Last updated: October 20, 2025

PART I: GENERAL

This Privacy Policy explains
how the entities owned or controlled by Ad Populum LLC and listed at section M
below (together “we”, “our”, or “us”) collect, use, and
share information about you (“customer”, “you”, or “your”)
that you provide or that we obtain at our retail locations (“in-store”),
online when you visit our websites (“Websites”), in person interactions
at one of our other locations, concerts, events, or experiences (“Events”),
or through other interactions with you that are described below (collectively,
our in-store locations, Websites and Events are referred to as our “Properties”).
We are the data controller with respect to the personal data we collect and process
under the scope of this Privacy Policy.

This Privacy Policy describes the
categories of personal information we process, the purposes for which we
process such personal information and the legal basis for such processing, the
potential recipients to whom we may disclose your personal data, as well as the
rights and choices or remedies you may have with respect to your personal
information, how you can assert those rights, and how you can reach us to get
answers to your questions. Please take a moment to familiarize yourself with
our privacy practices. If you have any questions regarding our privacy
practices, please email us at the applicable email address located at section M
below.

Our privacy practices are subject
to the applicable laws of the regions in which we operate. Accordingly, some
additional region-specific terms will apply only to customers located in those
geographic regions, or as required by applicable laws.

If you are located outside of the
USA, please review the supplemental information at Part III, Part IV
(Australia), and Part V (New Zealand) of this Privacy Policy which may apply to
you.

BY USING OR ACCESSING OUR
PROPERTIES, YOU SIGNIFY YOUR AGREEMENT TO BE BOUND BY OUR PRIVACY POLICY. IF
YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU MAY NOT ACCESS OR OTHERWISE USE OUR
PROPERTIES.

For more information about how
users with disabilities can access this Privacy Policy in an alternative
format, please email us at the applicable email address located at section M
below.

A.
WHAT OUR PRIVACY POLICY COVERS

We use the term “personal
information” – also called “personal data” in the laws of some states and
countries – to refer to information that reasonably identifies, relates to,
describes, or can be associated with you.

Stated differently, personal
information is information relating to an identified or identifiable natural
person (the “data subject”). An identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier
such as a name, an identification number, location data, an online identifier
or to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural person.

Data that has been deidentified
or that otherwise cannot reasonably be related back to a specific natural person
is not considered personal information. The precise definition of personal
information may vary depending on your state or country of residence.

This Privacy Policy applies to
the personal information that we obtain in various contexts, including when
you:

• access or use our Websites or
  any other applications or services that link to this Privacy Policy,
  including to purchase online tickets.
• visit us in-store or attend one
  of our Events.
• communicate with us in email,
  text and other communications between you and our Properties, or through
  any non-electronic correspondence that you send us.
• shop with our third-party
  partners.
• engage with us on social media.
• participate in any of our promotional
  programs, including sweepstakes, contests or surveys.

We may provide different or
additional privacy notices in connection with certain activities, programs, and
offerings. Additionally, we may provide additional “just-in-time” notices or
notices at collection, under applicable law, that may supplement or clarify our
privacy practices or provide you with additional choices regarding your
personal information.

B.
PERSONAL INFORMATION WE COLLECT FROM OR ABOUT YOU

The following are the categories
and types of personal information that we may collect from or about you,
depending on how you interact with us and our Properties:

• Personal identifiers, such as
  name, date of birth, email address, postal address, online identifier,
  username or social media handle, internet protocol (IP) address, account
  name, or other similar identifiers.
• Device and online identifiers
  and related information, including device identifier, IP address, cookies,
  mobile ad identifier, phone number, or similar unique identifiers.
• Internet or other electronic
  network activity information, including, browsing history, search history,
  and information regarding your interactions with our Properties or
  advertisements, which may be collected including via Meta Pixel.
• Demographic information, such
  as age or gender, or civil status information (including information on
  dependent minors).
• Financial information, such as
  credit card numbers.
• Commercial information,
  including products or services purchased, rented, returned, considered, or
  other purchasing or consuming histories or tendencies.
• User content, including your
  communications with us and any other content you provide, such as social
  media profiles, photographs, images, videos, survey responses, comments,
  product reviews, testimonials, and other content.
• Geolocation information,
  including through your IP address or mobile device.
• Audio and visual information,
  including photographs, images, and voice.
• Professional or
  employment-related information.

Inferences drawn from any of the
information above.

C.
HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information
about you from various sources by different methods.

Personal Information You
Provide

We will ask you to provide us
with personal information if you choose to engage with certain functions on our
Website or with us on our other Properties. The following are the categories
and types of personal information that we may collect from or about you,
depending on how you interact with our Properties:

• Create an account. When you
  create an account, you will provide us with certain personal identifiers,
  such as your name, date of birth, and email address. We will also ask you
  to provide a username and password.
• Make a purchase. If you make a
  purchase, you will need to provide certain personal identifiers, such as
  your name, physical address, and email address, as well as customer
  records information, including payment card number.
• Engage with social media. You
  may choose to share your own personal identifiers, such as your name and
  any other personal information you choose to include in your post, through
  our ratings and review pages, and social media pages.
• Interact with us. When you
  communicate with us or send us any feedback, questions, requests for
  support, comments, suggestions, ideas, or interact with us in any way, we
  will collect certain personal identifiers that you provide, such as your
  name and email address.
• Subscribe to updates and
  promotions. You will have the option to sign up for email or text message
  updates and offers that may be of interest to you. If you choose to sign
  up for such updates and promotions, we will ask you to provide us with
  personal identifiers, such as your name, email address and/or telephone
  number.
• Participate in a contest,
  sweepstakes or survey. We may collect personal information, such as name
  and email address, associated with your participation in a contest,
  sweepstakes or survey.
• Visit one of our stores. If you
  visit one of our locations, we may capture video images of you through our
  closed-circuit security camera and may collect geolocation information
  from your mobile device.
• Apply for or accept a job with us.
  We capture and use of personal information of applicants, employees and
  other staff members. Please email us at the applicable email address
  located at section M below for any questions related to our applicant and
  staff member privacy policies.
• Contact us. If you contact our
  customer care team via telephone, we may collect any personal information
  that you choose to provide to us over the phone. If you contact us through
  our Website, we may collect personal information, such as your name and
  contact information, and we may keep a record of your communication with
  us and any personal information that you choose to provide in the course
  of your communication with us.
• Participate in or attend an
  Event organized by us. We may ask to you provide certain personal
  information – such as name, contact information, address, date of birth  –
  in the context of such Events and where we ask you to provide your consent
  to us collecting and using image/voice/recordings for marketing, publicity
  and/or other purposes.

Personal
Information We Collect Automatically

We collect
internet and other electronic network information and location information
automatically as you navigate our Website. The technologies deployed through
our Website collect internet and other electronic network information as
follows:

