Privacy policy

<h1>MRK Fine Arts LLC Privacy Policy Last updated on 03/22/24.</h1>
 
 
We at MRK Fine Arts LLC (“Monica Rich Kosann”) respect your concerns about privacy. This Privacy Policy applies to MRK Fine Arts LLC (referred to herein as “MRK,” we,” or “our”). The policy governs our practices regarding the collection, use and disclosure of personal information that we collect offline and online, including via our website at www.monicarichkosann.com (the “Website”), by email, marketing communications, social media, mail, telephone, chat or other means.  
 
This Privacy Policy is subject to our Terms and Conditions.  We may update this Privacy Policy from time to time, as specified in the “Changes to This Privacy Policy” section below. 
 
Certain state laws confer certain rights relating to personal information to their residents. If you are a resident of those states, please also see the applicable sections in this Policy located at:
<ul>
<li><a href="https://www.monicarichkosann.com/policies/privacy-policy#CA_privacy_rights">Click here for California </a></li>
<li><a href="https://www.monicarichkosann.com/policies/privacy-policy#VA_privacy_rights">Click here for Virginia</a></li>
</ul>
 
Your Consent
 
Please review this Policy periodically.  You should read this entire Policy before submitting information, including personal information, to us in any form or using our Site.  Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Policy.
 
All personal information may be used for the purposes stated in this Policy.  We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. 
 
 
COLLECTION OF PERSONAL INFORMATION
 
We collect personal information using the following methods: 1) from you when you voluntarily provide it, including online when you visit our website, or when you interact with us in any other manner; 2) using automated technology, including when you visit our Site or interact with our electronic advertisements or communications; and 3) using third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and social networking websites and other entities.  To see a complete list of what we collect, how we use this data, please see our <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a>.
 
Personal Information
 
MRK collects Personal Information, such as your email address, name, address, or telephone number based on your communications with us including through purchase of products and submission of forms on the Site and communications via email, telephone call, and other electronic messages such as the refer a friend function. MRK also collects commercial information regarding your product purchases and transactions and payment information in connection with those transactions.
 
Internet / Network Activity
When you visit our website, we collect information about you through your browser, computer hardware and software.  This information can include your IP address, device ID, browser type, domain names, access times and dates, number of clicks, pages viewed, one or more cookies (as described below) that may uniquely identify your browser, and referring website addresses. We use this information for the improvement of our site.
 
Sensitive Personal Information
We do not collect or process sensitive personal information.
 
HOW WE USE YOUR PERSONAL INFORMATION
We use Personal Information of customers for a wide range of purposes, including:
<ul>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">to provide you with products and services or process requested transactions;</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">to create and manage your account;</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">the send you promotional materials and our catalogs;</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">to respond to your requests and feedback;</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">to improve our products, business, and Site;</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">to follow up with you after you have communicated with us or submitted information to us;</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">to send promotional communications or offers (unless you have requested that we not send such communications);</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">for marketing, research, legal and other purposes;</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">to perform data analyses (including anonymization and aggregation of personal information); and</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">as otherwise specified at the point of Personal Information collection.</li>
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EMAIL/TEXT MARKETING
We will occasionally send out promotional emails. You may opt-in to receive emails from us by providing an email address during checkout or through our website. If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Please note that unsubscribing from our promotional material will not prevent us from contacting you for other reasons, such as responses to customer service inquiries, or information about a community or plan type for which you have expressed interest in.
You may also choose to participate in certain text or SMS/MMS marketing. If you opt in to such marketing, we may collect and use certain personal information, including phone number, email, product browsing behavior, purchase behavior, device type, cellular carrier, and location to contact you and provide you marketing communications or promotions.
Monica Rich Kosann uses cookies to collect information around abandoned shopping carts. A cart is considered abandoned within one hour of inactivity/lack of purchase. Once the cart is considered abandoned, an SMS message will be sent as a reminder. <a href="https://www.monicarichkosann.com/pages/sms-terms-conditions">Click here for Mobile Terms & Conditions.</a>
 
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
Service Providers and Contractors
We disclose Personal Information you provide to consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host our website and data, security and fraud detection vendors.
 
