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Privacy Policy

Welcome! This Privacy Policy is intended to explain what types of information we at ELOQUII Design, Inc. ("ELOQUII") collect about you, and how we use and share that information. One section of this privacy policy also addresses what happens with information we collect on our pages on social media sites, such as Facebook, Twitter, Instagram, Pinterest, Tumblr, Pose, and YouTube ("Social Media Pages"). This Privacy Policy applies only to the information collected online at www.ELOQUII.com (the "Site") and the Social Media Pages, as well as information collected by us offline.

We recently updated our Privacy Policy on July 1, 2021.

Updates Include:

• Clarifying our practices with regard to sharing information outside of the company

What type of information does ELOQUII collect?

1. Categories of Personal Information:

Categories of personal information collected may include:

- Personal identifiers, such as name and address

- Device and online identifiers and related information, such as telephone number and email address

- Internet, application, and network activity, such as cookie IDs and browser visits

- Demographic information, such as age and date of birth

- Financial information, such as credit and debit card numbers and claims information

- Characteristics of protected classifications under state or federal law, such as gender and nationality

- Purchase history information, such as products you have bought, rented, and returned

- Location information, such as geo-location information

- Audio, visual, and other sensory information, such as audio and video recordings

- Employment information, such as occupation, title, licenses and professional memberships

- Education information, such as degree and schooling information

- Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors

Not all categories will be collected about every individual. This information is referred to as "Personal Information" in this Privacy Policy. Navigational Information and Personal Information are collectively referred to as "Information" in this Privacy Policy. Some laws define “Personal Information” differently, and we use those definitions when they are applicable. Rest assured, though, that no matter where you live, we treat your Personal Information with respect, and we collect, use, and share it only as described in this Policy. We do not consider Personal Information to include information that has been aggregated or anonymized so that it cannot be used to identify a specific individual.

2. Collection of Personal Information:

We collect information from you in a variety of ways. It may be:

- Provided directly by you or a member of your household

- Collected from a device associated with you or your household

- Collected from an external third-party source

a. Information Provided Directly by You or a Member of Your Household

We may ask you to provide personal information when you establish or update an Account on the Site, sign up to receive emails from ELOQUII or other marketing materials, make a purchase, contact customer support, create or update your wish list, send items to a friend, view your order history, participate in contests and surveys, or contact us.

b. Information Collected From a Device Associated With You or Your Household

When you visit our Site, we and third parties that provide functionality on the Site may engage, receive and record information about how you use and interact with the Site. This information is referred to in this Privacy Policy as "Navigational Information" and allows us to see which areas of the Site are most visited and helps us better understand our visitors' experiences at the Site.

We and service providers who provide services to our Site collect Navigational Information from technology such as Cookies and Web Beacons. Cookies are small text files that help us to personalize the content of the Site. Web Beacons are electronic files used to track your navigation on a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior. We use cookies and other tracking technology to help us remember and process the items in your shopping cart, understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about the Site’s traffic and interaction so that we can offer better experiences and tools in the future. We may also use these technologies to provide you with enhanced online display advertising tailored to your interests. We do not monitor, recognize, or honor any do not track mechanisms, including general web browser “Do Not Track” settings and/or signals, except as described below.

We may contract with service providers to assist us in better understanding visitors to the Site. These service providers are permitted to use the information collected on our behalf to help us conduct and improve our business and to provide fraud prevention services. If you prefer, you can choose to turn off some cookies via your browser settings. However, if you turn your cookies off, some features of the Site may not function properly. To learn more or to choose to opt-out of certain interest-based advertising, please visit the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choice.

c. Information We Collect from External Third-Party Sources

We also may receive information from other sources, such as our affiliates, parent companies, subsidiaries, joint ventures or other companies under common control with us, or from publicly available databases, or joint marketing partners.

What type of Information does ELOQUII collect on its Social Media Pages?

