Version November 15th, 2021

This privacy policy (the “Privacy Policy”) regulates how Lechia Inc (“Lechia”) shall treat the personal information and data of users who visit websites controlled by Lechia where this Privacy Policy are posted (collectively, the “Sites”) or other interactive features or downloads owned or controlled by Lechia and available through the Sites, or which interact with the Sites.

Lechia is the controller of the information and personal data of users collected through the Sites. This Privacy Policy is designed to provide information about our online privacy and data collection practices, such as the type of information we collect regarding visitors to the Sites. This Privacy Policy does not cover any information collected on any other website (unless specifically stated on such website). This Privacy Policy does not apply to websites operated or managed by Related Parties.

Please review this Privacy Policy carefully. If you have questions or concerns regarding this Privacy Policy, please contact hello@lechia.co, or send a letter to Lechia Inc. In addition, please review the Terms of Use, which govern your use of the Sites.

By clicking on the appropriate box on the registration page of this Privacy Policy, you accept these terms and agree to be bound by this instrument

Definitions. For the purpose of this Privacy Policy, the following terms shall have the meaning set forth in this section.

“Personal Information”: Any information relating to an identified or identifiable natural person or entity (depending on the jurisdiction from which you access the Sites), such as personal name, mailing address, email address and telephone number; birth date; gender; identity number; company name, mailing address, e-mail address and telephone number; and job position.

“Database”: Any organized set of Personal Information which is subject to Information Processing (as defined below), by electronic means or otherwise, whatever the mode of collection, storage, organization or access.

“Information Processing”: Any operation and systematic process, electronic or otherwise, enabling the collection, recording, organization, storage, alteration, linkage, assessment, blocking, erasure, dissociation and in general Personal Information Processing, as well as its assignment to third parties through transmission, searches, interconnections or transfers.

“Data Controller” or “Controller of a file, registry, database or databank”: The natural person or entity, public or private, who is the owner of a file, registry, Database or databank, or who has the authority to decide how and why Personal Information will be processed.

“Information Dissociation”: Any processing of Personal Information so that the information obtained cannot be associated with any identified or identifiable person.

“Related Party”: means any affiliates, entities which control Lechia and/or subsidiaries of Lechia.

“Promotion”: means any sweepstakes, contests, and other promotions offered through the Sites that may require registration.

“Service Providers”: means any sweepstakes, contests, and other promotions offered through the Sites that may require registration.

“Advertisers”: means any third-party advertiser.

“Third Party Websites”: means other websites or locations that are operated and controlled by third parties other than Lechia or its Related Parties.

Use of Personal Information. Lechia may use your Personal Information, whether collected actively or passively: (1) to provide you with information or services, or process transactions that you have requested or agreed to receive; (2) to process your registration with the Sites, including verifying that your e-mail address is active and valid; (3) to improve the Sites or our services, to customize your experience on the Sites, or with your consent to serve you specific content that is relevant to you; (4) to contact you with regard to your use of the Sites and, in our discretion, changes to our policies; (5) for internal business purposes; and (6) for purposes disclosed at the time you provide your Personal Information. In addition, as a secondary purpose, with your consent, Lechia may use your Personal Information for direct or indirect marketing of Lechia’s products to you.

Active Collection of Personal Information. In general, you can visit the Sites without revealing your identity or giving us any information about yourself. However, in order to access or take advantage of some areas of the Sites, we may ask you to provide Personal Information. Upon such request, Lechia shall also ask for your express consent to actively collect Personal Information from you. If you consent such action, the continuous use of the Sites shall be understood as an affirmation of your consent on further requests for Personal Information. We may obtain demographic or similar information from Service Providers and, with your consent, may combine that information with the Personal Information we collect and track in order to create a profile on an individual so that we may provide you with personalized services and interactive communication, advise you about new products that may be of interest to you, and for internal market research and product development purposes. We treat all such information as Personal Information subject to this Privacy Policy.

Personal Information may be requested and collected at various locations and on various forms on the Sites.

You may always elect not to submit Personal Information, however, as a result, you may not be able to access certain of the Sites’ features and functionality. You are responsible for maintaining the accuracy of the information you submit to us.