Third Party Partners
We disclose Personal Information to third parties we work with who help us gather information from you and communicate with you including social media companies, entities that assist with marketing and advertising, and companies providing data analytics.
 
Legal Obligations
We may disclose Personal Information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations.
 
Sale or Corporate Restructuring
We may disclose Personal Information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.
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HOW WE USE “COOKIES” AND OTHER TECHNOLOGY
As you enter the Site, our server records and monitors your IP address and uses it to develop statistical analysis.  These analyses assist us in refining and adapting the content and design of our site.  The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users.  Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology.  A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer's browser.  A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity.  They are also sometimes referred to as pixels and tags.
As you access or use our Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy.  Such automated technologies further help us to keep track of your interactions with our website and provide you with a more customized experience.
To find more information about cookies please visit www.allaboutcookies.org.  Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use.  By disabling cookies, you won't be able to enjoy the convenience provided by our customization.
Third Party Advertising And Analytics Disclaimer
We and/or third parties including service providers on our behalf, may use cookies, web beacons and other similar technology, to collect information from you such as your activities on the Website for the purposes described in this Policy including analytics, monitoring performance, and improvement of our Site (traffic, errors, page load time, popular pages, etc.)
Examples of our third-party service providers to help deliver our services or to connect to our services include:
<ul>
<li>Google Ads: We use Google Ads.  You can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/.</li>
<li>Meta Ads and Pixel:  We use Meta Ads to advertise and market our services to you. To learn more about how Facebook uses your data please visit <a href="https://www.facebook.com/privacy/explanation">https://www.facebook.com/privacy/explanation</a> or log on to your Facebook account and access your settings. To understand more about Facebook advertising and manage your preferences, please visit <a href="https://www.facebook.com/about/ads">https://www.facebook.com/about/ads</a>.</li>
</ul>
 
This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.
 
Digital Advertising Alliance
You can also opt out from companies like Google, Meta and other participating companies through the Digital Advertising Alliance in the USA: <a href="http://www.aboutads.info/choices/"> http://www.aboutads.info/choices/</a>.  You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: <a href="http://youradchoices.ca/"> http://youradchoices.ca/</a> or the European Interactive Digital Advertising Alliance in Europe: <a href="http://www.youronlinechoices.eu/"> http://www.youronlinechoices.eu/</a>, or opt out using your mobile device settings.
 
 
PAYMENT
We at Monica Rich Kosann do not have access to your credit card information. If you choose a direct payment gateway (through our site platform and e-commerce platform, Shopify) to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
 
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.
 
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
 
For more insight, you may also want to read <a href="https://www.shopify.com/legal/terms">Shopify’s Terms of Service</a> or <a href="https://www.shopify.com/legal/privacy">Privacy Statement</a>.
 
International Canadian & Australian Orders:
We partnered with Global-e, a third party service acting as your seller-on-record for Australia and Canada.  When you buy your MRK products via Global-e, you will see that your payment method is charged by **Global-e/MRK**, and the purchase is subject to Global-e’s Terms and Conditions and Privacy Policy (which will be clearly presented in checkout before you place the order). You can contact Global-e here: <a href="https://service.global-e.com/">https://service.global-e.com/</a> or view <a href="https://www.global-e.com/consumer-privacy-policy">Global-e privacy policy</a><a href="https://globale-prod.s3-eu-west-1.amazonaws.com/GlobaleLegalDocuments/GlobalePrivacyPolicy/Global-e%20Privacy%20Policy.pdf">.</a>
 
RETENTION OF PERSONAL INFORMATION
We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy.  We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.  For more information regarding retention of personal information, see <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a>.
 
INTENDED AUDIENCE OF WEBSITES; COPPA COMPLIANCE
The Children's Online Privacy Protection Act ("COPPA") does not apply to us.  Our Website is not directed to children under the age of 13.  As a result, our Website does not request or knowingly collect Personal Information from individuals under the age of 13.  If you are not 13 or older, you should not visit or use our Website. If we learn that personally identifiable information of persons under 13 years of age has been collected on the Website without verified parental consent, then we will take appropriate steps to delete the information.
 
 
EXTERNAL LINKS
We may make available third party applications through our Website, blog and social media applications for your use. Links to such applications, any other websites included in this Website or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Website or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account’s operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.
 