Personal Information may be collected directly by us through our Social Media Pages and may also be collected by the social media sites hosting our Social Media Pages (each, a "Social Media Site"). We will use and share the Personal Information we collect on through our Social Media Pages in the manner specified below in How does ELOQUII use your information? and in What information does ELOQUII share?

This Privacy Policy does not cover Personal Information collected by any Social Media Site or the privacy and security practices of any Social Media Site. Please review privacy policies and terms of service on the applicable Social Media Site, if you have any questions about their privacy or security practices.

The Social Media Sites may provide aggregate information and analysis to us about visitors' use of our Social Media Pages. This allows us to better understand and analyze our user growth, general demographic information about the users of our Social Media Pages, and interaction with content on our Social Media Pages. Overall, this information may be used to help us understand the types of visitors and users of our Social Media Pages and use of the content.

How does ELOQUII use your Information?

We use your Information to:

- Fulfill your order or requests for services and provide customer service

- Create and maintain your account

- Conduct auditing and monitoring of transactions and engagement

- Conduct marketing, personalization, and third-party advertising

- Protect the security and integrity of our websites, mobile services and our business, and help prevent fraud

- Update our operational and technical functionality

- Conduct business analysis, such as analytics, projections, identifying areas for operational improvement

- Conduct research and development

- Fulfill our legal function or obligations

If you have set up an Account at the Site, you may save Personal Information in that Account, and we will access this Personal Information to make your shopping quicker and easier. We require you to create and/or access your Account to use various features of the Site, such as accessing your order history and creating a wish list.

With respect to emails, we will use your Personal Information to send you exclusive information about special offers, media events, new products and much more. If at any time you would like to stop future delivery of emails from us, please follow the removal instructions located at the end of each message. Please note, however, that your request not to receive email information will not preclude us from contacting you by email or otherwise regarding questions we have about your purchase and other operational emails, such as shipping information.

You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about special offers, new products and more. You may opt out of receiving text messages at any time by texting STOP to 33233. For more information about text messages, see our Terms and Conditions.

We use the Personal Information collected on our Social Media Pages to send communications regarding our products, services, and promotions; to respond to your inquiries; to conduct surveys, sweepstakes or contests; to analyze your activity on our Social Media Pages and to develop our products and services.

We may anonymize and aggregate data collected through the Site and use it for any purpose. Such information does not identify you individually.

What Information does ELOQUII share with third parties?

All of the categories of personal information that we collect may be shared with other companies, including those within our corporate family, for a business purpose.

Service Providers. We may use service providers to assist us with the Site and our e-commerce business. Some examples of the assistance that may be provided by service providers are: monitoring and analyzing Site activity, operations and marketing assistance, hosting the Site, assisting us with our Social Media Pages, processing orders, running promotions and events and surveys, maintaining our database, processing employment applications, providing fraud prevention services and administering and monitoring emails. It is possible that some of these service providers will be located outside of the United States. We will share your Information with these service providers only as necessary for them to perform their functions and to the extent permitted by law.

Family of companies. We may share your personal information with other brands and businesses within the Walmart corporate family. When we do, the information will be used in ways that are consistent with this Policy.

Cooperative Databases. In connection with the distribution of our print catalogs and other marketing materials, we participate in cooperative data sharing databases. The participants of these databases provide customer names, mailing addresses and information about their customers’ purchasing history to the database vendor which allows the database participants to segment and/or obtain access to potentially interested parties to which they may wish to target their own promotions. If you do not wish to have your name, email address and mailing address released to these cooperative databases, you can opt-out by sending an email to marketing@ELOQUII.com.

Email Referrals. When you send an email from the Site to a friend, we will send the recipient of the email your email address, message, and your selected outfit or item(s). We may include an opportunity for the recipient to sign up to receive promotional materials from us.

Business Transactions. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, financing due diligence, bankruptcy, receivership sale of assets, dissolution, transition of service to another provider, or similar event, some or all of the Information may be part of the transferred assets.

Legal Requirements. To the extent permitted by law, we may also disclose Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others.

