Privacy Policy

YOUR PRIVACY IS IMPORTANT TO US

This Privacy Policy ("Policy") outlines the policies and practices of Zameni & Co LLC ("Zameni & Co," "we," "us," or "our") regarding the collection, use, and disclosure of personal information. We are committed to respecting your privacy rights and maintaining the security of your personal information. Personal information, as used in this Policy, refers to information that can identify, relate to, describe, be associated with, or be reasonably linked to you or your household. We adhere to data privacy and security laws to ensure compliance and protect your personal information.

The purpose of this Policy is to provide you with an overview of our current practices for collecting, using, and disclosing personal information. These practices have remained consistent for the past 12 months. If you have provided us with your personal information or if we have obtained your personal information from other sources, we handle it in accordance with this Policy.

ACCEPTANCE OF TERMS AND UPDATES TO THE PRIVACY POLICY

By accessing or using the site, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. We may periodically update this Privacy Policy to incorporate new practices and procedures concerning your personal information. Any changes to this Privacy Policy will be posted here and will replace the previous version. In some cases, if you have provided us with your email or mailing address, we may also notify you of the changes.

PERSONAL INFORMATION AND THE PURPOSE OF COLLECTION

We collect the following personal information when you use our services, along with an explanation of why we collect it:

Product Purchases: When you purchase our goods or products, whether through our website or other means, we may collect your name, postal address, date of birth, email address, order information, questionnaire responses, and payment details (e.g., credit card, Apple Pay, Google Pay, PayPal, Amazon Pay, Afterpay, etc.). This information is collected to process and deliver your purchased products, address customer service inquiries, and for internal business purposes.

Marketing: We may collect your name, postal address, email address, and phone number for marketing and sales purposes, including sending advertisements, catalogs, promotions, and other sales communications.

Website: When you visit our website, we collect your Internet Protocol ("IP") address, cookies, and information about your activities and interactions on our site. This information is collected to provide you with relevant website content, understand user preferences, customize your experience, and personalize suggestions and advertisements.

Customer Service: If you contact our customer service department via phone, email, website contact form, or live chat, we may collect your name, phone number, postal address, email address, and any messages or content you share with us. We collect this information to address and follow up on your customer service inquiries.

As outlined below, we may collect or have collected the following categories of personal information ("PI" or "personal information") in the past 12 months. We may add new categories of PI and purposes for its use, in which case we will update this section of the Privacy Policy.

PI does not include:

Publicly available information from government records. Deidentified or aggregated consumer information. Information excluded from the scope of the CCPA, such as certain health or medical information, personal information collected, processed, sold, or disclosed under specific laws like the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, and other information protected by different regulations.

We have collected your PI for the following business or commercial purposes. We may change or add to these purposes, and if required by law, we will inform you and obtain your consent.

To provide you with information, products, or services you request. To fulfill or meet the reason for which the information is provided. To contact you and send email alerts and other notices regarding our products, services, events, or news of potential interest to you. To process payments. To engage in marketing activities. To communicate with you on social media about our products and services. To fulfill our contractual obligations and enforce our rights, including billing, payment, and collections. To review, improve, and monitor our website, applications, online services, and overall customer experience, including customization based on specific needs. To provide customer service and ensure product and service quality control. For testing, research, analysis, and product and service development. To respond to law enforcement requests and comply with applicable laws, court orders, regulations, or legal processes. As disclosed to you during the collection of your personal information or as stated in the CCPA. To process employment applications and enhance our recruitment efforts. To protect our rights, property, security, safety, employees, consumers, information systems, and the general public. To evaluate or facilitate a merger, divestiture, restructuring, reorganization, dissolution, sale, or transfer of some or all of our assets, whether as a going concern or part of bankruptcy, liquidation, or similar proceedings, where personal information held by us is among the assets transferred. You. We may collect personal information that you provide to us over the internet, through our website or mobile app, via email, or during phone conversations or in-person meetings with our professionals. We may also collect information when you attend our events or visit our physical locations. Related Entities and Affiliates. We may collect information about you from our related parties, affiliates, and joint ventures. Social media and related services. Third Parties. We may lawfully obtain information about you from other third-party sources. This could include service providers such as data storage providers, logistics and delivery services, customer relationship management providers, and other authorized service providers.

SHARING OF YOUR PERSONAL INFORMATION

We do not sell or share your personal information, including sensitive personal information, with third parties.

However, we may disclose your personal information to service providers who assist us in providing our services, such as shipping, payment processing, marketing and advertising, email and text communications, applications, sales, business and inventory support, photography, website and software development, platform management, cloud services, data storage, and technical support.

