CULTURES CLOTHING COMPANY COMMITMENT TO PRIVACY

We are committed to protecting your privacy and the security of all data on the Shopping Area. To demonstrate this commitment, we have adopted this Privacy Policy. This Privacy Policy is based on the principles of notice/awareness, choice/consent, access/participation and integrity/security in the collection and use of all information regarding our Users and their activities on the Shopping Area. This Privacy Policy is incorporated by reference into, and forms a part of the Terms of Use of the Shopping Area and, therefore, should be read together with such Terms of Use.

 

I. NOTICE OF OUR PRIVACY POLICY This Privacy Policy notifies You of, among other things: (i) what information we gather from You, (ii) how we may use or disclose that information, (iii) with whom the information may be shared, (iv) what choices are available to You regarding collection, use and distribution of the information, (v) our efforts to protect the information, and (vi) how You can correct any inaccuracies in the information You provide to us.

 

II. WHAT TYPES OF INFORMATION ARE COLLECTED AND WHY

• a. Information submitted by You At times, we may ask You to provide information about yourself in order to better serve You. For example, some of the information collected may include name, title, address, phone number, email address, birthdate, and personal information concerning your interests, occupation, gender and other demographic information. If You use a credit card on the Shopping Area, we will also collect your credit card account number, expiration date, and related information.

• b. Information collected by Cookies , through Google Analytics or another approved analytics provider, also makes use of website "cookies" to help You use our services more easily and to help us continuously improve our Shopping Area and our service to You. A "cookie" is a small data file that a website can send to your browser, which may then be stored on your computer to help our Shopping Area "remember" information about You to make it easier and more efficient to use our Shopping Area. Our Shopping Area employs session cookies. A session cookie does not remain on your computer after You close your web browser window. Our session cookies contain none of your personal identifying information and cannot be used to track You around the Internet. Our session cookies can only be used by the Shopping Area and they only exist for the duration of your visit. Depending on the settings in your browser, You may have the option to deny the session cookie; however, doing so may negatively impact upon the performance of the Shopping Area or restrict us in better serving your needs and interests. The "help" portion of the toolbar on most browsers will tell You how to prevent your browser from accepting new cookies, how to have the browser notify You when You receive a new cookie, or how to disable cookies altogether.

• c. Web Analytics/Use of Web Beacons or GIF files , through Google Analytics or another approved analytics provider, performs analysis on many aspects of the Shopping Area including, but not limited to, tracking traffic, click-through, visitor paths, page views or page impressions (which are requests to load a single webpage of a given Internet site) and the number of pages visited on the Shopping Area, among other things. Such analytics methods may utilize electronic images known as Web beacons - small strings of code that are placed in a webpage which are sometimes also called single-pixel gifs - to count Users who have visited certain pages.

• d. Policy on Information from Persons under the Age of 18 We do not seek to collect personally identifiable information from persons under the age of 18. If You are under the age of 18, please do not submit any personally identifiable information to us. If You are the parent or guardian of a child under the age of 18 who has submitted such information and become aware of such unauthorized submission, please inform us by contacting us at the email address or telephone number listed above and we will remove such information from our database. If You are concerned about such children's use of the Shopping Area, You may use web filtering technology to supervise or limit access to the Shopping Area. No person under 13 years of age may use the Shopping Area. We also do not send email correspondence to anyone who tells us that they are under the age of 13 without their parent's consent. Our online sweepstakes or promotion are restricted to entrants who are at least 18 years old. The parent or guardian of a child between the ages of 13 and 18 is financially and legally responsible for the child's actions on the Shopping Area.

• e. Your California Privacy Rights Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personally identifiable information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Cultures Clothing Company 6370 Overbrook Avenue Philadelphia, PA 19151 Attention: Alloyius McIlwaine Please allow 30 days for a response.

 

III. HOW IS MY INFORMATION USED?

• a. User Identification We may retain this information on a secure server so that on re-visiting our Shopping Area, You will not need to re-enter that information. We may use this information in an aggregated form to measure number of visits, average time spent on the Shopping Area, pages viewed, and other relevant statistics. We collect this information to measure the use of our Shopping Area and to improve the content or operation of our Shopping Area.

• b. Contacting You Concerning Promotions and New Products We may request You to "opt-in" to receive certain communications from the Shopping Area, us and/or Cultures Clothing Company. We will not send unsolicited messages to You concerning promotions or new products or other marketing material unless You have opted-in. If, after You have opted-in, You no longer wish to receive such communications from us and/or Cultures Clothing Company, please follow the procedures set forth below in the section titled "How Can I "Opt-out" of Receiving e-mail Communications." Please note that your request to stop receiving these communications may not prevent us from sending such messages that were generated prior to the time we were able to process your request.