• Usage Information. Information
  about your interaction with our Website, such as the pages you access on
  our Website, the frequency of access, what you click on, and when you
  accessed the Website.
• Location Information.
  Information about your location, which may be determined through your
  device’s IP address and which may include precise geolocation information.
• Mobile Device Information. Your
  mobile device may also share precise geolocation information when you are
  in one of our stores if you consent to such sharing by enabling it in your
  device’s location settings.
• Device Information. Information
  about the device you are using, such as hardware model, operating system,
  browser, and your Website preferences.
• When you visit our Website,
  open or click on emails we send you, or interact with our advertisements,
  we or third parties we work with may automatically collect certain
  information using technologies such as cookies and other tracking
  technologies described below.
• Cookies and Similar
  Technology. “Cookies” are pieces of information that may be placed on
  your device by a website to collect data to facilitate and enhance your
  communication and interaction with that website. Such data may include,
  for example, the address of the websites you visited before and after you
  visited our Website, the type of browser you are using, your Internet
  Protocol (IP) address, what pages in the Website you visit and what links
  you clicked on, the region where your device is located, and geographic
  information based on your IP data. We may store some information on your
  device or device hard drive as a cookie or similar type of file (such as
  clear gifs, web beacons, tags, and similar technologies that work on
  mobile devices) to collect data related to usage of the Website. We may
  also use cookies to customize your visit to the Website and/ and for other
  purposes to make your visit more convenient or to enable us to enhance our
  services. To find out more information about Cookies generally, including
  information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org.
• Clickstream. As you use
  the Internet, a trail of electronic information is left at each website
  you visit. This information, which is sometimes referred to as “clickstream
  data,” can be collected and stored by a website’s server. Clickstream data
  can tell us the type of computer or device and browsing software you use
  and the address of the website from which you linked to the Website . We
  may collect and use clickstream data as a form of aggregate information to
  anonymously determine how much time visitors spend on each page of our Website,
  how visitors navigate throughout the Website, and how we may tailor our
  web pages to better meet the needs of visitors. This information will be
  used to improve our Website and our services.
• Analytics. We may work
  with third-party service providers who use the technologies described in
  this section to conduct website analytics to help us track and understand
  how visitors use our Website or other services.
• In-store and Other Offline
  Technologies. In some cases, we record customer service calls for
  quality assurance. We may also use closed circuit television or other
  video recording technology in our stores for safety, security, fraud, loss
  prevention, and operational purposes.
• Social Media Platforms and
  Networks. Our Website may include social media features, such as
  Instagram, Facebook, and Twitter widgets. These widgets may use cookies or
  other tracking technologies to collect electronic and other internet
  activity information, such as your IP address and which page you are
  visiting on our Website. Such social media features and widgets are hosted
  by third parties and your interactions with those features are governed by
  the privacy policies of the companies that provide them. We may also
  collect information about you from social media platforms and networks if
  you post content publicly or to our social media account (e.g. by using a
  hashtag) or if you post content to third-party social media hosts such as
  Facebook, Twitter, Pinterest, and Instagram.
• From Other Sources. We
  may obtain information about you from other sources, such as data
  analytics providers, marketing or advertising service providers, fraud
  prevention service providers, vendors that provide services on our behalf,
  or publicly available sources. We also create information based on our
  analysis of the information we have collected from you.

D.
HOW WE USE YOUR PERSONAL INFORMATION, PURPOSE FOR PROCESSING AND COLLECTION

We limit
the personal information we collect to what is reasonable and relevant for
various purposes, including:

Products and Services
Fulfillment

Depending on how you use our
Website or otherwise interact with our Properties, we may use your personal
information to:

• Provide products and services,
  such as to fulfill your orders and/or complete the transactions you
  request.
• Provide access to our locations
  and in-store.
• Process your payments.
• Provide you receipts and order
  updates.
• Deliver your purchases.
• Send notifications to you
  related to your account, purchases, subscriptions.
• Create, maintain, and otherwise
  manage your account, profile, or subscription, including offering
  functionalities such as the ability to save your user preferences and
  transaction history.
• Provide a forum for discussion,
  questions, posting photos, sharing experiences.
• Provide interactive features of
  our Website, such as product reviews.

Communicating With You

We use your personal information
to communicate with you, such as to respond to and/or follow-up on your
requests, inquiries, issues or feedback, and to provide customer service.

Marketing and Promotional
Purposes

We use personal information for
marketing and promotional purposes, including to:

• Send marketing, advertising,
  and promotional communications by email, text message or postal mail (such
  as trend alerts, promotions, new product launches, and event invitations).
• Show you advertisements for
  products or services tailored to your interests on social media and other
  websites.
• Provide you with information
  about products or services we believe may interest you.
• Administer our sweepstakes,
  contests, other promotions and surveys.

Analytics and Personalization

We use personal information to
conduct research and analytics, including to:

• Improve our services and
  product offerings.
• Understand how you interact
  with our Properties, advertisements, and communications with you to
  determine which of our products or services are the most popular and to
  improve our Properties and marketing campaigns.
• Customize the marketing and
  advertising that we show you.
• Create a more personalized
  experience for you when you visit us online or in stores
• Better understand our
  customers’ needs.
• Provide personalized
  recommendations about our products and services.

Security and Fraud Prevention

We use personal information to
detect, investigate, prevent, or take action regarding possible malicious,
deceptive, fraudulent, or illegal activity, including fraudulent transactions,
attempts to manipulate or violate our policies, procedures, and terms and
conditions, security incidents, and harm to the rights, property, or safety of
us and our users, customers, employees, or others; and to maintain the security
of our in-store locations.

Legal Obligations

We use personal information to
comply with our legal or regulatory obligations, to establish or exercise our
rights, and to defend against a legal claim.

Core Business Functions

We use personal information to
support core business functions, such as to:

• Provide, maintain and improve
  the functionality of our Website, including identifying and resolving any
  issues.
• Monitor user experience.
• Engage in quality assurance of
  our customer care team and monitor our customer care communications.

Please note that if you
specifically consent to additional uses of your personal information, we may
use your personal information in a manner consistent with that consent. Examples
include – but are not limited to – consents or waivers you provide to us for
collecting and using your voice/image in photos or recordings during Events
organized by us. Our use of the personal information provided to us through
such consents will most often be based on our (or a third party’s) legitimate
interests, as set out below.

E.
HOW WE DISCLOSE YOUR INFORMATION

Besides using your personal
information ourselves, and in addition to any specific uses mentioned elsewhere
in this Privacy Policy, we may disclose your personal information and other
information to other companies, affiliates, and third parties in the following
instances:

• Vendors and Service
  Providers. We may share the personal information we collect with
  entities that provide support services to us, such as analytics providers,
  call center providers, customer support providers, chat providers, email
  providers, shipping service providers, payment processors, web hosting
  providers, and e-commerce providers that assist us in taking orders,
  managing orders, and resolving customer issues. We also share the personal
  Information we collect with entities that provide us with support to
  market our products and services, including interest-based advertising as
  well as to other contractual partners who provide management, logistics,
  operational and other services and support to us.
• Affiliated Entities. We
  may share your personal information with one or more of our affiliated entities
  for their own marketing purposes where permitted by applicable law.
• Delivery Services. We
  may share the personal information we collect with our delivery partners
  and their employees and independent delivery personnel (including drivers)
  for the purpose of providing you delivery services that you may request in
  connection with a purchase from us. In addition, if you are providing
  delivery services for us (as a driver or otherwise) to our customers, your
  personal information may be collected by us and our third-party delivery
  partners.
• Corporate Reorganization. If
  we enter into, or intend to enter into, a transaction that alters the
  structure of our business, such as a reorganization, merger, acquisition,
  sale, joint venture, assignment, consolidation, transfer, change of
  control, or other disposition of all or any portion of our business,
  assets or stock, we would share personal information with third parties,
  including the prospective buyers or targets (and their respective agents
  and professional advisors) for the purpose of facilitating and completing
  the transaction. We would also share personal information with third
  parties if we undergo bankruptcy or liquidation, in the course of such
  proceedings.
• To Prevent Harm. We
  may disclose personal information if we believe it is necessary to detect,
  investigate, prevent, or take action against illegal activities, fraud, or
  situations involving potential threats to the rights, property, or
  personal safety of any person.
• Legal Purposes. We
  may disclose personal information and other information as we believe
  necessary or appropriate: (a) under applicable law, including laws outside
  your country of residence; (b) to comply with legal process; (c) to
  respond to requests from public and government authorities including
  public and government authorities outside your country of residence; (d)
  to enforce our Terms of Use; (e) to protect our operations or those
  of any of our affiliates; (f) to protect our rights, privacy, safety or
  property, and/or that of our affiliates, you, or others; and (g) to allow
  us to pursue available remedies or limit the damages that we may sustain.
• With Your Consent. Apart
  from the reasons identified above, we may request your permission to collect,
  process and share your personal information for a specific purpose. We
  will notify you and request consent before you provide the personal
  information or before the personal information you have already provided
  is shared for such purpose.
• Aggregated or Non-personal
  information. We may share aggregated or non-personal information
  with unaffiliated third parties, such as business partners, manufacturers,
  distributors, and retailers. We may share this non-personal information
  for a variety of purposes, including to improve and enhance your
  experience using the Website or other Properties, and for our market research
  activities.
• Interest-Based Advertising.
  We may ourselves, or with third party vendors, use information we collect
  or vendor information to deliver targeted advertising to you when you
  visit other websites or digital properties, or our Website. Cookies,
  clickstream data, and other similar technologies described in this Privacy
  Policy may be used in this process. For example, if you are searching for
  information on a particular product, we or our vendor may cause an
  advertisement to appear on other websites you view with information on
  that product. This form of advertising, sometimes called “targeted
  advertising,” “behavioral advertising,” or “cross-context behavioral
  advertising,” enables us and our vendors to know your interests in
  connection with the delivery of that specific ad. We believe that such
  advertising is helpful because you will see advertisements that are
  relevant to your interests. However, if you would like to opt out of these
  interest-based advertisements, you may follow the opt-out process
  described below under Your Choices.