Of the categories of PI noted above, during the past 12 months, we disclosed the following:

Categories of Personal Information Disclosed

Categories of Third Parties to Whom Disclosed

• Identifiers
• Other elements
• Characteristics of protected classifications under California or federal law
• Commercial information
• Education information
• Internet or other electronic network activity
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information
• Professional or employment-related information
• Consumer profile
• Sensitive Personal Information

We disclose your personal information to the following parties:

• Third parties directed by you: We will disclose your personal information to third parties as directed by you.
• Business partners: We may disclose your personal information to our business partners for collaborative purposes or event invitations. Each business partner should have their own privacy statement outlining their data collection, use, and disclosure practices.
• Service providers: We disclose information to service providers who perform services on our behalf, such as marketing companies, professional service providers, debt collectors, IT providers, and data storage companies. We may also authorize our service providers to collect personal information on our behalf.
• Governmental entities and legal service providers: We may disclose your personal information to comply with the law or in the course of providing our products and services. We may also disclose information in response to requests from government agencies or investigatory bodies.
• Successors to our business: If all or part of our business is sold, we may disclose personal information as part of the preparation or execution of that transaction.

Retention of Personal Information

Children

This website is not intended for or directed at children under the age of 13. Moreover, we do not knowingly collect personal information from children under the age of 13.

Do Not Track Notice

Our website does not currently support or respond to Do Not Track requests. Do Not Track is a browser preference that informs websites of your desire not to be tracked. You can enable or disable Do Not Track through your browser settings. For more information on opting out of interest-based advertising, you can visit http://www.networkadvertising.org/choices.

Links to Third-Party Websites

Certain parts of our website may contain links to external websites that are not under our control or maintenance. These links do not signify our endorsement of those websites, their content, or the individuals or entities associated with them. You acknowledge that these links are provided solely for your convenience, and we hold no responsibility for the content of such websites. Your use of these linked websites is subject to their respective terms of use and privacy policies.

Email and SMS Communication

We utilize third parties to enhance our ability to identify visitors to our website. As part of this service, we may provide identifiers, including visitors' IP addresses, cookies, and hashed email addresses captured during their visit, to these third parties. We and these third parties use this data to gain more insights about our visitors and engage with them through alternate channels such as email and direct mail. You have the right to opt-out of this activity. To opt-out, please follow the instructions provided in the SMS Communication section of our Terms page.

Social Media Sharing Features

Our website may offer social media sharing features and integrated tools that allow you to share your actions on this website with other platforms, and vice versa. These features may collect information about your IP address and the specific page you are visiting on our website. They may also utilize cookies or other tracking technologies. By using these features, you may share information with your friends or the public, depending on your settings with the third-party provider of the social sharing feature. These social media sharing features may be hosted by third parties or directly on our website. Your interactions with these features are governed by the privacy policies of the companies providing them. For more information about data collection and processing related to social media sharing features, please refer to the privacy policies of the respective third-party providers.

Notice to California Residents

Shine the Light

If you are a California resident, you have the right under California Civil Code Section 1798.83 to request information regarding the disclosure of your personal information by certain members of our company to third parties for their direct marketing purposes. You may make such requests once per calendar year. The information provided will include the categories of customer information and the names and addresses of businesses with which we shared customer information in the preceding calendar year (e.g., requests made in 2022 will cover sharing activities in 2021). To submit your request, please use the contact information provided at the end of this policy.

Eraser Law

If you are a California resident under the age of 18 and a registered user of any site where this policy is posted, you may request the removal of your personal information. Please note that such a request does not guarantee the complete or comprehensive removal of the content or information you have posted. There may be circumstances where the law does not require or allow removal, even if requested.

California Consumer Privacy Act (CCPA)

The following section applies to California residents ("consumers" or "you") as required by the California Consumer Privacy Act (CCPA). It describes our policies and practices regarding the collection, use, and disclosure of personal information collected about you, including information obtained when you access or use the website, visit our locations, communicate with us via phone or email, attend our events, engage in social media interactions, view our emails, or interact with our authorized service providers.

This section supplements and amends the information contained in the Privacy Policy specifically for California residents. Terms defined within the CCPA have the same meaning within this section. All other terms retain their meaning from the Privacy Policy or applicable Terms of Use, as appropriate. The remaining provisions of the Privacy Policy continue to apply, except where modified by this CCPA section.

This CCPA section does not apply to personal information collected from you as a job applicant, employee, owner, director, officer, or contractor of our company. It also does not apply to personal information collected from you as an employee, owner, director, officer, or contractor of another company, partnership, sole proprietorship, nonprofit organization, or government agency when your communications or transactions with us occur solely within the context of our business relationship with that entity.

Please carefully read this CCPA section before using the website or submitting information to us. By accessing or visiting the website, you indicate your understanding that the collection, use, and sharing of your information are subject to the terms outlined in this CCPA section.

If you do not consent to the collection, use, and disclosure of your personal information as described in this CCPA section, please refrain from providing us with such information.