 
CONTACT PREFERENCES; OPT-IN AND OPT-OUT<span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;"> 
We would like to keep in touch with you in ways that you find to be beneficial.  If you don’t want us to use your contact information to communicate with you, please tell us so when you provide your contact information.
 
If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe) or by contacting us at concierge@monicarichkosann.com. Please note that unsubscribing from our promotional material will not prevent us from contacting you for other reasons, such as order confirmations, responses to customer service inquiries, or information about an event for which you have registered.
 
Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals.  In addition, we may allow third parties to collect personal Information from your activity on our website, as described in the “Information Collection and Use” section above.
 
DATA TRANSFERS
We may transfer the personal information we collect about you through the Site to countries other than the country in which the information originally was collected, including to the United States. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Online Privacy Notice.
 
 
SECURITY
 <span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">We take appropriate steps to protect personal Information from loss, misuse and unauthorized access, disclosure, alteration or destruction, whether in transmission or storage.  Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free. Moreover, you are responsible for maintaining the confidentiality of any user name and password you use.
 
GOVERNING LAW
 <span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">This Policy and our privacy practices will be subject exclusively to the laws of the State of California, United States of America.  We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.
 
 
CHANGES TO THIS PRIVACY POLICY<span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;"> 
This Privacy Policy may be revised from time to time for any reason.  If this Privacy Policy changes, the revised policy will include a new effective date and we will notify you of such changes by posting the revised policy on this page.  Be sure to check the Privacy Policy whenever you submit personal Information or use our website.
 
CONTACT US
If you have questions or concerns related to this Privacy Policy or our information practices, would like to update or correct information you have provided or would like to opt-out of promotional communications from us, please contact us as follows:
Email:  concierge@monicarichkosann.com
Phone Number:  1-800-251-3141
Address:  P.O. Box 797, Norwalk, CT 06852
 
 
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CALIFORNIA CONSUMERS ONLY:  Your California Privacy Rights
This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).  This Notice does not apply to you if you are not a California resident.  Please visit our <a href="https://www.monicarichkosann.com/policies/privacy-policy">Privacy Policy</a> (“Policy”) for more information.  Any capitalized terms undefined in this Notice have the same definition as the Policy. 
PERSONAL INFORMATION COLLECTED, SOLD OR SHARED
Information Collected
We collect the categories of personal information about California consumers as described in Annex 1 to this Notice.  To review these categories click here: <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a>.
Business-to-Business (“B2B”) Information
If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship.  We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.  We do not disclose that information outside our business relationship without your consent.  See <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a> for more details.
 
Information Sold or Shared
We have not sold any personal information for a business or commercial purpose in the preceding 12 months.
We have shared the following categories of personal information for targeted advertising in the preceding 12 months:
<ul>
<li>  Personal Information</li>
<li>  Commercial Information</li>
<li>  Internet Activity</li>
</ul>
We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months:
<ul>
<li>  Personal Identifiers</li>
<li>  Commercial Information</li>
<li>  Financial Information</li>
<li>  Internet Activity</li>
</ul>
 
We do not knowingly sell or share the personal information of individuals under 16 years of age without affirmative authorization.
For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a>
 
 
CPRA RIGHTS AND REQUESTS
Under the CPRA, you are entitled to certain rights, and you can make requests with regard to those rights as follows:
Right to Know about the Categories of Personal Information Collected (“Right to Know”)
Right to Request Deletion of Personal Information (“Right to Delete”)
Right to Correct or Rectify Inaccurate Information about you (“Right to Correct”)
 