F.
HOW WE PROTECT YOUR PERSONAL INFORMATION

We have
implemented measures designed to secure your personal information from
accidental loss and from unauthorized access, use, alteration, and disclosure.
We endeavor to protect your personal information by maintaining physical,
electronic, and procedural safeguards.

If you have an online account,
please avoid sharing your password or using any information that others can
easily learn about you, such as a family member’s name or birthday. We also
recommend that you frequently change your password. When you are finished with
a session on our Website, be sure that you log out and close the browser window
so nobody can pick up where you left off.

However, no method of safeguarding
information is completely secure. While we use measures designed to protect
personal information, we cannot guarantee that our safeguards will be effective
or sufficient. In addition, you should be aware that Internet data transmission
is not always secure, and we cannot warrant that information you transmit
utilizing the Website is or will be secure.

G.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We will only retain your personal
information for as long as it is necessary to fulfill the purpose for which it
was collected. The length of time we retain your information will vary
depending upon the information and why it was collected. In some instances, we
have legal and regulatory obligations to retain your information and it cannot
be deleted within those timeframes. We may retain personal information about
you for a longer period if we reasonably consider that such data may be
necessary for the establishment, exercise or defense of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. Information
that is no longer required to be retained by us will be securely destroyed or deidentified.

H.
LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES

We may create links to other
websites that we think may interest you, such as providers of various products
and services. We may also provide links that allow you to send or forward a
post from our Website through or to a third-party social media site or other
means of electronic communication, such as an email or text messaging service.
We do not endorse any other websites, providers or services by providing such
links, and our privacy policy applies only to your use of our Properties. We
are not responsible for the privacy policies of any websites and services we
link to on our Website, and you should read the privacy policies of each site
you visit to determine what information that site may collect about you.

The Website may also integrate
with social networking services. We do not control such services and are not
liable for the manner in which they operate. While we may provide you with the
ability to use such services in connection with our Website, we are doing so
merely as an accommodation and, like you, are relying upon those third party
services to operate properly and fairly.

Please be aware that personal
information which you voluntarily include and transmit online in a publicly
accessible blog, forum, social network or otherwise online may be viewed and
used by others. We are unable to control such uses of your personal
information, and by using such services you assume the risk that the personal
information provided by you may be viewed and used by third parties.

I.
YOUR CHOICES

Consistent with applicable law,
you may exercise the options described in this section regarding your choices
with respect to your personal information and communications from us. You may
also have certain additional rights available under applicable law depending on
your state or country of residence, as described further in the supplemental
information contained in the other Parts of this Privacy Policy.

Your Account, Subscriptions
and Privacy Preferences

• Your Profile Information.
  If you have an online account with us, you can review and change your
  personal information at any time by logging into your account on the
  Website and visiting your account profile page. There, you can make
  changes to your name, password, postal address, email address, phone
  number, or credit card information that you had previously entered.
• Email. If you do not
  wish to receive promotional or marketing emails from us, you can
  unsubscribe by using the unsubscribe link included in each such email. In
  some cases we may provide an unsubscribe link within an operational email
  (e.g., surveys). Please note that we will continue to send you
  notifications necessary to the Website and your account to your email
  address.
• Text Messages. We may
  send you SMS text messages if you have consented to receive mobile
  offers. You can cancel text messages at any time. After you opt-out, we
  will send you a confirmation message that you have successfully
  unsubscribed. Message and data rates may apply.
• Postal Mail. If you do
  not wish to receive catalogs, coupons, and other promotional postal mail, please
  email us at the applicable email address located at section M below.
• Telephone. If you do not
  wish to receive promotional telephone calls please email us at the
  applicable email address located at section M below. You also may opt-out
  during any in-bound telephone call from us.
• Device Location Settings.
  You may prevent your mobile device from sharing your location data by
  adjusting the permissions on your mobile device.
• Push Notifications. If
  you have enabled push notifications, you may disable these at any time by
  updating your device settings. If you have enabled push notifications on
  your web browser, you may disable these at any time by clicking into the
  message and opting-out of future notifications.

Cookies, Tracking, and
Interest-Based Advertising

If you would like to stop or
restrict the placement of cookies or flush any cookies that may already be on
your computer or device, please refer to and adjust your web browser
preferences. Further information on cookies is available at
www.allaboutcookies.org. By deleting our cookies or disabling future cookies,
you may not be able to access certain areas or features of our Website or some
of its functionality may be affected.

The online advertising industry
provides a service through which you may opt out of receiving targeted ads from
certain data partners and other advertising partners that participate in
self-regulatory programs. You can opt out of targeted advertising from certain
providers that participate in the Digital Advertising Alliance (DAA) program
at www.aboutads.info/consumers.
Other providers are members of the Network Advertising Initiative, and you can
opt out of interest-based advertising by those members by visiting http://optout.networkadvertising.org/.
Please note that by opting out, you will continue to see generic advertising
that is not tailored to your specific interests and activities.

For clarity, cookie-based
opt-outs must be performed on each device and browser that you wish to have
opted out. For example, if you have opted out on your device browser, that
opt-out will not be effective on your mobile device. Additionally, if you opt
out on one of your devices, that opt out may not be effective on all of your
devices. You must separately opt out on each device.

For targeted advertisements
delivered through mobile apps, you can install the DAA’s AppChoices app (which
is available in Google Play or the Apple App store) on your device to opt out
of targeted advertising by certain providers and can also select a system level
advertising preference feature on your device (such as “Limit Ad Tracking” on
Apple devices or “Opt-out of Interest-based ads” on Android devices).

Please note that cookie-based
opt-outs are not effective on some mobile services. Users may opt out of
certain advertisements on mobile applications or reset advertising identifiers
via their device settings. To learn how to limit ad tracking or to reset the
advertising identifier on your iOS and Android device, click on the following
links:

iOS – https://support.apple.com/en-us/HT202074
Android – https://support.google.com/ads/answer/2662922?hl=en

“Do Not Track”

Some browsers have a “Do Not
Track” feature (also known as DNT) that lets you tell websites that you do not
want to have your online activities tracked. To learn more, please visit https://www.eff.org/issues/do-not-track. We
do not respond to or honor DNT signals or similar mechanisms transmitted by web
browsers.

J.
CHILDREN’S ONLINE PRIVACY

Our Websites are not marketed to
and we do not knowingly collect or maintain personal information from children
under the age of 16. If we learn that we have collected or received personal
information from a child under the age of 16 without verification of parental
consent, we will use all reasonable efforts to delete that information from our
databases. If you believe we might have any information from or about a child
under the age of 16, please let us know by contacting us at the contact
information provided in section M below.

