Davines retains personal information only for as long as necessary to provide our services and process your requests, purchases, transactions, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. 

Davines may disclose your information for a business or commercial purpose or share for cross-context behavioral advertising. When we disclose or share your information for cross-context behavioral advertising, we enter into 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.

A. Personal Information We Disclose for a Business or Commercial Purpose

In the preceding twelve (12) months, Davines has disclosed the following categories of personal information for a business or commercial purpose:

• Identifiers: Distributors and subsidiaries, successor(s) in interest in connection with a corporate event such as corporate reorganization, restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

• California Customer Records personal information categories: Distributors and subsidiaries, payment processors (if data is related to payments), successor(s) in interest in connection with a corporate event such as corporate reorganization, restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

• Commercial information: Distributors and subsidiaries, successor(s) in interest in connection with a corporate event such as corporate reorganization,  restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

• Professional or employment-related information: Distributors and subsidiaries, successor(s) in interest in connection with a corporate event such as corporate reorganization,  restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies.

• Inferences drawn from other personal information: Subsidiaries, successor(s) in interest in connection with a corporate event such as corporate reorganization,  restructuring, merger, acquisition, bankruptcy, or another major event, and governmental and/or law enforcement agencies. 
  

Business or Commercial Purposes for Disclosing Your Personal Information 

We may disclose the personal information we collect for one or more of the following business or commercial purposes:

• To fulfill or meet the reason you provided the information;

• To monitor and analyze trends, usage, and activities in connection with our products and services;

• To provide, support, personalize, and develop our Sites, products, and services;

• To create, maintain, customize, and secure your account with us;

• To process your requests, purchases, transactions, and prevent transactional fraud;

• To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses;

• To provide you with email alerts, promotional offers and other notices concerning our services;

• To facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;

• To personalize your Sites experience, and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email or text message (with your consent, where required by law);

• To help maintain the safety, security, and integrity of our Sites, products and services, databases and other technology assets, our clients and business, and to ensure that our Sites are working as intended and for analytics, auditing and technical assistance purposes and other general business purposes;

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

• As described to you when collecting your personal information or as otherwise set forth in the CCPA; and

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Davines’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Davines about our users and/or customers is among the assets transferred.

B. Personal Information We Sell or Share for Cross-Context Behavioral Advertising

In the preceding twelve (12) months, Davines has not sold personal information. Davines does not sell personal information. In the preceding twelve (12) months, Davines has shared for cross-context behavioral advertising the following categories of personal information:

• Identifiers: Advertising and marketing providers, social networks, data analytics providers.

• Internet or other similar network activity: Advertising and marketing providers, social networks, data analytics providers.

• Inferences drawn from other personal information: Advertising and marketing providers, social networks, data analytics providers. 

1. Business or Commercial Purposes for Sharing for Cross-Context Behavioral Advertising or Selling your Personal Information 

We may share personal information for cross-context behavioral advertising the personal information we collect for one or more of the following business or commercial purposes:

• To deliver content, and product and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email or text message (with your consent, where required by law); and

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

2. Right to Opt-Out of Selling or Sharing for Cross-Context Behavioral Advertising

If you are age 16 or older, you have the right to direct us not to share your personal information for cross-context behavioral advertising at any time. We do not share for cross-context behavioral advertising the personal information of consumers we have actual knowledge are less than 16 years old.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to gdpr@davines.it.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing for cross-context behavioral advertising.

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.

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

A. Access to Specific Information and Data Portability Rights

 You have the right to request that Davines disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion and Correction Rights), we will disclose to you:

1. The categories of personal information we collected about you;

2. The categories of sources from which we collected personal information about you;

3. Our business or commercial purpose for collecting, selling or sharing your personal information for cross-context behavioral advertising;

4. The categories of third parties with whom we share your personal information for cross-context behavioral advertising; and

5. The specific pieces of personal information we collected about you (also called a data portability request).

6. Additionally, if we sold, shared for cross-context behavioral advertising, or disclosed your personal information for a business or commercial purpose, we will provide you with two separate lists disclosing: 

   1. The categories of personal information Davines shared for cross-context behavioral advertising or sold to third parties and for each category identified, the categories of third parties to whom it sold or with whom it shared for cross-context behavioral advertising that particular category of personal information; and

   2. The categories of personal information Davines disclosed for a business or commercial purpose to third parties and for each category identified, the categories of third parties to whom it disclosed that particular category of personal information.

B. Deletion Request Rights 

You have the right to request that Davines delete any of your personal information that it collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion and Correction Rights), 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 in compliance with the CCPA if retaining the information is necessary for us or our service provider(s) to, among others: complete the transaction for which we collected the personal information, provide a good or service that you requested or take actions reasonably anticipated within the context of our ongoing business relationship with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. Correction of Inaccurate Personal Data Rights

You may update or correct your personal information free of charge, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will correct (and direct our service providers to correct) your personal information in our records, unless an exception applies. We may ask that you identify yourself and the information you wish to change for security purposes. 

To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request to us by:

• Email: gdpr@davines.it

• Toll-free Phone Number: + 866-328-4637 during regular business hours (Monday through Friday, 9:00 am to 5:30 pm ET) 

Only you, or a person registered with the California Secretary of State 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 twelve (12) month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

• 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We shall confirm receipt of a customer’s request to know or delete within ten (10) business days. We endeavor to respond to a verifiable consumer request to access, delete or correct within forty-five (45) days of its receipt, and to a verifiable consumer request to opt-out of selling or sharing their personal information or to limit use of their sensitive personal information within fifteen (15) business days of its receipt. If we require more time (up to 45 days) to respond to a verifiable consumer request to access, delete or correct, we will inform you of the reason and extension period in writing within the initial forty-five (45) days after receipt of the verifiable consumer request.

If you have an account with us, our written response to your verifiable consumer request will be delivered through such account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. For data portability requests, we will select a format that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Any disclosures we provide pursuant to a verifiable consumer request will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. If applicable, our response will also explain the reasons we cannot comply with your request.

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

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; or

• Retaliate against you for exercising your CCPA rights.

Pursuant to California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834; or by telephone at 800-952-5210; or by email to dca@dca.ca.gov. For more information about protecting your privacy, you may wish to visit: https://www.ftc.gov/.

Davines reserves the right to amend this privacy notice at its discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our Sites and update the notice’s effective date.

If you have any questions or comments about this notice, the ways in which Davines collects and uses your information described above, your choices and rights regarding such use, please do not hesitate to contact us at gdpr@davines.it or +1 212 924 2470 ext.12.