Deidentified & Aggregated Personal Information. We continually strive to make customer shopping experiences more relevant and with less friction and may offer related services and insights to our suppliers and others. As a result, we may share with others insights that combine information from many customers in ways that do not directly identify you. For example, we may combine your shopping history with that of other customers to deliver generalized insights to our suppliers. These insights do not identify individual customers. This information helps our suppliers provide products and services relevant to our customers. We may receive payment for these insights.

To deliver information about products and services that may be of interest to you, we may share information with other companies, such as publishers, advertisers and measurement analytics providers. For example, we may share device-related data (such as device identifier, type of device, IP address, cookies and other information associated with your browsing and app usage) and individual preferences and characteristics (such as insights and inferences related to shopping patterns and behaviors). This information does not identify you directly, but is necessary to personalize the advertisements you receive. We do not receive payment for this information.

We also allow companies that show advertisements on our webpages or our apps to collect information from your browsers or devices via the use of cookies or other technologies. Other companies' use of cookies and other data collection technologies are subject to their own privacy policies, not this one. Like many companies, we may allow cookie matching with select partners. However, these parties are not authorized to access information from our cookies. For more information about your choices related to advertising activities see “What are Your Choices?”

Categories of Personal Information We Disclose to Each Type of Third Party:

We may share your personal information with certain categories of third parties, as described below.

Types of Third Parties to Which the Personal Information Was Disclosed for a Business Purpose

Categories of Personal Information Disclosed for a Business Purpose

Those we are legally required to share with

Audio, visual, and other sensory information

Characteristics of protected classifications under state or federal law

Demographic information

Device and online identifiers and related information

Education information

Employment information

Financial information

Individual preferences and characteristics

Internet, application, and network activity

Location information

Personal identifiers

Purchase history information

Service providers that receive data in order to provide services to us (e.g. technology providers, cloud storage providers, etc.)

Audio, visual, and other sensory information

Device and online identifiers and related information

Employment information

Financial information

Individual preferences and characteristics

Internet, application, and network activity

Location information

Personal identifiers

Purchase history information

California Privacy Rights

California Consumer Privacy Act:

If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests per the requirements of California law.

1. You can request access to a copy of the personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.

2. You can request that we delete your personal information.

3. You can request that we stop selling your personal information.

More information on each of these requests is below.

1. Request my Personal Information: If you make this request, which we also refer to as a Request to Access Information, we will return to you (to the extent required by law):

• The categories of personal information we have collected about you.

• The categories of sources from which we collect your personal information.

• The business or commercial purpose for collecting or selling your personal information.

• The categories of third parties with whom we share personal information.

• The specific pieces of personal information we have collected about you.

• A list of categories of personal information that we have sold, along with the category of any other company we sold it to. Any of the categories of personal information that we collect could be included in a sale to other companies, including those within our corporate family. If we have not sold your personal information, we will inform you of that fact.

• A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

You can ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to personal information we collected about you in the previous 12 months.

2. Delete My Personal Information: You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account, and limit your use of functions that require your personal information.

3. Stop Selling My Personal Information: We share personal information within our Walmart family of companies and with certain third parties in a way that may be considered a “sale” under California law. For purposes of California law, we may share with these parties all categories of personal information. We do not knowingly sell the personal information of minors under 16 years of age. If you are a California resident, you have a right to opt-out of the sale of your personal information. To do so, click “Do Not Sell My Personal Information” at the bottom of this page to submit your request.

Below is a chart showing the types of personal identifiers that we may have sold in the previous 12 months.

Categories of Third Parties to whom the Personal Information may be Sold

Categories of Personal Information Sold

Advertising companies (like ad servers, advertising agencies, technology vendors, providers of sponsored content, cooperative databases, and others)

Device and Online Identifiers

Financial Information

Internet, application, and network activity

Location Information

Personal Identifiers

Purchase History Information

Other entity in the Walmart family of companies

Device and Online Identifiers

Financial Information

Internet, application, and network activity

Location Information

Personal Identifiers

Purchase History Information

We will not discriminate against you for exercising your rights. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Please know, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require usage of your personal information to function.