K.
TRANSMISSION OF INFORMATION TO OTHER COUNTRIES

If you submit personal
information to us, your personal information may be transferred to, stored and/or
processed in a foreign country where privacy laws may be less stringent than
the laws in your country. By submitting your personal information to us you
agree to the transfer, storage, and processing of your personal information in
a country other than your country of residence including, but not necessarily
limited to, the United States.

L.
CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to
change at our sole discretion, and the updated Privacy Policy will be posted on
our Website. Each version of this Privacy Policy will be identified by its last
updated date as provided at the top of this page. Please check back frequently
and review this Privacy Policy for any updated terms or changes.

M.
CONTACT US

If you have any
questions or comments regarding this Privacy Policy, please do not hesitate to email
us or write to us at the applicable address located below.

AD POPULUM

Email: legal@adpopulumllc.com

Mail: Ad
Populum, LLC, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

AMSCAN,
PARTY CITY

Email: privacy@partycity.com

Mail: PartyCity.com
LLC c/o NECA, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

Mail: Amscan II
LLC c/o NECA, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

ENESCO,
DEPARTMENT 56, ALLEN DESIGNS

Email:
privacy@enesco.com

Mail (USA):
Enesco, LLC, 500 Park Boulevard, Suite 1300, Itasca, IL 60143-1258

Mail (Canada):
Enesco Canada Corporation, 2425 Skymark Avenue, Unit 3, Mississauga, ON L4W 4Y6

Mail (UK):
Enesco Limited, Brunthill Rd, Carlisle CA3 0EN, United Kingdom

Mail
(France): Enesco France, 2426 RN 7, 06270 Villeneuve-Loubet, France

 

DIAMOND
COMICS

Email: privacyteam@diamondcomics.com

Mail: Diamond
Comics Distributor II, LLC, c/o NECA, 603 Sweetland Avenue, Hillside, New
Jersey, 07205-1799

GRACELAND

Email:
privacy@graceland.com

Mail: Elvis
Presley Enterprises 1, Inc., 3734 Elvis Presley Blvd., Memphis, TN 38116

 

NECA,
LOOTCRATE, BUILD A CRATE, HAUL-A-THON

Email: privacy@NECAonline.com

Mail: NECA,
LLC, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

KIDROBOT

Email: privacy@necaonline.com

Mail: KidRobot,
LCC, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

WIZKIDS,
DUNGEONS & DRAGONS MINIS, CONNECT WITH PIECES, TRAINS AND STATIONS

Email:
privacy@NECAonline.com

Mail:
WizKids/NECA, LLC, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

RUBIES, DENUO NOVO

Email: customerservice@rubies.com

Mail: Rubies
II, LLC 601 Cantiague Rock Road, Westbury NY 11590

EXKALIBER,
LIVIN’ WELL, FORCE 1 RC, POWERYOURFUN, USA TOYZ

Email: privacy@necaonline.com

Mail: ExKaliber
LLC, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

SMIFFYS,
CHASING FIREFLIES

Email: privacy@necaonline.com

Mail (UK): Smiffys
II, Ltd., Mercury House Willoughton Drive, Foxby Lane Business Park,
Gainsborough, DN21 1DY UK

CHRISTY’S BY
DESIGN

Email: legal@adpopulumllc.com

Mail: Christy’s
By Design Pte. Ltd., 133 Cecil Street, #17-01A Keck Seng Tower, Singapore
069535

CHIA, THE
‘OVE’ GLOVE

Email: privacy@necaonline.com

Mail: Joseph
Enterprises Inc., c/o NECA, 603 Sweetland Avenue, Hillside, New Jersey,
07205-1799

LOUD SHOP

Email: legal@adpopulumllc.com

Mail:
LoudShop.com, Universal House, Pennywell Rd, St Jude’s, Bristol BS5 0ER, United
Kingdom

MOVIEGALLERY.COM,
HOLLYWOODVIDEO.COM, GAMECRAZY.COM

Email: privacy@NECAonline.com

Mail: MGIP, LLC,
c/o NECA, 603 Sweetland Avenue, Hillside, New Jersey, 07205-1799

PART II: SUPPLEMENTAL INFORMATION FOR RESIDENTS
OF SPECIFIC US STATES

NEVADA

This paragraph supplements Part I
of this Privacy Policy if you are a consumer in the State of Nevada. If this
applies to you, you may request to opt-out of the current or future sale of
certain of your personal information. We do not currently sell any of your
personal information for monetary consideration under Nevada law, nor do we
plan to do so in the future. However, you can submit a request to opt-out of
future sales, as defined by Nevada law, by contacting us at the applicable
email address located at section M above. Please include “Opt-Out Request Under
Nevada Law” in the subject line and body of your message.

CALIFORNIA

The following paragraphs
supplement Part I of this Privacy Policy if you are a consumer in the State of
California. The California Consumer Privacy Act of 2018 (“CCPA”) and the
California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California
Consumer Privacy Laws,” provide California consumers with specific rights
regarding their personal information. This California Privacy Rights provision
describes your rights under the California Consumer Privacy Laws, explains how
you may exercise your rights, and provides an overview on the types of personal
information we collect. To exercise the rights below please see the section
entitled How to Contact Us About Your California Privacy Rights.

California Consumer Privacy Laws
provide you with the following rights:

• Right to know. You
  have the right to know what categories and specific pieces of personal
  information we collect about you, the sources from which we collect
  personal information, our business or commercial purpose for the
  collection, use, and sharing of your personal information, and any
  categories of third parties to whom we sell or with whom we share your
  personal information.
• Right to data portability. You
  have the right to request a copy of personal data we have collected and
  maintained about you in the past 12 months. California Consumer
  Privacy Laws allow you to request your information from us up to twice
  during a twelve (12) month period. We will provide our response in a
  readily usable format, which is usually electronic.
• Right to delete. You
  have the right to request that we delete the personal information that we
  have collected from you and maintained, subject to certain exceptions.
  Please note that if you request deletion of your personal data, we may
  deny your request or may retain certain elements of your personal data if
  certain exceptions apply under California Consumer Privacy Laws.
• Right to opt out of selling
  or sharing. You have the right to opt out of the sale or sharing
  of your personal information, along with the right to opt in to the sale
  of such information. If we sell or share any of your personal information,
  you may, at any time, tell us not to sell or share your personal
  information. We will also treat Global Privacy Control browser signals as
  opt-out of sale/share requests under the California Consumer Privacy Laws.
  At the time this Privacy Policy was last updated, we have sold (as defined
  in California Consumer Privacy Laws) and shared personal information for
  the purpose of cross-context behavioral advertising in the past 12 months,
  as detailed below.
• Right to correct. You
  have the right to request the correction of any personal information we
  maintain about you.
• Right to limit use or
  disclosure of sensitive personal information (“SPI”). You have
  the right to limit the use or disclosure of your SPI if we are using your
  SPI beyond what is reasonable and proportionate to provide the requested
  goods or services.
• Right to nondiscrimination. You
  have the right not to receive discriminatory treatment by us for the
  exercise of your CCPA privacy rights. Unless permitted by the CCPA, we
  will not:
• Deny you goods or services.
• Charge you different prices or
  rates for goods or services, including through granting discounts or other
  benefits, or imposing penalties.
• Provide you a different level
  or quality of goods or services.
• Suggest that you may receive a
  different price or rate for goods or services or a different level or
  quality of goods or services.

How to Contact Us About Your
California Privacy Rights

• Emailing us at the
  applicable email address located at section M above.

