PRIVACY POLICY

We at Shop Olive, LLC (with our affiliates and subsidiaries, "Shop Olive", "we", “our” or "us") take your privacy seriously.  This policy explains our collection and use of information on and through our websites, products, services, apps and applications (the "Services"), and the related choices you have.  By using or accessing the Services, you hereby consent to our collection, use and sharing of your information as described herein.

Your use of the Services is at all times subject to the Shop Olive Terms of Use, which incorporate this Privacy Policy.  Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

We may update this Privacy Policy from time to time.  We may notify you of material changes by posting a notice on our website, sending you an email, and/or by some other means.  You should consult this Privacy Policy regularly for changes.  If you use the Services after changes have been posted, then the revised Privacy Policy applies.

A. TYPES OF INFORMATION COLLECTED

We and the Services collect different types of information through the Services.

1. GENERAL INFORMATION

Personal information is information about you that can be used by itself, or combined with other information, to personally identify you ("Personal Information").  We collect this information directly from you when you provide it to us and by any and various means.  For example, when you make a purchase on our website, you provide us with your name, email, phone number, address and billing information, etc.  When you register to receive Shop Olive news, we collect your name, age and email address, etc.  

2. SPECIFIC TO THE SERVICES

When you sign up for a Shop Olive account (an "Account"), we may collect information including but not limited to your name, email address, birthdate, password, address, and billing information (collectively, "Account Information").  

We use Account Information to create, manage and maintain Accounts and provide the Services and Shop Olive products. For example, for purchases on our website, we collect address and billing information to facilitate your current or future purchases.

3. AUTOMATICALLY AS YOU NAVIGATE: LOG FILES, COOKIES, AND OTHER TECHNOLOGIES

When you use or visit the Services, the Services automatically record and store certain information in log files.  Generally, we use this information in an aggregated and anonymized way.  If we need to combine this type of information with Personal Information, we treat it as Personal Information. Automatically collected information includes statistical or technical information such as your Internet Protocol address, operating system, time and date, and how you navigate the Services.

On our websites, we may – depending on your cookie preferences – also collect information through the use of "Cookies" or similar tracking technologies, which are identifiers transferred to your browser. We use first and third party Cookies to help our websites work, provide you with relevant content and to improve our Services. 

Shop Olive uses Cookies and similar tracking technologies to track the activity on our Services and certain information may be held or stored.  Cookies are files with a small amount of data which may include an anonymous unique identifier.  Cookies are sent to your browser from a website and stored on your device.  Other tracking technologies also may be used such as beacons, tags and scripts to collect and track information and to improve and analyze the Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

We also may work with third parties to manage our advertising on other websites. Our third party advertising partners may use cookies or similar technologies on our and other sites to provide you advertising based upon your browsing activities and interests, or to display ads that link back to our site. If you wish to opt out of interest-based or retargeted advertising click here, or if you are in the European Union click here.

4. EMAIL, SURVEYS, AND YOUR CHOICES

If you have provided us with your contact information, we will use this information to communicate with you about your order or Account or address your questions.  If you have, or, for a child under the age of 13 (or up to 16, depending on the country), his or her parent/legal guardian has, given us consent by providing us your contact information, we may, subject to your marketing preferences, send you education, marketing, product support, and research emails.  Our third-party mail service provider provides us with anonymized and aggregated information about the respondents to our emails.  You can unsubscribe from our marketing and research emails anytime by following the instructions included in them.  We track open rates for our emails so we can improve our communications with you and our services.  If you participate in our optional surveys, information you provide to us, including Personal Information, will be linked with your Account.  We will not share the Personal Information you provide through a contest or survey with third parties unless we give you prior notice and choice. Some of our Services include links to third party websites or apps.  We are not responsible for such websites. These sites may have their own privacy policies and practices.

5. SOCIAL MEDIA & CONTESTS

We have or may have a presence on various social media platforms, such as Facebook and Instagram. We receive anonymized and aggregated demographic and use information from these services when you engage with us on them. In addition, we may offer sharing features and other integrated tools (such as the Facebook "Like" button). Such integrated features may share data and are governed by the privacy policies of the third parties that provide these features. From time to time, we may conduct contests and sweepstakes. If you participate, we may collect information from you, as described in the terms of the contest or sweepstakes.

6. SHOPIFY

Shop Olive uses Shopify to process transactions on its website and through its Services.  Shopify may have a Privacy Policy that differs from Shop Olive.  You should review Shopify’s Privacy Policy in addition to this Privacy Policy.

B. HOW WE USE THIS INFORMATION

We use information that we collect about you or that you provide to us, including any Personal Information, as described throughout this Privacy Policy, including to:

• Provide and deliver products and services you request;

• Operate, maintain, and improve the Services;

• Allow you to participate in interactive features;

• Personalize and customize your experience, content, marketing, and recommendations;

• Respond to requests that you make and provide you with customer service, informative announcements, and promotional information about us or our products;

• Assist those who help us in designing, analyzing, and operating the Services;

• Carry out our obligations and enforce our rights, and protect against fraud, unauthorized or illegal activity, or policy or billing violations;

• Notify you about changes to the Services;

• In any other way we may describe when you provide the information, with your consent or the consent of a parent or legal guardian; and

• Fulfill any other purpose for which you provide it.

