Privacy Policy

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

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

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

Privacy Policy

PART I: GENERAL

A. WHAT OUR PRIVACY POLICY COVERS

B. PERSONAL INFORMATION WE COLLECT FROM OR ABOUT YOU

C. HOW WE COLLECT YOUR PERSONAL INFORMATION

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

E. HOW WE DISCLOSE YOUR INFORMATION

F. HOW WE PROTECT YOUR PERSONAL INFORMATION

G. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

H. LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES

I. YOUR CHOICES

J. CHILDREN’S ONLINE PRIVACY

K. TRANSMISSION OF INFORMATION TO OTHER COUNTRIES

L. CHANGES TO THIS PRIVACY POLICY

M. CONTACT US

PART II: SUPPLEMENTAL INFORMATION FOR RESIDENTS OF SPECIFIC US STATES

NEVADA

CALIFORNIA

OTHER STATES

PART III: SUPPLEMENTAL INFORMATION FOR RESIDENTS OUTSIDE THE USA

Legal Basis for Processing

Transmission of Information Outside the EEA

Data Subject Rights (General)

Data Subject Rights (Under GDPR)

Exercise of Your Rights

PART IV: SUPPLEMENTAL INFORMATION FOR RESIDENTS OF AUSTRALIA

PART V: SUPPLEMENTAL INFORMATION FOR RESIDENTS OF NEW ZEALAND

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