Verification of Your Identity

After you submit a request, (except
as otherwise may be provided under California Consumer Privacy Law with respect
to opt-out requests) we must verify your identity in order for us to properly
respond and/or confirm that it is not a fraudulent request. To verify your
identity, we will request, at a minimum, that you provide your name, email
address, phone number, address, and relationship to us, so that we can seek to
match this information with the information existing in our systems. When
providing us this information, you represent and affirm that all information
provided is true and accurate. If we are unable to verify that the consumer
submitting the request is the same individual about whom we have collected
personal information, we may contact you for more information, or we may not be
able to meet your request.

Only you, or an agent legally
authorized to act on your behalf, may make a verifiable request related to your
personal information. If you are making a request as the authorized agent of a
California consumer, we will ask you also submit reliable proof that you have
been authorized in writing by the consumer to act on such consumer’s behalf.

Our Response Time to Your
Request

We will make every effort to
respond to your request within forty-five (45) days from when you contacted us.
If you have a complex request, the California Consumer Privacy Laws allow us up
to ninety (90) days to respond. We will still contact you within forty-five
(45) days from when you contacted us to let you know we need more time to
respond.

Sale of Information

In the preceding 12 months, we
have sold your internet or other electronic network activity collected via
cookies and other tracking technologies to data analytics providers and ad
networks. We do not sell your personal information for monetary consideration,
but the disclosure of your information to certain third parties may be
considered a “sale” under California Consumer Privacy Laws. We may have also
shared your identifiers and information collected from your purchases with
other third parties, which may be also be deemed a sale under the California
Consumer Privacy Laws.

Categories of Personal
Information We Collect and Our Purposes of Collection and Use

You can find a list of the
categories of personal information we collect in the Personal Information
We Collect From You section above. For information regarding the
sources from which we obtain personal information, please see the How
We Collect Your Personal Information section above. And to learn more
about the business or commercial purposes for which we collect and use personal
information please see the How We Use Your Personal Information &
Purpose for Collection section above.

Categories of Personal
Information Disclosed and Categories of Parties to Whom it was Disclosed.

The categories of personal
information that may have been disclosed to a third party for a business
purpose or other commercial purposes, as well as the purposes for disclosing
that information, are provided in the How We Disclose Your Personal
Information and How We Use Your Personal Information &
Purpose for Collection sections of this Privacy Policy, above and are
further summarized below.

In the past 12 months, we have disclosed
the following categories of personal information to the following categories of
third parties for the purposes stated below:

• We have disclosed your personal
  identifiers, internet or other electronic network activity, your customer
  records information, and geolocation data to data analytics providers,
  operating systems, and other third parties to help us perform services,
  including maintaining or servicing accounts, providing customer service,
  processing or fulfilling orders and transactions, verifying customer
  information, processing payments, providing advertising or marketing
  services, providing analytics services, providing email communications,
  providing delivery services, and hosting our Website.
• We have disclosed your personal
  identifiers, geolocation data, and internet or other electronic network
  information to IT support and data analytics providers to detect security
  incidents, protect against malicious, deceptive, fraudulent, or illegal
  activity, and to identify and repair Website errors that impair
  functionality.
• We have disclosed your personal
  identifiers, internet or other electronic network information, and
  geolocation to data analytics providers and operating systems to help us
  undertake activities to verify or maintain the quality or safety of a
  service or device that is owned, manufactured, manufactured for, or
  controlled by us, and to improve, upgrade, or enhance the service or
  device that is owned, manufactured, manufactured for, or controlled by us.
• We have disclosed your personal
  identifiers, geolocation data, and internet or other electronic network
  information to data analytics providers and operating systems to undertake
  internal research for technological development and demonstration.

The following categories of
personal information may have been sold or shared (as defined by
California Consumer Privacy Laws) to a third party for the purpose of
cross-context behavioral advertising:

• Personal identifiers, such as
  name, phone number and email address;
• Internet or other electronic
  network activity information, such as your IP address, type of browser,
  version of operating system, carrier and/or manufacturer, device
  identifiers, device event information, make and model of device, and
  mobile advertising identifiers; and

Each of the categories of
personal information listed above may be sold or shared with the following
categories of third parties for the purpose of cross-context behavioral
advertising:

• Advertising publishers,
  advertising networks and other partners that place advertisements on our
  behalf;
• Advertising partners that place
  advertisements on our Website on behalf of other advertisers; and
• Parties that provide
  statistical and analytic information regarding the effectiveness of our
  marketing.

Sensitive Personal Information.

We may collect or process precise
geolocation data. This information may be considered “sensitive personal
information” under California Consumer Privacy Laws. However, we do not use
your geolocation information to infer other characteristics about you. To the
extent required by the California Consumer Privacy Laws, you may limit the processing
of your sensitive personal information by contacting us through the methods
noted above.

Notice of Financial Incentive

We may provide programs, such as
sweepstakes, contests, or other similar promotional campaigns (collectively,
the “Programs”). When you participate in one of these Programs, we
typically ask you to provide your name and contact information (such as email
address and/or telephone number). Because our Programs involve the collection
of personal information, they may be considered a “financial incentive” program
under California Consumer Privacy Laws. 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, less the expense related to offering those products, services, and
benefits to Program participants.

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. Visit the terms and
conditions page of each Program to view full details, including how to join.
You may also withdraw from or opt in to the Program by emailing us at the
applicable email address located at section M above.

California “Shine the Light”

Under California Civil Code
Section 1798.83 (“Shine the Light”), California residents have the right to
request in writing from businesses with whom they have an established business
relationship: (a) a list of the categories of personal information, as defined
under Shine the Light, such as name, email address, and mailing address, and
the type of services provided to the customer that a business has disclosed to
third parties (including affiliates that are separate legal entities) during
the immediately preceding calendar year for the third parties’ direct marketing
purposes; and (b) the names and addresses of all such third parties. To request
the above information, please contact us by email at the applicable email
address located at section M above. If you do not want your personal
information shared with any third party who may use such information for direct
marketing purposes, then you may opt out of such disclosures by sending an
email to us at the applicable email address located at section M above.

OTHER STATES

The following paragraphs
supplement Part I of this Privacy Policy if you are a consumer in a US state
not already covered above. Depending on the state in which you reside, you may
have certain privacy rights. The exact scope of these rights may vary by state.
You may exercise such rights as detailed below in the section entitled How
to Contact Us About Your State’s Privacy Rights.

If you are a resident of
Colorado, Connecticut, Florida, Montana, Oregon, Texas, Virginia, Utah,
Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota,
Maryland (Oct 2025), Kentucky (Jan. 2026), Indiana (Jan. 2026), Rhode Island
(Jan 2026) you may have the following rights:

Right to Know. You
have the right to know and see what personal data we have collected about you.

Right to Data Portability. You
have the right to obtain a copy of your personal information that you
previously provided to us in a portable and, when feasible, readily usable
format, where the processing is carried out by automated means.

Right to Correct. Residents
of Colorado, Connecticut, Florida Montana, Oregon, Texas, Virginia, Delaware,
New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Kentucky,
Indiana, Rhode Island have the right to correct inaccuracies in your personal
information, taking into account the nature of the personal information and the
purposes of the processing of your personal information.

Right to Delete. Residents
of Colorado, Connecticut, Florida, Montana, Oregon, Texas, Virginia, Delaware,
New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Kentucky,
Indiana, Rhode Island have the right to request that we delete personal
information provided by, or obtained about, you.

Right to opt out of
Processing. You have the right to opt out of the sale of your personal
information and/or the processing of your personal information for purposes of
(i) targeted advertising (excluding Iowa), (ii) profiling in furtherance of
decisions that produce legal or similarly significant effects concerning you,
and (iii) profiling in furtherance of decisions that produce legal or similarly
significant effects concerning you (residents of Colorado, Connecticut,
Florida, Montana, Oregon, Texas, Virginia, Delaware, New Hampshire, New Jersey,
Nebraska, Tennessee, Minnesota, Maryland, Kentucky, Indiana, Rhode Island). As
of the date of this Privacy Policy:

• We do process personal
  information for the purposes of targeted advertising
• We do not sell your personal
  information in exchange for monetary consideration
• We do not engage in profiling
  decisions based on your personal information that produce legal or
  similarly significant effects concerning you.