HOW TO MAKE YOUR REQUESTS TO KNOW, DELETE, OR CORRECT.
You have the right make requests for the aforementioned rights (Request to Know; Request to Delete; or a Request to Correct (a “Request”)).
To make a Request for any of the information set forth above, please submit a verifiable consumer request pursuant to the instructions below. The Request must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, shared, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request.  If we cannot verify your identity, we will not be able to respond to your request.  We will acknowledge your Request within 10 business days and will attempt to respond substantively within 45-90 days.
You may make a Request the following ways:
<ul>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">You may make a request here:  concierge@monicarichkosann.com</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">You may make a request using our webform here.</li>
<li><span style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" data-mce-style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;">You can make a request by calling us: 1-800-251-3141</li>
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Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identification.
We will review all information provided by you to us, to determine whether we can respond to your Request  We will inform you of our decision to deny or grant your Request.
For any Requests to Know, you may make such Requests twice within a 12-month period. 
For Requests to Correct, you will need to provide evidence supporting the inaccuracy of the current information, and we reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.
We will retain correspondence, documents and information related to any Request for 24 months as required by law.
ADDITIONAL CPRA RIGHTS
The following are additional rights afforded to you under the CPRA. 
     Right to Know Sensitive Personal Information Collected
We do not collect or use Sensitive Personal Information.
     Right to Opt out of Sharing and Selling
We do not sell your Personal Information as defined under the CPRA.  We do share your personal information for targeted advertising.
 
To opt out of sharing you may:
<ul>
<li>Make a request here:  concierge@monicarichkosann.com</li>
<li>Make a request using our <a href="https://www.monicarichkosann.com/pages/california-resident-do-not-sell-my-info">webform here</a>.</li>
<li>Make a request by calling us: 1-800-251-3141 </li>
</ul>
For more information about our collection practices, please visit our <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a> of this Policy. 
     Right to Non-Discrimination for Exercising Consumer Privacy Rights
You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.
 
ADDITIONAL OPTIONS TO OPT-OUT OF SALE OR SHARING WITH THIRD PARTY COMPANIES
You have controls and choices with respect to the collection and use of your information by third parties. These are summarized for you below.  We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation. 
 
Online Behavioral Advertising Opt-Out
You can opt out of sharing your information with third-party companies engaged in online behavioral advertising, including social networking sites such as Google and Facebook, using the following tools provided through the AdChoices website powered by the Digital Advertising Alliance (DAA): For websites: http://optout.aboutads.info/?c=2&lang=EN.  For mobile apps: http://www.aboutads.info/appchoices
 
Cookies
As explained in our "Cookies" section above, you can opt out of cookies using your browser. 
Please Note:
<ul>
<li>Opt-outs are device and browser based.  You must opt out on each device and each browser where you want your choice to apply.</li>
<li>Opt-outs maybe stored via cookies.  If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.</li>
<li>We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc.  These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.</li>
</ul>
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You may still receive ads from us that are not tailored to your interests. 
 
Opt-out Preference Signals 
We have implemented technical measures to honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain Personal Information. To process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you must turn it on for each browser and each device you use. If you have enabled a valid opt-out preference signal device from your browser, we will not sell or share your Personal Information without first seeking your explicit consent.
Notice of Financial Incentive
From time to time, MRK may provide financial incentives to consumers who elect to participate in these programs and, in connection with such programs, allow us to collect and retain certain personal information, such as Identifiers (e.g., your name, email address, or phone number) and Commercial Information (e.g., your purchase history).  These incentives may result in differences in the prices of our products offered to consumers (e.g., discounts and other promotions).  For example, the financial incentives we may provide include discounts based upon purchase activity, discounts in exchange for collection of your personal information, or other periodic discounts for promotional purposes.
The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.
Participation in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions, or contact us at concierge@monicarichkosann.com.
The value of your personal information that allows us to make these offers and financial incentives is the value of the offer itself.  Each financial incentive or price or service difference related to the collection and use of personal information is calculated based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself, the expense associated with the offer, and the anticipated revenue generation that may be realized by rewarding brand loyalty and repeat purchases.[MC2] 
 
 AUTHORIZED AGENT INFORMATION
You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.
Authorized agents can make requests under the California Consumer Privacy Act by emailing us at email address: concierge@monicarichkosann.com. We will require authorized agents to provide proof of the consumer’s identity and proof of designation as the authorized agent. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.
We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
California Do Not Track Notice: Because there are not yet common, industry-accepted “do not track” standards and systems, our website does not respond to Do Not Track signals.  In addition, we may allow third parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above and as described in <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a> below. 
CONTACT FOR MORE INFORMATION
For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at concierge@monicarichkosann.com.
Changes to This Privacy Policy
This Policy may be revised from time to time for any reason.  If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page.  Be sure to check the Policy whenever you submit personal information to us.
<div style="display: block; position: relative; top: -300px; height: 1px;" id="VA_privacy_rights" data-mce-style="display: block; position: relative; top: -300px; height: 1px;"></div>
 