• c. Use of Your Information At times, we may request You to provide personal information to identify You as a User of the Shopping Area and to assist and speed the completion of transactions on the Shopping Area. Since we are acting on behalf of Cultures Clothing Company, we share and forward all such personally identifiable information to Cultures Clothing Company, which owns the intellectual property rights to such current and prospective information. We may also use information collected about your preferences and activities at the Shopping Area, such as the particular pages You request at the Shopping Area and purchases or other transactions You effect through the Shopping Area. We may vary the content You receive in future visits to the Shopping Area based on your preferences and activities.

• d. Disclosure of Your Information We will not disclose your personally identifiable information to any persons or entities outside of or Cultures Clothing Company and selected third party service providers (and only as necessary for such third party service provider to perform such services). Selected third party service providers include subcontractors that provide credit card processing on our Shopping Area, providers that host or help support the Shopping Area or otherwise provide technical assistance. If You do not want your personally identifiable information used as otherwise detailed in this Privacy Policy, then You must not use the Shopping Area. Neither we, nor Cultures Clothing Company will lease, license, sublicense, rent, transfer, disclose, disseminate or otherwise grant access to such information unless:

o (i) You have been given an opportunity to "opt-in" and have agreed to so opt-in to such disclosure of your information;

o (ii) Cultures Clothing Company must share your information in order to provide a product or service that You have ordered or requested, in which case we will require that any third person or entity we use to fulfill your order agrees that it does not have the right to use your information other than to fulfill your order or request; or

o (iii) Cultures Clothing Company are required to respond to subpoena, court orders or other requirement of law which requires disclosure of your information.

• e. Disclosure of Aggregate Information We may combine your personally identifiable information and information about your preferences and activities, with those of all or a particular group of our Users to prepare collective profiles of our Users and their activities for our and/or Cultures Clothing Company's internal use. For example, we may track the number of our Users who view certain pages or use certain features or compile the total dollar amount of sales conducted through the Shopping Area in a particular geographic region or to track purchasing trends. Such information, and other information we derive from individual Users' information, allows us to continue to grow and provide You with quality information through more accurate marketing and advertising with respect to the Shopping Area. We may share aggregated information concerning our Users, without attribution of personally identifiable information, to other companies with whom we conduct business.

• f. How Can I "Opt-out" of Receiving E-mail Communications? Cultures Clothing Company and seek to comply with the CAN-SPAM Act of 2003 (Controlling the Assault of Non-Solicited Pornography and Marketing Act) in any and all promotional emails, online promotions, or similar campaigns that Cultures Clothing Company and/or may undertake. You are permitted to opt-out of receiving certain communications from the Shopping Area. Neither we nor Cultures Clothing Company will send unsolicited messages to You if You indicate that You do not wish to receive such messages. If You do not wish to receive unsolicited email messages, please access the "My Account" section of the Shopping Area and adjust your mailing preferences from the "yes" to the "no" option. Please allow us 10 business days from when the request was received to complete the unsubscribe request.

• IV. WHAT WE DO TO KEEP THE SHOPPING AREA SECURE a. Security We employ procedural and technical safeguards to secure your personally identifiable information against loss, theft, alteration, and unauthorized access, use and disclosure. Any information You enter on our accounts setup page within the Shopping Area is encrypted before transmission to our server by using 128-bit Secure Sockets Layer encryption software. You can safely enter your credit card and personal registration information and it cannot be read in transit to our server. We also employ many security procedures to protect your information from unauthorized access by Users inside and outside . Please note that e-mail (as opposed to account information) is not encrypted, so e-mail is not considered to be a secure means of transmitting credit card information. Regardless of the precautions taken by us, we cannot ensure or warrant the security of any information You transmit to us, and You transmit such information at your own risk. What You Can Do To Protect Your Information?

o (i) Use only secure websites when disclosing your information. Secure pages begin with "https".

o (ii) Avoid using easy to figure out access and personal ID (PIN) codes. o (iii) Never respond to unsolicited requests for your social security number or financial information.

o (iv) Do not disclose your passwords to the Shopping Area or your account information to any other person.

o (v) Be sure to log off and close the browser when finished using a shared computer.

• b. Hypertext Links The Shopping Area only contains hyperlinks or "links" to websites owned and operated by Cultures Clothing Company, Cultures Clothing Company's approved licensees, or our approved advertisers, and we cannot and are not responsible for maintaining your privacy once You leave our Shopping Area. If You provide any information to parties who operate websites that are linked to or from this Shopping Area, different rules may apply to their collection, use or disclosure of your personally identifiable information. We encourage You to review other websites' or advertisers' policies before revealing any sensitive or personal information. Under no circumstances shall and/or Cultures Clothing Company have any liability whatsoever for the activities conducted by or at any website accessed from or through the Shopping Area.