Right to limit use or
disclosure of sensitive personal information (“SPI”). You may have the
right to either limit (opt-out of) or require consent to process sensitive
personal data. Florida residents have the right to opt out of the collection or
processing of sensitive data and to opt out of the collection of personal data
collected through the operation of a voice recognition or facial recognition
feature.

Right to Nondiscrimination. The
right to not be discriminated for exercising the aforementioned rights.

Categories of Personal
Information We Collect and Our Purposes of Collection and Use

You can find a list of the
categories of personal information we collect in the Personal
Information We Collect From You section above. For information
regarding the sources from which we obtain personal information, please see
the How We Collect Your Personal Information section above.
And to learn more about the business or commercial purposes for which we
collect and use personal information please see the How We Use Your
Personal Information & Purpose of Collection section above.

Categories of Personal
Information Disclosed and Categories of Parties to Whom it was Disclosed.

The categories of personal
information that may have been disclosed to a third party for a business
purpose or other commercial purposes, as well as the purposes for disclosing
that information, are provided in the How We Disclose Your Personal
Information and How We Use Your Personal Information &
Purpose for Collection sections of this Privacy Policy, above and are
further summarized below.

In the past 12 months, we have
disclosed the following categories of personal information to the following
categories of third parties for the purposes stated below:

• We have disclosed your personal
  identifiers, internet or other electronic network activity, your customer
  records information, and geolocation data to data analytics providers,
  operating systems, and other third parties to help us perform services,
  including maintaining or servicing accounts, providing customer service,
  processing or fulfilling orders and transactions, verifying customer
  information, processing payments, providing advertising or marketing
  services, providing analytics services, providing email communications,
  providing delivery services, and hosting our Website.
• We have disclosed your personal
  identifiers, geolocation data, and internet or other electronic network
  information to IT support and data analytics providers to detect security
  incidents, protect against malicious, deceptive, fraudulent, or illegal
  activity, and to identify and repair Website errors that impair
  functionality.
• We have disclosed your personal
  identifiers, internet or other electronic network information, and
  geolocation to data analytics providers and operating systems to help us
  undertake activities to verify or maintain the quality or safety of a
  service or device that is owned, manufactured, manufactured for, or
  controlled by us, and to improve, upgrade, or enhance the service or
  device that is owned, manufactured, manufactured for, or controlled by us.
• We have disclosed your personal
  identifiers, geolocation data, and internet or other electronic network
  information to data analytics providers and operating systems to undertake
  internal research for technological development and demonstration.

How to
Contact Us About Your State’s Privacy Rights

• Emailing
  us at the applicable address located at section M of Part I of this
  Privacy Policy.

Appeals

We respond to requests to
exercise privacy rights in accordance with our legal obligations, but please
note that not all of these rights may be available to you depending on where
you live. If we decline to take action regarding a request that you have
submitted, we will inform you of our reason for declining to take action and
provide instructions for how to appeal the decision. In the event that we do
not respond to a request that you make pursuant to one of the privacy rights
set forth above, you may have the right to appeal our refusal to take action
within a reasonable period of time after you receive our decision. In such
instances, within 60 days of our receipt of an appeal, 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 the appeal is denied,
we will also provide you with an online mechanism, if available, or other
method through which you may contact the Attorney General to submit a
complaint. In certain circumstances, we may decline a privacy rights request,
particularly where you are not a resident of one of the eligible states or
where we are unable to verify your identity.

PART III: SUPPLEMENTAL INFORMATION FOR RESIDENTS
OUTSIDE THE USA

This Part III supplements Part I
of this Privacy Policy if you are a consumer outside the US (e.g., in Canada, the
United Kingdom, the European Economic Area (“EEA”)). If you are a
resident of Australia or New Zealand, please also see Part IV and Part V of
this Privacy Policy.

Legal Basis for Processing

In countries and regions where it
applies, we collect, process, use and, as applicable, disclose personal
information related to you on the basis of the following legal grounds under
the General Data Protection Regulation, Regulation (EU) 2016/679 of the
European Parliament and of the Council of 27 April 2016 on the protection of
natural persons with regard to the processing of personal data and on the free
movement of such data (“GDPR^”):

• Your consent (Art. 6(1) letter
  (a) GDPR): by using or interacting with any of our Properties, you consent
  to your personal information being collected and processed by us for the
  purposes and as regulated in this Privacy Policy. You may vary or fully
  revoke your consent at any time, by sending an email to the contact details set out in Section N
  below. Withdrawal of consent will have an effect only for the future and
  does not affect the legitimacy of our use and/or processing of your
  personal information until that date. Please note that you will be unable
  to use all or part of the Website and/or may not have access to or be able
  to benefit fully from our Properties if you do not provide consent to the
  processing of your personal information. Please note that we may continue
  to use any part of your personal information for which we may have other
  legal grounds for processing in accordance with the applicable law.
• When the processing is
  necessary for the performance of a contract between us and you or in order
  to take steps at your request prior to entering into a contract (Art. 6
  (1) letter (b) GDPR): such as to provide products and services, fulfill
  your orders and/or complete the transactions you request, provide access
  to our Properties, process your payments, provide you receipts and order
  updated or deliver your purchases.
• Our legitimate interests (Art.
  6 (1) letter (f) GDPR):  To the extent necessary, we may also process your
  personal information to protect legitimate interests of our own and/or of
  third parties (such as, but not limited to, maintaining security of our
  Properties, resolving disputes and/or troubleshooting problems, for other
  security and fraud-prevention purposes, marketing and publicity). When we
  process your personal data to meet our legitimate interests, we balance
  our legitimate interests against your fundamental rights and freedoms and
  we implement appropriate safeguards to ensure that your interests, rights
  and freedoms do not override our legitimate interests. For more
  information about this, please contact us at the contact details provided
  in Section N below.
• As required for compliance with
  a legal obligation to which we are subject (Art. 6(1) letter (c) GDPR): for
  example, in order to respond to legal or regulatory inquiries, to
  establish or exercise our rights, and to defend against a legal claim.

Transmission of Information
Outside the EEA

As discussed in Part I of this
Privacy Policy, if you submit personal information to us, your personal
information may be transferred to, stored and/or processed in a foreign country
where privacy laws may be less stringent than the laws in your country.

Transfers of personal information
to jurisdictions outside the EEA and/or other countries to which the European
Commission has recognized an adequate level of protection of personal data
through an adequacy decision shall be performed only subject to adequate
safeguards, as provided by the applicable legislation. Such transfers of
personal information may be based on (i) standard data transfer clauses adopted
by the European Commission (such as those adopted through European Commission
Implementing Decision (EU) 2021/914 on standard contractual clauses for the
transfer of personal data to third countries pursuant to Regulation (EU)
2016/679); (ii) certain particular data protection frameworks (such as the
EU-US Data Privacy Framework); (iii) binding corporate rules or (iv) such other
appropriate safeguards within the meaning of Art. 46 of the European General
Data Protection Regulation (GDPR) adopted pursuant to  Regulation (EU) 2016/679.

You have the right to ask us for
more information about the safeguards we have put in place as mentioned above.
Contact us as at the contact details set out in Section M of Part I of this
Privacy Policy if you would like further information.

Data Subject Rights (General)

Depending on your country of
residence, you may have certain additional rights available under applicable
law depending on country of residence. These rights may include:

·
Right to Know. You have the right to be provided with
clear, transparent and easily understandable information about how we use your
information and your rights. This is why we’re providing you with the
information in this Privacy Policy.  If you have any questions about our Privacy
Policy, please contact us at the applicable address located at section M of
Part I of this Privacy Policy.