 
VIRGINIA CONSUMERS ONLY:
VIRGINIA PRIVACY ACT NOTICE
This Notice provides additional information to Colorado, Connecticut, and Virginia residents whose personal data is collected pursuant to the Virginia Consumer Data Protection Act (“VCDPA”).   
The Notice below applies only to Virginia residents.  Please visit our <a href="https://www.monicarichkosann.com/policies/privacy-policy">Privacy Policy </a>(“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.
 
PERSONAL INFORMATION COLLECTED, SOLD, OR USED FOR TARGETED ADVERTISING
Information Collected
We have collected the categories of personal data about Virginia consumers as described in this Notice in Annex 1.  To review these categories, <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">click here</a>. 
Information Sold or Used for Targeted Advertising
We have not sold any personal information to third parties for a business or commercial purpose in the preceding 12 months.
We disclose the following categories of personal data for Targeted Advertising (See <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a> for further details):
<ul>
<li>Personal Identifiers</li>
<li>Commercial Information</li>
<li>Internet/Network Activity</li>
</ul>
For details regarding the categories of third parties with whom we have shared this information, please see <a href="https://www.monicarichkosann.com/policies/privacy-policy#Annex_1">Annex 1</a>.
 
 
VCDPA RIGHTS AND REQUESTS
Under the VCDPA, you are entitled to certain rights, and you can make requests with regard to those rights as follows:
Right to Confirm, Access, and Data Portability (“Right to Know”)
You have the right to confirm whether or not we are processing your personal data and to access such personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means. 
 
Right to Request Deletion of Personal Information (“Right to Delete”)
 
You have the right to request the deletion of your personal data provided by or obtained about you, subject to certain exceptions permitted by law.
 
Right to Correct or Rectify Inaccurate Information about you (“Right to Correct”)
 
You have the right to request that we rectify inaccurate information about you.
 
HOW TO MAKE YOUR REQUESTS TO KNOW, DELETE, OR CORRECT.
To make a Request for any of the information set forth above, please submit a verifiable consumer request pursuant to the instructions below.  We will respond to your request within 45 days of receipt, unless we request an extension for an additional 45 days to respond.
You can exercise this right in the following ways:
<ul>
<li>You may make a request here:  concierge@monicarichkosann.com</li>
<li>You may make a request using our <a style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" href="https://www.monicarichkosann.com/pages/california-resident-do-not-sell-my-info">webform here</a>.</li>
<li>You can make a request by calling us: 1-800-251-3141</li>
</ul>
<ul></ul>
 
Once we receive your request, we will begin the process to authenticate your identity to confirm that you are the person that is the subject of the request (the “Authentication Process”).  The Authentication Process consists of matching identifying information provided by you with the information we have about you in our records.  Upon making a request, you should be prepared to provide us with information that will help us to verify your identification.  If we cannot authenticate your identity, we will not be able to respond to your request.
We will retain correspondence, documents and information related to any Request for 24 months as required by law.
ADDITIONAL VCDPA RIGHTS
The following are additional rights afforded to you under the VCDPA.
Right to Opt-Out of Sale of Personal Data
We do not sell your Personal Information as defined under the VCDPA. 
Right to Opt Out of Data Processing for Targeted Advertising
You have the right to opt out of the processing of your personal data for purposes of targeted advertising.
You can opt out of data processing for targeted advertising in the following ways:
<ul>
<li>You may make a request here:  concierge@monicarichkosann.com</li>
<li>You may make a request using our <a style="font-family: -apple-system, BlinkMacSystemFont, 'San Francisco', 'Segoe UI', Roboto, 'Helvetica Neue', sans-serif; font-size: 0.875rem;" href="https://www.monicarichkosann.com/pages/california-resident-do-not-sell-my-info">webform here</a>.</li>
<li>You can make a request by calling us: 1-800-251-3141</li>
</ul>
<ul></ul>
 
Right to Opt-Out of Profiling
You have the right to opt out of the processing of your personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects.
You can opt out of profiling in the following ways:
<ul>
<li>You may make a request here:  concierge@monicarichkosann.com</li>
<li>You may make a request using our <a href="https://www.monicarichkosann.com/pages/california-resident-do-not-sell-my-info">webform here</a>.</li>
<li>You can make a request by calling us: 1-800-251-3141</li>
</ul>
 
 
Right to Non-Discrimination for Exercising Consumer Privacy Rights
You have the right not to receive discriminatory treatment for exercising your privacy rights, including by exercising the rights specified herein.  As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.
 