To exercise the California privacy rights for requesting or deleting your personal information, please click “Request for Personal Information” at the bottom of this page or call 1-844-693-5678.

To exercise your right to opt out of the sale of personal information, click “Do Not Sell My Personal Information” at the bottom of this page to submit your request.

Verifying Your Identity for Requests to Access or Delete Personal Information

We take the privacy of your personal information seriously and want to ensure that we provide only you or your authorized agent with your personal information. The CCPA also requires that we verify the identity of each person who makes a request to know what personal information we have about you or to delete the personal information we have about you.

What personal information do I provide to verify my identity?

To verify your identity, we ask you to provide your:

First name*

Last name*

Middle initial

Email address*

Phone number

Address*

*required field

How do you verify my identity?

We may verify your identity in a few different ways. We’ve partnered with a third party identification service to help us verify your identity and prevent fraudulent requests. When you make your request, you will be asked to answer a few questions about yourself to help us validate your identity. If you have an online account, we may ask you to log into your account and complete a one-time passcode validation.

In some instances, we may ask you to provide other documentation to verify your identity. If this happens, we will reach out to you directly with this request.

What if you can’t verify my identity?

If we can’t verify your identity, we will not be able to process your request to know what personal information we have about you or to delete the personal information we have about you. If we are unable to verify your identity with a high degree of certainty, we will only be able to provide a report with category-level information and we may not be able to delete some of your information.

How to Submit a Request Using an Authorized Agent

An authorized agent is a person or business who has authorization to request to know what personal information we have about you, to delete the personal information we have about you, or to opt out of the sale of personal information on behalf of a California resident. Authorized agents use the same links described above to submit requests.

If you are submitting a request on behalf of another person, we require a valid power of attorney or other documentation demonstrating your authority to submit this request. This can be a letter or other documentation signed by the California resident authorizing you to submit this request. You can download a sample letter from the request form.

How do I send you my documentation?

If you submit a request on our website, you will be asked to upload this documentation when you submit your request. If you submit your request over the phone, you will be asked to email your forms to consumerprivacy@wal-mart.com. Please note, you will have 10 business days to provide all required documentation.

Your California Privacy Rights - Shine the Light:

Under California Civil Code Section 1798.83, California residents who have established business relationships with us may choose to opt out of our sharing their Personal Information with third parties for their own direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to operations@eloquii.com or write to us at:

ELOQUII Design, Inc.

250 Hudson St, 4th Floor

New York NY 10013

Visitors From Outside the U.S.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By using the Site and/or providing us with any Information, you consent to any transfer and processing in accordance with this Policy.

Information that is NOT covered by this Privacy Policy

If you decide to make any Personal Information or other information, photos, or other content publicly available through features on the Site, you acknowledge and agree that this information and content is made available to all users of the Site and others, and that it is not subject to the terms of this Privacy Policy.

Updating your Personal Information

We prefer to keep your Personal Information accurate and up-to-date. To do this, we provide you with the opportunity to update or modify your Personal Information by logging in to your Account.

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Site. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide Personal Information through Internet without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to other websites

For your convenience, our web site may contain links to web sites that are owned and/or operated by third parties (each, a "Third Party Site"). We are not responsible for the privacy practices, advertising, products, services or the content of any Third Party Site. Links that appear on the Site should not be deemed to imply that we endorse or have any affiliation with any Third Party Site or the products, services, or content made available through any Third Party Site. We encourage you to review the separate privacy policies and terms of use of each Third Party Site that you visit.

Security statement

We take steps to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send via e-mail.

Updates to Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Site as they go into effect. By accessing the Site after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

Questions or Concerns

If you have additional questions or would like more information regarding our information collection, use of disclosure practices, please feel free to contact us at:

ELOQUII Design, Inc.

250 Hudson St, 4th Floor

New York, NY 10013

operations@eloquii.com

You can also refer to our FAQs

This privacy policy was last updated July 1, 2021.

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