Passive Collection of Information. In addition to the Personal Information that you actively provide to us, we or our Service Providers may use a variety of technologies to automatically collect information when you use the Sites and when you use certain third party sites (see “Network Advertising and Retargeting,” below). This information may include demographic information, browser type, operating system, IP address, mobile device identifiers and other information of this kind. This information may also include clickstream data, which is information about the page-by-page paths you take as you browse through the Sites and certain third-party sites. Some third parties may also collect similar information when you visit the Sites or other online websites and services.

The methods that we and our Service Providers may use to automatically collect such information include the following:

• Cookies: Cookies are data files that are placed on a computer when it is used to visit a website. These cookies may be used for many purposes, including, without limitation, tracking user preferences and web pages visited while using the Sites and certain third-party sites for marketing and other purposes. These Service Providers use cookies or web beacons to help us deliver Site content, compile Site metrics and analytics, and help us improve and customize your experiences on the Sites and in our advertising efforts. A list of these companies is available on request. You may disable cookies using your browser’s preferences. However, some features of the Sites may not function properly or may operate slowly if you disable the cookies. Please also be aware that disabling cookies will remove all cookies from your system including those you may find useful such as passwords and usernames you have saved on frequently visited websites.
• Web Beacons and Pixels: We may include small graphic images called web beacons, also known as “Internet tags” or “clear gifs,” or pixels in our web pages and e-mail messages. We may use web beacons, pixels or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to the Sites, to monitor how users navigate the Sites, to count how many e-mails that we sent were actually opened or to count how many particular articles or links were actually viewed, and for third party marketing as described below in “Network Advertising and Retargeting.”
• Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Sites. It is temporarily downloaded onto your computer from our web server or a third party we work with, is active only while you are connected to the Sites and is deleted or deactivated thereafter.
  
  

Passively collected information about you, may be combined or associated with your Personal Information. In addition, we may send you product promotions that we think you may be interested in receiving based on the passively collected information. If we associate any such passively collected information with Personal Information about you, we will treat the combined information as Personal Information. In each of these instances, we will apply this Privacy Policy to any information received, unless otherwise specifically disclosed by us.

Network Advertising and Retargeting. Lechia participates in online advertising networks and exchanges that display relevant advertisements to site visitors based on their interests as reflected in their browsing of the Sites and certain third-party sites participating in the same networks and exchanges. These companies use cookies, web beacons, pixels and other similar technologies to passively collect information from you which may be used to tailor the advertising you see on the Site or elsewhere on the web. This means that some information about your browsing of the Service and certain third party sites may be shared with these companies for the purpose of delivering ads to you on the Service and certain third party sites, and Lechia may receive from some of these companies information about third party sites that you have visited. This information is used for marketing purposes and the practice is sometimes termed “retargeting” to indicate that information from one retailer is used to suggest to you relevant products offered by another retailer.

This Privacy Policy does not cover any use of information that such third parties themselves may have collected from you (e.g., type of browser, operating system, domain name, day and time of visit, page(s) visited) or the methods used by the third parties to collect that information (e.g., cookies, web beacons and clear gifs). We make no representations or warranties regarding the policies or business practices of such third-party advertisers and we encourage you to familiarize yourself with their privacy policies. You can also learn more about opting out of network advertising retargeting below under “Opting Out of Network Advertising Retargeting. The Sites do not respond to “do not track” signals.

Information from Third Parties. We may, from time to time, obtain supplemental information about you from third party sources or from our marketing partners in connection with co-branded websites or promotions and from network advertising services (see above). If we receive Personal Information from a third-party source and/or we combine the information we receive from these third-party sources with your Personal Information, we will treat that information and the combined information as Personal Information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect and use such information.

Sweepstakes, Contests and Promotions. We may offer Promotions. By participating in a Promotion, you are agreeing to the terms, conditions or official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

Disclosure of Information. Except as otherwise provided herein, Lechia does not share, rent, or sell any Personal Information it collects to any third party for marketing or solicitations purposes. We may, however, in our sole discretion, share browsing information with third parties such as advertisers and business partners, always subject to the anonymity of personal data. For example, we may communicate the age segmentation of visitors to our Sites.

Your Rights.

Right to Access, Rectify, Erase and Object to Information Processing of Personal Information. You can exercise your rights to (i) access the Personal Information we have about you as well as about the Information Processing done with your Personal Information, (ii), rectify the Personal Information in the event that it is incomplete or inaccurate, (iii) erase the Personal Information that its being used for one of the intended uses stated in this Privacy Policy and (iv) object to the Information Processing of your Personal Information at any time by sending a letter to Lechia’s address mentioned below or writing to hello@lechia.co.