Right to Know About Personal Information Collected, Disclosed, or Sold

In addition to the information provided above, as a California resident, you have the right to request more information about the following topics related to the preceding 12 months, to the extent applicable:

• Categories and specific pieces of personal information collected about you.
• Categories of sources from which we collected your personal information.
• Business or commercial purpose for collecting or, if applicable, selling your personal information.
• Categories of third parties with whom we shared your personal information.
• Categories of personal information shared for a business purpose with third parties. To request this information, please email us at info@zamenico.com or use our contact form. We will need to verify your request before processing it.

Right to Request Deletion of Personal Information

You have the right to request the deletion of personal information we collected or maintained about you. Upon receiving your request, we will inform you of the personal information that can be deleted from our records, and we will instruct any service providers or contractors who received your personal information to also delete it.

There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete it. Instances where retention is necessary include (1) completing a transaction or providing a requested good or service, (2) detecting security incidents and protecting against malicious or fraudulent activities, (3) debugging to identify and repair errors, (4) exercising free speech rights, (5) complying with legal obligations, and (6) using personal information for internal purposes consistent with your expectations and applicable laws.

To request the deletion of your personal information, please email us at info@zamenico.com or use our contact form. We will need to verify your request before processing it.

Right to Request Correction

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the information and its purpose for processing. Upon receiving a verifiable consumer request (see below), we will provide a response in accordance with the CCPA.

You have the right to direct us to limit the use of sensitive personal information we collect about you to activities that an average consumer would reasonably expect for the provision of goods and services, certain other permissible purposes under the CCPA, and as permitted by applicable law. This right only applies to sensitive personal information collected or processed for the purpose of inferring characteristics about you.

Right to Request Correction

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the information and its purpose for processing. Upon receiving a verifiable consumer request (see below), we will provide a response in accordance with the CCPA.

You have the right to direct us to limit the use of sensitive personal information we collect about you to activities that an average consumer would reasonably expect for the provision of goods and services, certain other permissible purposes under the CCPA, and as permitted by applicable law. This right only applies to sensitive personal information collected or processed for the purpose of inferring characteristics about you.

Non-Discrimination for Exercising Privacy Rights

We are committed to not discriminating against you for exercising your rights under the CCPA, as outlined above. This means that we will not engage in the following practices: (A) denying you goods or services; (B) charging different prices or rates for goods or services, including applying discounts or penalties; (C) providing a different level or quality of goods or services; or (D) suggesting that you will receive different prices, rates, or quality based on your exercise of privacy rights.

How to Submit

To submit a request for California Consumer Rights as described in this CA Addendum, please contact our company via email at info@zerocompany.com or by using our contact form. We reserve the right to respond only to verifiable consumer requests. A verifiable consumer request can be made by an individual who is:

• The consumer who is the subject of the request.
• A consumer acting on behalf of their minor child.
• A natural person or an entity registered with the California Secretary of State authorized to act on behalf of a consumer.

What to Provide

If requested, you must provide sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask for identifying information that we already have on record about you, or we may utilize a third-party verification service. We will make an effort to avoid requesting sensitive personal information to verify your identity. If we cannot verify your identity or authority to make the request and confirm the personal information relates to you, we may be unable to fulfill your request or provide you with personal information. However, making a verifiable consumer request does not necessitate creating an account with us.

Additionally, you should describe your request with enough detail to allow us to review, understand, assess, and respond accordingly. The personal information we collect from an individual through a verifiable request will not be used for any other purpose, except as required by law.

Our Response

We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a fee is applicable, we will provide an explanation for our decision and offer a cost estimate before proceeding with your request. We will make reasonable efforts to respond to verifiable consumer requests within forty-five (45) calendar days of receipt. However, in certain cases, we may require an additional extension of up to forty-five (45) calendar days and will notify you accordingly.

If you have an account with us, our written response will be delivered to that account. For those without an account, we will provide our written response either by mail or electronically, based on your preference. The disclosures we provide will pertain to the 12-month period preceding the receipt of your verifiable consumer request. For personal information collected on or after January 1, 2022, and as permitted by applicable regulations, you may request that the disclosures cover a period extending beyond the referenced 12 months, provided it does not require disproportionate effort on our part. The response we provide will also include explanations for any instances where we are unable to comply with a request. As permitted by the CCPA, we will not respond to more than two requests from an individual within any 12-month period.

Authorized Agent

You have the option to authorize a natural person or a business registered with the California Secretary of State to act on your behalf regarding the rights outlined in this CA Addendum. If you submit a Request to Know or a Request to Delete through an authorized agent without providing them with a qualifying power of attorney, you must provide written permission, signed by you, for the agent to act on your behalf. We reserve the right to deny requests from individuals or businesses claiming to be authorized agents if they do not provide sufficient proof of authorization.

Cookies

We employ the use of cookies on this website. Cookies are small text files that are transferred from a website or its service provider to your computer or other devices. They are commonly used to enhance website functionality and improve user experience. By allowing websites to read and write these text files, cookies enable websites to recognize you, retain your account login information between visits, and remember important information that enhances your convenience while using the website.