ADDITIONAL OPTIONS TO OPT OUT OF SALE OR TARGETED ADVERTISING
In addition to the above options to opt out of the “sale” or processing of your personal data for targeted advertising as described above, you have controls and choices with respect to collection and use of your data by third parties.  These are summarized for you below.  We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation.
 
Advertising Opt-Out
You can opt out of sharing your data with third-party companies engaged in targeted advertising including social networking sites such as Google and Facebook using the following tools:
<ul>
<li><a href="http://optout.aboutads.info/?c=2&lang=EN">For Websites</a> [hyperlink:<a href="https://optout.aboutads.info/?c=2&lang=EN"> https://optout.aboutads.info/?c=2&lang=EN</a>]</li>
<li><a href="http://www.aboutads.info/appchoices">For Mobile Apps</a> [hyperlink:<a href="https://youradchoices.com/appchoices"> https://youradchoices.com/appchoices</a> ]</li>
</ul>
 
Google Opt-Out
If you would like to opt out of Google Analytics and Ads, you can.  If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on here [<a href="https://tools.google.com/dlpage/gaoptout">https://tools.google.com/dlpage/gaoptout</a>], and you can opt out of interest-based Google ads using this link [<a href="https://adssettings.google.com/u/0/authenticated">https://adssettings.google.com/u/0/authenticated</a>.
 
Facebook Ad Preferences
To understand more about Facebook advertising and manage your preferences, please visit Facebook Ads [<a href="https://www.facebook.com/about/ads">https://www.facebook.com/about/ads</a>].  Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.]
 
 
OPT-OUT PREFERENCE SIGNALS
We honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal data. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal data for targeted advertising purposes without first seeking your explicit consent.
 
COOKIES
As explained in our <a href="https://www.monicarichkosann.com/policies/privacy-policy#use_cookies">“How We Use ‘Cookies’ and Other Automated Technology”</a> section, you can opt out of cookies using your browser.  You may also exercise your right to opt-out of cookies using our Cookie Preference Center (Link to Cookie Banner).
Please Note:
<ul>
<li>Opt-outs are device and browser based.  You must opt out on each device and each browser where you want your choice to apply.</li>
<li>Opt-outs maybe stored via cookies.  If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.</li>
<li>We may still share your Personal Information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc.  These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.</li>
</ul>
<ul></ul>
You may still receive ads from us that are not tailored to your interests.
 
AUTHORIZED AGENT
You may designate an authorized agent to make a request on your behalf to opt out of the sale of personal data.
Authorized agents may make requests under the VCDPA on behalf of consumers by filling out customer care <a href="https://www.monicarichkosann.com/pages/california-resident-do-not-sell-my-info">form here</a>..  We will require authorized agents to provide proof of the consumer’s consent to and designation of the authorized agent for purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the consumer who is the subject of the request.  We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request. 
 
RIGHT TO APPEAL
You have the right to appeal our decision to deny any of your privacy rights requests above.  Within 60 days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. 
If your appeal is denied, you may submit a complaint to the Virginia Attorney General at<a href="https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint"> https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint</a>.
 