·
Right to Withdraw Your Consent. To the extent a specific
element of our processing of your personal information relies upon your
consent, you may withdraw such consent at any time with future effect.  Such a
withdrawal will not affect the lawfulness of the processing prior to the
consent withdrawal.

·
Right to Access. You may have the right request access to your
personal information and certain other information about how we use your
information (e.g., the purposes of the processing, the categories of personal
information concerned, and how it has been or will be disclosed).  The
interests of other individuals may restrict your access.  You may have the
right to obtain a copy of your personal information free of charge.  For
further copies requested by you, we may charge a reasonable fee based on
administrative costs.

·
Right to Correct. You may have the right to have your
personal information corrected if it’s inaccurate or incomplete.

·
Right to Erasure. This is also known as “the right to be
forgotten”. In certain circumstances, you may request the deletion or removal
of your personal information.

·
Right to Restrict. Under certain circumstances, you may
have the right to restrict further use by us of your personal information. When
processing is restricted, we can still store your information, but may not continue
to use it.

·
Right to Data Portability. Under certain circumstances,
you may have the right to receive the personal information we have collected concerning
you, or which you have provided to us, in a structured, commonly used and
machine-readable format, and you may have the right to transmit that
information to another entity without hindrance from us.

·
Right to Object. Under certain circumstances, you may have
the right to object to your personal information being used by us in certain ways,
including data processing, processing for direct marketing and automated
decision making. This may include the right to know whether we sell your
personal information and the right to prohibit the sale your personal
information; at the current time we do not sell or share your personal
information with third parties for their marketing purposes.

·
Right to Non-Discrimination. We do not discriminate
against individuals who exercise any of their rights described in this Privacy
Policy.  However, we may require use of your personal information to provide
you with access to and optimal use of our Properties. In such cases, where you
object to certain use of your personal information (including our ability to
make automated decisions based on personal information you’ve supplied or we’ve
collected about you) it may negatively affect our ability to provide you with
the optimum level of customer service and our ability to provide you with
certain services.

Data Subject Rights (Under GDPR)

Where GDPR applies, you have a
number of rights under the law in relation to your personal information, as
follows:

• the right of access pursuant
  to Art. 15 GDPR: you have the right to obtain from us confirmation as
  to whether or not personal information concerning you is being processed,
  and, where that is the case, access to (including by obtaining a copy of)
  such personal information and the manner in which, and the purposes for
  which we process your personal information so that you can verify its
  accuracy and the lawfulness of the processing; Please note that once we
  transform your personal information into anonymous information, we will no
  longer be able to provide you with a copy of any such data which was
  initially provided by you as personal information.
• the right to rectification
  pursuant to Art. 16 GDPR: you have the right to obtain from us the
  rectification of inaccurate personal information concerning you, and the
  right to have incomplete personal data completed, including by means of
  providing a supplementary statement
• the right to erasure
  pursuant to Art. 17 GDPR: the right to obtain from us the erasure of
  your personal information where (a) your personal information is no longer
  necessary for the purpose for which it was collected/processed; (b) you
  wish to withdraw your consent to the processing of such data by us (except
  where we have another legal ground for the processing that we may rely
  on); (c) where processing is based on our legitimate interests and there
  are no overriding legitimate grounds for processing; (d) where your
  personal information has been unlawfully processed; Please note that,
  where we have disclosed your personal information to third parties before
  your exercise of the right to erasure, we may be unable to procure that
  such third parties also give effect to such request. Where your personal
  information has been made accessible on a public forum (such as a website,
  social media platform or similar public channel), we may be unable to
  direct or procure that the operators of such website/platforms/channels
  comply with such erasure request (and you may need to refer directly to
  such operators).
• the right to restriction of
  processing pursuant to Art. 18 GDPR: you have the right to obtain from
  us the restriction of processing of your personal information where (a)
  the accuracy of such personal information is contested by you (for such
  period as will enable us to verify the accuracy of your personal
  information); (b) the processing of your personal information is unlawful,
  but you object to the deletion of such data and request restriction of its
  use instead; (c) you consider that we no longer need your personal
  information for the purposes of the processing, but require such personal
  information for the establishment, exercise or defense of legal claims;
  (d) you have objected to the processing of your personal information on
  grounds of ‘legitimate interest’ as per (iii) above, pending verification
  by us on whether our legitimate grounds override your own.
• the right to objection
  pursuant to Art. 21 GDPR: you have the right to object, on grounds
  relating to your particular situation, at any time to processing of your
  personal information, which is based on our legitimate interests. We shall
  no longer process the personal information unless we have compelling
  legitimate grounds for the processing which override your interests,
  rights and freedoms or for the establishment, exercise or defense of legal
  claims. You may object to the processing of your personal information for
  direct marketing purposes at any time, without giving reason.
• the right to data
  portability pursuant to Art. 20 GDPR: You have the right to receive
  personal information concerning you, and which you have provided to us, in
  a structured, commonly used and machine-readable format, and to transmit
  such data to another data controller (please note this applies only where
  our processing of your personal information is based on your consent or on
  a contract, and the processing is carried out by automated means)
• the right to appeal to a
  competent data protection supervisory authority (Art. 77 GDPR): you
  have the right to appeal to the competent data protection supervisory
  authority.

Exercise of Your Rights

We encourage you to first contact
us directly to resolve any concerns/complaints with respect to the processing
of your personal information by us.

To exercise your rights, please
contact us at the appropriate address set out in section M of Part I of this
Privacy Policy.  You also have the right to lodge a complaint with the
competent data protection supervisory authority if we have not addressed your
questions or concerns about personal information. Please note that you may not
be able to submit a complaint to such authority until you have first approached
us to attempt to resolve any such dissatisfaction or complaint.

If you choose to assert any of
these rights under applicable law, we will respond within the time period
prescribed by applicable law.  Please note that many of the above rights are
subject to exceptions and limitations. For example, under GDPR, your exercise
of these rights is subject to certain exemptions to safeguard the public
interest (e.g. the prevention or detection of crime), our interests (e.g. the
maintenance of legal privilege) or rights and freedoms of others. Your rights
and our responses will vary based on your country or territory of residency.

While we will make good faith
efforts to provide you with access to your personal information, we may deny or
limited access to such personal information where: this would interfere with
the execution or enforcement of the law or with private causes of action
(including the prevention, investigation or detection of offences or the right
to a fair trial); the legitimate rights and interest of others would be
violated through such disclosure; this would prejudice the confidentiality
necessary in monitoring, inspection or regulatory functions connected with
sound management, or in future or ongoing negotiations involving us. We will of
course endeavor to offer you an adequate explanation of the necessity, and
reason for, restricting access in the circumstances mentioned above.

If you exercise any of these
rights, we will check your entitlement and respond without undue delay, but not
later than within a month. In complex cases or at times of receiving numerous
requests, this period may be extended by two further months of which we will
inform you.

To review or update your personal
information including user information to ensure it is accurate, please write
to us at the contact details provided in Section M of Part I of this Privacy
Policy, informing us of any changes that may need to be made in respect of your
personal information and we will update such information on your behalf and in
our systems.

If you want us to delete your
personal data from our systems, please write to us at the contact details
provided in Section M of Part I of this Privacy Policy. You may no longer be
able to use the Website and or other Properties afterwards, as certain personal
information is necessary in order for us to provide the Website.

Please remember, however, if we
have already disclosed some of this personal information to third parties, we
may not be able to access that information any longer or force the deletion or
modification of any such information by the parties to whom we have made those
disclosures. We will of course comply with any legal obligation we may have to
notify them of your request.

Please note that even though you
may request the deletion of your personal information by us, we may be required
(by law or otherwise, such as to prevent fraud, resolve disputes, or
troubleshoot problems) to keep this information and not delete it, or to keep
this information for a certain time, in which case we will comply with your
deletion request only after we have fulfilled such requirements.

When you request deletion of your
personal information, such personal information will be deleted from the active
database, but (limited) personal information may remain in our archives where
legally permitted.

Please note that any processing
of your personal information prior to the deletion of your account will remain
valid under the legal grounds then prevailing.

PART IV: SUPPLEMENTAL INFORMATION
FOR RESIDENTS OF AUSTRALIA

This Part IV applies to you only
if you are located in Australia. This Part IV is supplemental to Part I and
Part III of this Privacy Policy which also apply to you if you are located in
Australia. In the event of an inconsistency between this Part IV and Part I or Part
III of this Privacy Policy, the information in this Part IV prevails, to the
extent of the inconsistency.

We collect, process, use and, as
applicable, disclose personal information in accordance with the Privacy Act
1988 (Cth) (Australian Privacy Act) and the Australian Privacy Principles
(APPs) as set out in Schedule 1 of the Privacy Amendment (Enhancing Privacy
Protection) Act 2012 (Cth).

We have adopted the APPs. A copy
of the Australian Privacy Act and the APPs can be provided on reasonable
request.

Collection of Unsolicited
Information

If we receive unsolicited
personal information about you, we will determine whether such information is
of the nature that it could have been collected by us if we had solicited it
from you. If that is not the case, we will destroy or de-identify the
unsolicited information.

Direct Marketing

Direct marketing to you is
permitted in accordance with APP 7. However, APP 7 does not apply to the extent
that any of the following apply: (a) the Do Not Call Register Act 2006
(Cth); (b) the Spam Act 2003 (Cth); or (c) any other Commonwealth Act,
or a Norfolk Island enactment, prescribed by the regulations.

Cross-Border Disclosure of Personal
Information

Before disclosing your personal information
to an overseas recipient, we will take reasonable steps, as appropriate in the
circumstances, to ensure that the overseas recipient does not breach the APPs.
This paragraph will not apply if: (a) in the jurisdiction of the overseas
recipient, there is a substantially similar law or scheme to protect your
personal information and there are mechanisms that you can access to take
action to enforce that protection, the overseas recipient may comply with that
law or scheme; or (b) you consent to the disclosure of your personal
information to the overseas recipient, knowing that such consent means the
paragraph will not apply.

When the overseas recipient is
us, we will treat your personal information in accordance with this Privacy
Policy.

Security of Personal
Information

If we hold your personal
information and we no longer need that information for any purpose for which
the information may be used or disclosed under this Privacy Policy, we will
take reasonable steps, as appropriate in the circumstances, to destroy or
de-identify the information.

Access to Personal Information

If we hold your personal
information, you are entitled to request access to that information. Unless an
exemption under the APPs applies, we will comply with your request. Even if an
exemption does apply, we will still take reasonable steps to give you access to
your information in a manner which meets your needs, if possible in the
circumstances.

We will respond to your request
for access to your personal information within a reasonable period of time and,
where reasonably practicable, in the manner requested by you.

We will not charge you for the
making of a request to access your personal information. We may charge you for
providing access to your personal information, however this charge must not be
excessive.

If we refuse you access to your
personal information, we will provide you with written notice of the reasons
for our refusal and how you can make a complaint about the refusal.

Correction of Personal
Information

If we hold your personal
information and, either: (a) we are satisfied that the information is
inaccurate, out of date, incomplete, irrelevant or misleading; or (b) you
request that we correct the information, then we will take such steps (if any)
that are reasonable in the circumstances to correct that information.

If your information has
previously been disclosed to a third party and that information has since been
corrected, we will disclose the corrected information, if requested by you.

We will respond to your request
to correct your personal information within a reasonable period of time.

We will not charge you for the
making of a request to correct your personal information. We will not charge
you for any action required by us as a result of your request to correct your
personal information.

If we refuse to correct your
personal information, we will provide you with written notice of the reasons
for our refusal and how you can make a complaint about the refusal.

How an Individual Can Make a
Complaint

If you wish to make a complaint
about the manner in which we have dealt with your personal information, you can
contact us using the details in section M of this Privacy Policy.

After contacting us, if you
remain unsatisfied with the manner in which we have dealt with your personal
information, you may contact the Office of the Australian Information
Commissioner for guidance on the courses of action which may be available to
you.

Office of the Australian
Information Commissioner

Website:            https://www.oaic.gov.au

Email:                 enquiries@oaic.gov.au

Telephone:       1300 363 992

PART V: SUPPLEMENTAL INFORMATION FOR RESIDENTS
OF NEW ZEALAND

This Part V applies to you only if
you are located in New Zealand. This Part V is supplemental to Part I and Part
III of this Privacy Policy which also apply to you if you are located in New
Zealand. In the event of an inconsistency between this Part V and Part I or Part
III of this Privacy Policy, the information in this Part V prevails, to the
extent of the inconsistency.

We collect, process, use and, as
applicable, disclose personal information in accordance with the Privacy Act
2020 (NZ) (NZ Privacy Act) and, in particular, the Information Privacy
Principles (IPPs), as set out in section 22 of the NZ Privacy Act.

We have adopted the IPPs. A copy
of the NZ Privacy Act and the IPPs can be provided on reasonable request.

Purpose of Collection of Personal
Information

Personal information will not be
collected unless it is for a lawful purpose connected with a function or
activity of ours and such collection is necessary for that purpose.

Cross-Border Disclosure of Personal
Information

We may disclose your personal
information to a foreign entity or person only in circumstances described in
IPP 12.

If we expressly inform you that
by providing the personal information to a foreign entity or person that you
may not have the same protections or safeguards in that jurisdiction than under
New Zealand law, and you authorize disclosure of the personal information, such
authorization satisfies IPP 12.

Storage and Security of
Personal Information

If we hold your personal
information, we will ensure that the information is protected by such security
safeguards as are reasonable in the circumstances.

In circumstances where it is
necessary for the information to be disclosed, we will do everything reasonably
within our power to prevent unauthorized use or unauthorized disclosure of the
information.

Access to Personal Information

You may request from us: (a) confirmation
as to whether we hold any of your personal information; and (b) access to your
personal information.

The rules
as to how we respond to your request are set out in Part 4, Subpart 1 of the NZ
Privacy Act. Such response will be provided within 20 working days of the
request.

If we refuse your request to
access your personal information, we will provide you with written notice as to
the reasons for the refusal.

If you are given access to your
personal information, you will be advised that you may request a correction of
that information.

Correction to Personal
Information

You are entitled to request a
correction of your personal information. We will take such steps (if any) that
are reasonable in the circumstances to ensure that, having regard to the
purposes for which the information may be lawfully used, the information is
accurate, up to date, complete and not misleading.

If we deny your request to
correct your personal information, and you provide us with a statement of
correction, we will take steps that are reasonable in the circumstances to
attach your statement of correction to the personal information.

The rules as to how we respond to
your request are set out in Part 4, Subpart 1 of the NZ Privacy Act. Such
response will be provided within 20 working days of the request.

If we refuse your request to
correct your personal information, we will provide you with written notice as
to the reasons for the refusal.

How an Individual Can Make a
Complaint

If you wish to make a complaint
about the manner in which we have dealt with your personal information, you can
contact us using the details in section M of this Privacy Policy.

After contacting us, if you
remain unsatisfied with the manner in which we have dealt with your personal
information, you may contact the New Zealand Office of the Privacy Commissioner
for guidance on the courses of action which may be available to you.

New Zealand Office of the
Privacy Commissioner

Website:            https://www.privacy.org.nz/

Email:                 enquiries@privacy.org.nz

Telephone:       0800 803 909