In order to properly attend your request, please attach your name, surname, postal address, telephone, e-mail address and any other contact details that we can use to verify your identity and contact you, a copy of you ID card or a photo-ID and a clear and precise description of the Personal Information which you wish to access, rectify, erase, limit the use or disclosure of, or object to the Information Processing of, as well as any other information useful to locate the Personal Information. All our communications with you will be delivered with the highest available reserve and confidentiality levels. The claim shall be subject to the applicable data protection regulation regarding time periods and other requirements.

Revocation of Consent and limitation of use and disclosure. At any time, you may revoke the consent given to Lechia over your Personal Information by contacting the data protection team at the e-mail address stated above. After that, we shall eliminate all Personal Information stored in our databases. However, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. You may also limit the use or disclosure of your personal information by reaching the data protection team at the e-mail address stated above, indicating your desire to withdraw or limit your information. An answer will be provided to you according to the mechanism and timeframe required by applicable law.

Opting Out of Mailing Lists. You can always ask us to delete your name from our lists of correspondence. In the event that you want to delete your name from a mailing list, or if you wish to update your information (e.g., change your address), you can do so at any time by notifying Lechia by letter to the address listed below or by sending an email to the address mentioned above.

Opting Out Of Receiving Commercial E-mail Correspondence from Lechia. If you do not wish to receive e-mail notices regarding our products or services, you may opt-out at the time you provide your Personal Information to us. Otherwise, at any other time you may opt-out by any commercial e-mail you receive from Lechia by selecting the “unsubscribe” or similar option included with each e-mail.

Opting Out of Network Advertising Retargeting. If you do not wish to receive retargeted advertising from Lechia based on your activity on third party sites, you may disable cookies as described above in the cookies section and clear your browser history.

Children’s Privacy Protection. The access to and use of the Sites by minors, in accordance with current legislation, is the responsibility of their respective parents, legal guardians or representatives. Likewise, Lechia acknowledges that those of legal age who, in accordance with the legislation in force, are parents, legal guardians or representatives, shall be responsible in the event that minors under their guardianship access the Sites, and therefore, they are strongly recommended to take the appropriate precautions while browsing the Sites.

Third Party Links. There may be hyperlinks on the Sites to Third Party Websites (including but not limited to social media sites and applications). These Third-Party Websites may use their own cookies, web beacons and other technology to independently collect information about you. In addition, these Third-Party Websites may solicit Personal Information from you. The Third-Party Websites have separate privacy and data collection practices. Once you leave this site, Lechia has no control or liability of any kind on privacy standards or on the activities of collecting data on other sites. We make no representations regarding the policies or business practices of such Third-Party Websites and encourage you to familiarize yourself with their privacy policies before providing them with your Personal Information.

Storage and Transfer of Information. The Sites are operated in the United States of America. Please be aware that information we collect, including Personal Information, will be processed and stored in the Relevant Jurisdiction and may also be transferred to, processed and stored in other jurisdictions, where the privacy and data protection laws may differ from those of the United States of America. Accordingly, courts and other authorities in the Relevant Jurisdiction and in such other jurisdictions may, in certain circumstances, be entitled to access your Personal Information. By using the Sites or providing us with any information through the Sites, you consent to this transfer, processing and storage of your information in the Relevant Jurisdiction and in such other jurisdictions, included for the treatment of personal data. Regardless of where the processing takes place, Lechia’s Service Providers are required by contract to protect the confidentiality and security of your Personal Information.

Security. Lechia retains your Personal Information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. Lechia takes commercially reasonable steps to help protect and secure Personal Information. However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect, and you use our Sites and provide us with your information at your own risk.

Changes to this Policy. Lechia may from time to time revise its Privacy Policy. You will be advised if required by local law of any changes and will be effective immediately when revised policy is posted on the Sites. Please check the Sites regularly for any changes. We will not, however, use your existing Personal Information in a manner materially different from that set forth in the policy posted on the Sites at the time your Personal Information was collected unless we receive your consent.

Contacting us. If you have any questions about our Privacy Policy, the practices of the Site, or your dealings with the Site, wish to request access or correction or updated of your Personal Information, wish to withdraw your consent (subject to legal or contractual restrictions and reasonable notice) or have reason to believe that Lechia may have failed to comply with this Privacy Policy, please write to hello@lechia.co.