet or other electronic network activity information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose

can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

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Your Rights

You have rights under certain US state data proteclton laws. However, these rights are not absolute, and in

certain cases, we may decline your request as permitted by law. These rights include:​

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non•discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as

defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including

Minnesota's privacy law)

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as

permitted by applicable law, including California's and Delaware's privacy law)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by

applicable law, including Minnesota's and Oregon's privacy law)

• Right to review, understand, question, and correct how personal data has been profiled (as permitted by

applicable law, including Minnesota's privacy law)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including

California's privacy law)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a

voice or facial recognition feature (as permitted by applicable law, including Florida's privacy !aw)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us

at hello@karlacourtney.com.

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Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about

whom we have the information in our system. We will only use personal information provided in your request to

verify your identity or authority to make the request. However, if we cannot verify your identity from the

information already maintained by us, we may request that you provide additional information for the purposes of

verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify

your identity before processing your request and the agent will need to provide a written and signed permission

from you to submit such request on your behalf.

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Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal

our decision by emailing us at hello@karlacourtney.com. We will inform you in writing of any action taken or not

taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is

denied, you may submit a complaint to your state attorney general.

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California 'Shine The Light' Law

California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are

California residents to request and obtain from us, once a year and free of charge, information about categories

of personal information {if any) we disclosed to third parties for direct marketing purposes and the names and

addresses of all third parties with which we shared personal information in the immediately preceding calendar

year. If you are a California resident and would like to make such a request, please submit your request in writing

to us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS

NOTICE?'

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13. DO WE MAKE UPDATES TO THIS NOTICE?

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In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated

'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify

you either by prominently posting a notice of such changes or by directly sending you a notification. We

encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

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14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

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If you have questions or comments about this notice, you may email us at hello@karlacourtney.com.

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15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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Based on the applicable laws of your country or state of residence in the US, you may have the right to request

access to the personal information we collect from you, details about how we have processed it, correct

inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our

processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please contact hello@karlacourtney.com.

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