C. SHARING YOUR INFORMATION

We may share your Personal Information as follows:

• With third parties that support our business, such as to process payments, provide accounting, or store and/or process information, and who are bound to keep Personal Information confidential and adequately protected and use it only for the purposes for which we disclose it to them.

• With our affiliates or subsidiaries, provided the data is adequately protected.  Also, if we are acquired, dissolve, or go through a change of control, Personal Information could be one of the assets transferred, subject to your consent, where required by law.

• To fulfill the purpose for which you provide it (for example, when you want to share something to social media, to post it to a third party account on your behalf), for any other purpose disclosed by us when you provide the information, or otherwise with your consent or, in case of a child, the consent of a parent or legal guardian.

• To comply with relevant laws, regulations, lawful requests by public authorities, including to meet national security or law enforcement requirements, court orders, and legal process; protect and defend the rights or property of us or third parties and investigate and prevent fraud; and in an emergency, including to protect safety.

We also may freely disclose Aggregate Data to third parties for research and development, product development and improvements, and other related business purposes.

D. TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES FROM THE EU

The Services are hosted and operated in the United States.

Shop Olive participates in and has certified its compliance with the EU-US Privacy Shield Framework.  Shop Olive, Inc is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List [https://www.privacyshield.gov/list].

Shop Olive is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf or as third party recipient.  Shop Olive, Inc. complies with the Privacy Shield Principles and – to the extent applicable – the EU data protection principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions, by either choosing third party recipients that are Privacy Shield certified, EU Standard Contractual Clauses or other EU approved data transfer mechanisms.  If you wish to receive details on the transfer mechanisms chosen, please contact the Shop Olive Privacy Policy Administrator at the address indicated.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Shop Olive is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Shop Olive may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us according to the contact provisions herein.  Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

E. ACCESSING YOUR INFORMATION; YOUR RIGHTS; OPT-OUT RIGHTS

Upon request, we will provide you with information about whether we hold any of your Personal Information. You can contact us at  info@shopolive.co or through the contact information provided below to modify, request a copy of, or request deletion of this Personal Information or your Account. You have the additional following rights under EU Data Protection rules with regard to your Personal Information:  Rectification of inaccurate Personal Information, objection to the processing of Personal Information, restriction of processing of Personal Information, and portability of Personal Information.  If you think your rights have been violated, you also have the right to lodge a complaint with your national EU Data Protection Authority.  You can learn more about these rights at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

We will use commercially reasonable efforts to respond to your request within 30 days unless such request is unreasonable under or would violate applicable law.  If you request to delete Personal Information, you may no longer be able to use some features.

We will retain information for as long as your Account is active or as necessary to provide you services.  We may also be required to keep some of your Personal Information for legal reasons, for instance to comply with statutory retention periods or for tax purposes. In addition, we will continue to retain and use Aggregate Data.

OPT-OUT RIGHTS. We offer certain choices about how we communicate with you and what information we obtain.

• You may opt-out of receiving emails at any time by clicking "unsubscribe."

• If you are a user in the EU, you can opt-out from the collection of Analytics Data by visiting the settings section of your app.

• You can delete cookies on your browser by following the instructions in our Cookie Policy. Some third parties we work with may provide additional specific opt-out mechanisms. For more information, visit our Cookie Policy.

If you are California or Nevada resident please see Sec. G below for your California and Nevada Privacy Rights.

F. SECURITY

We take reasonable precautions to protect your data. Payment transactions are encrypted in transit. Although we endeavor to provide reasonable security, no system can prevent all potential breaches or guarantee perfect security. Please contact us immediately at  info@shopolive.co if you suspect a vulnerability in our systems, products, or services.

G. YOUR CALIFORNIA AND NEVADA PRIVACY RIGHTS

The information and terms in this California and Nevada Users section supplements the information and terms contained in the rest of this Privacy Policy and applies to you if you reside in the United States. We adopt these terms to comply with the California Consumer Privacy Act of 2018 and Nevada Senate Bill 220 (an Act relating to Internet privacy) and other California and other state privacy laws (all such laws are collectively referred to for purposes of this Privacy Policy as the “CCPA”).  Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.  

Residents of the State of California may request a list of all third parties to which we, though the Services, have disclosed certain information during the preceding year for the third parties' direct marketing purposes. If you are a California resident and want such a list, please contact us at info@shopolive.co or by calling the following phone number 724-263-1175.  For all requests, you must put the statement "Your California Privacy Rights" in the subject line and body of your request, as well as your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information. 