Making an Appeal
You can make an appeal in the following ways:
<ul>
<li> You may make an appeal by phone by contacting us at: 1-800-251-3141.</li>
<li>You may also enter your appeal <a href="https://www.monicarichkosann.com/pages/california-resident-do-not-sell-my-info">here</a>. We reserve the right to deny appeals in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.</li>
</ul>
<h2>RETENTION OF PERSONAL DATA</h2>
We will retain your personal data for as long as it is necessary for the purposes set out in the <a href="https://www.monicarichkosann.com/policies/privacy-policy">Privacy Policy</a> and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your personal data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
 
 
<div style="display: block; position: relative; top: -300px; height: 1px;" id="ANNEX_1" data-mce-style="display: block; position: relative; top: -300px; height: 1px;"></div>
 
ANNEX 1 California and Virginia Notice of Collection, Use, and Disclosure
<a href="https://www.monicarichkosann.com/policies/privacy-policy">See our full Privacy Policy here</a>
<a href="https://www.monicarichkosann.com/policies/privacy-policy#CA_privacy_rights">See California Privacy Rights here</a>
<a href="https://www.monicarichkosann.com/policies/privacy-policy#VA_privacy_rights">See Virginia Privacy Rights here</a>
 
 
Annex 1
<table>
<tbody>
<tr>
<td style="width: 108.727px;">
Category
</td>
<td style="width: 79.8438px;">
Examples
</td>
<td style="width: 99.1172px;">
Collected From
</td>
<td style="width: 115.234px;">
Purposes
</td>
<td style="width: 103.508px;">
Disclosed to
</td>
<td style="width: 49.1172px;">
Sold or Shared
</td>
<td style="width: 76.5078px;">
Retention Period
</td>
</tr>
<tr>
<td style="width: 108.727px;">
Personal Identifiers
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial Information
</td>
<td style="width: 79.8438px;">
Name, signature, mailing address, telephone number, email address, date of birth, and, credit card information.
 
 
 
 
 
 
 
 
Products or services purchased, obtained, considered, reviewed or other purchasing or consuming habits.
</td>
<td style="width: 99.1172px;">
You when you visit our Site (including your online activities on our Site),  enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us in person, via phone or email or other methods. 
 
 
 
 
 
</td>
<td style="width: 115.234px;">
To respond to and fulfill your requests; to verify your identity; to process your transactions when you have cashed out and to report your winnings for tax purposes;
 
 
To improve our products, services, Site, and social media;
 
To provide you with a customized user experience;
 
To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications);
 
 
For marketing, research, legal, and other business purposes; and
 
To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies. 
</td>
<td style="width: 103.508px;">
Consultants, service providers, and contractors that we use to support our business and operations (e.g., hosting or operating our Site, data collection, reporting, ad response measurement, Site metrics and analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services;
 
Third-party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code);
 
Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics;
 
Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests;
 
An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of our company or its affiliates including any negotiation thereof; and
 
Third-party sponsors of contests, sweepstakes, discounts, and promotions that you enter into.
</td>
<td style="width: 49.1172px;">
Yes
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
No 
</td>
<td style="width: 76.5078px;">
We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
 
</td>
</tr>
<tr>
<td style="width: 108.727px;">
Internet/Network Activity
 
</td>
<td style="width: 79.8438px;">
IP address, your device information, domain name, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicks, transactions entered into and site-navigation patterns.
</td>
<td style="width: 99.1172px;">
Your computer or mobile device, through your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our Site, and on our social media channels or through our third-party sources. 
 
Third-party sources include third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.
</td>
<td style="width: 115.234px;">
Analyze and track usage of our services and products including our Site and social media accounts;
 
Improve our Site, services, and products;
 
Provide you with a customized user experience;
 
 
For other marketing, research, legal, and other business purposes; and
 
To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
</td>
<td style="width: 103.508px;">
Consultants, service providers, and contractors that we use to support our business and operations;
 
Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and
 
An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of our company or its affiliates including any negotiation thereof.
</td>
<td style="width: 49.1172px;">
Yes
</td>
<td style="width: 76.5078px;">
We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
</td>
</tr>
<tr>
<td style="width: 108.727px;">
Business-to-Business (“B2B”) Information
</td>
<td style="width: 79.8438px;">
Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.
</td>
<td style="width: 99.1172px;">
You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.
</td>
<td style="width: 115.234px;">
For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.
</td>
<td style="width: 103.508px;">
We do not disclose B2B Information outside our business relationship without your consent. 
</td>
<td style="width: 49.1172px;">
No
</td>
<td style="width: 76.5078px;">
We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
</td>
</tr>
</tbody>
</table>