"Do Not Track" Signals under the California Online Protection Act (CalOPPA):  The Company does not support Do Not Track ("DNT").  Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.  You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

In additional to the Information defined in other sections of this Privacy Policy, we may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (also included within “Personal Information”). In particular, we have collected or may collect the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples (Including, but not limited to) or (non- exhaustive list)	Collected (YES or NO)
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin (including language use and possession of a driver’s license issued to persons unable to provide their presence in the United States as authorized under federal law), citizenship, religion or creed (including religious dress and grooming practices), marital status, medical condition (including cancer or a record or history of cancer), AIDS/HIV, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy, childbirth, breastfeeding and related medical conditions), sexual orientation, veteran or military status, Political affiliations or activities, status as a victim of domestic violence, assault, or stalking, genetic information (including familial genetic information), request for family care leave, request for leave for an employee’s own serious health condition, request for Pregnancy Disability Leave, retaliation for reporting patient abuse in tax-supported institutions.	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	NO
F. Internet or similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from personal information	Profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes	YES

Personal Information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In additional to the statements made in other sections of this Privacy Policy, we obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you when you submit any forms with, for or on our Services.
• Directly and indirectly from your interaction with our Services.  For example, from submissions through our Services website portal or website usage details (including without limitation IP address, device ID, geolocation data collected automatically).
• Directly from you.  For example, from documents that you provide to us related to the services for which you engage us or from audience segments used for targeted advertising.
• Indirectly from you.  For example, through information we collect from you in the course of providing services to you.
• From data aggregators and similar vendors.
• From third-parties that interact with us in connection with the Services we provide.  For example, from demand-side platforms, data management platforms, ad targeting vendors, and/or attribution partners.  For example, we may ingest audience data from third-party data providers to power targeted ad serving. We may also receive aggregated vehicle sales records for analytics and other purposes.
• From anti-fraud and other crime prevention partners.

In additional to the uses identified in other sections of this Policy, we may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the Personal Information is provided. For example, if you provide us with Personal Information in order for us to provide Services, we will use that information and submit as indicated.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our Services including the powering of products and features used throughout the site.
• To power and maintain saved user accounts.
• For attribution purposes.
• To send promotional materials.
• To provide custom and/or individually-tailored website experiences.
• For ad serving, targeting and retargeting, creation of audience segments, and related OBA (online behavioral advertising) purposes.
• To create inferred search preferences and inclination/intent to purchase certain vehicles or makes/models for improved ad targeting and custom experience implantation.
• For internal operations and Services optimization including product development.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our users or others.
• To enable anti-fraud and crime prevention efforts.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Where information is provided in connection with employment or employment applications, Information may be used in the normal course of employment and the application process.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
• To verify the accuracy of the Personal Information through a third-party vendor or entity.
• We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

Beyond the previously-enumerated reasons for disclosure of your Personal Information to third parties, we may disclose your Personal Information to a third party for other business purposes.  When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we may or have disclosed the following categories of Personal Information for business purposes more fully discussed throughout this Policy and as described below:

• Identifiers — we collect names and other identifiers when consumers open accounts or use our Services.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) — we collect names and other identifiers when consumers open accounts or use our Services.
• Protected classification characteristics under California or federal law — we may collect certain characteristics when purchasing products or services or using our Services (e.g. veteran discount).
• Commercial information — we collect this information for attribution purposes.
• Internet or similar network activity — we collect behavioral information to create custom experiences and targeted messaging.
• Geolocation data — we collect Geolocation data to create custom experiences and targeted messaging as well as for the performance of Services.
• Inferences drawn from Personal Information — we collect inference information to create custom experiences and targeted messaging.

We may disclose your Personal Information for a business purpose to the following categories of third parties:

• Our subsidiaries, parent(s) and affiliates.
• Service providers (including without limitation ad targeting/retargeting vendors, attribution vendors, and HR and other internal operations platform providers).
• Clients and customers.
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you.

The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights:  You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: 

• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights:  You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech and/or ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

By email at:  info@shopolive.co 

By mail at:

Only you (or a person registered with the Secretary of State of your state of residence that you authorize to act on your behalf) may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  The verifiable consumer request must:  (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Personal Information Sales Opt-Out and Opt-In Rights:  If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out").  We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.  Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us as follows:

By email at:  info@shopolive.co 

By mail at:

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.  However, you may change your mind and opt back into Personal Information sales at any time by contacting us as provided above.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Response Timing and Format:  We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we reserve the right to deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option (if no preference is indicated we reserve the right to contact you at our discretion).  Any disclosures we provide will only cover the 12-month period preceding the receipt date of the verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination:  We will not discriminate against you for exercising any of your CCPA 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.

H.  LINKS TO OTHER SITES

Our Services may contain links to other sites that are not operated by Shop Olive.  If you click a third-party link, you will be directed to that third-party's site.  You are strongly advised to review the Privacy Policy of every site you visit.  Shop Olive has no control over and assumes no responsibility for the content, terms and conditions, privacy policies or practices of any third-party sites or services.

I.  HOW TO CONTACT US

By email at:  info@shopolive.co 

By mail at: