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Scent For Success

PRIVACY POLICY

We, at Scent for Success, are committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the personal data we collect from users of our website.

By using the Services, users consent to the collection and use of their Personal Data by us. You also represent to us that you have any and all authorizations necessary to use these Services including using them to process Personal Data. We collect and use the information you provide to us, including information obtained from your use of the Services. Also, we may use the information that we collect for our internal purposes to develop, tune, enhance, and improve our Services, and for advertising and marketing consistent with this Privacy Policy.

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personal Data’ is being used online. Personal Information means data which relate to a living individual who can be identified – (a) from those data, or (b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

Please read our privacy policy carefully to get a clear understanding of how our website collects, uses, protects or otherwise handles users’ Personal Data.

This Privacy Policy is intended to inform users about how our website treats Personal Data that it processes about users. If users do not agree to any part of this Privacy Policy, then we cannot provide its Services to users and users should stop accessing our services.

By using the Services, You acknowledge, consent and agree that we may collect, process, and use the information that you provide to us and that such information shall only be used by us or third parties acting under our direction, pursuant to confidentiality agreements, to develop, tune, enhance, and improve the Services.

Although we may attempt to notify you when changes are made to this Privacy Policy, you are responsible for periodically reviewing any changes which may be made to the Policy. We may, in our sole discretion, modify or revise the Policy at any time, and you agree to be bound by the same.

Our privacy policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this policy periodically.

1. INFORMATION WE COLLECT:

1.1. You provide us information about yourself – Your Full Name, Username, E-mail Address, Geolocation. If you correspond with us by e-mail, we may retain the content of your e-mail messages, your e-mail address, and our responses.

1.2. We collect Know Your Customer data such as Passport Number, Identification Number, Address, Contact Details, etc in order to identify you.

2. INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES:

2.1 When you access or use our Services, we automatically collect information about you, including:

a) Usage Information: If you choose to post messages on our message boards, online/ offline chats or other message areas or leave feedback for other users, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If you send us personal

correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the Website, we may collect such information into a file specific to you.

b) Log Information: We log information about your use of our Website, including your browser type and language, access times, pages viewed, your IP address and the Website you viewed before navigating to our Website.

c) Device Information: We may collect information about the device you use to access our Services, including the hardware model, operating system and version, unique device identifier, phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information.

d) Location Information: With your consent, we may collect information about the location of your device to facilitate your use of certain features of our Services, determine the speed at which your device is traveling, add location-based filters (such as local weather), and for any other purposes.

e) Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to you. A “cookie” is a small data file transferred to your computer’s hard drive that allows a Website to respond to you as an individual, gathering and remembering information about your preferences in order to tailor its operation to your needs, likes and dislikes. Overall, cookies are safe, as they only identify your computer to customize your Web experience. Accepting a cookie does not provide us access to your computer or any Personally Identifiable Information about you, other than the information you choose to share. Other servers cannot read them, nor can they be

used to deliver a virus. Most browsers automatically accept cookies, but you can usually adjust yours (Microsoft Internet Explorer, Firefox or Google Chrome) to notify you of cookie placement requests, refuse certain cookies, or decline cookies completely. If you turn off cookies completely, there may be some Website features that will not be available to you, and some Web pages may not display properly. To support the personalized features of our Website (such as your country and language codes and browsing functions) we must send a cookie to your computer’s hard drive and/or use cookie-based authentication to identify you as a registered Website user. We do not, however, use so-called “surveillance” cookies that track your activity elsewhere on the Web. We may also collect information using web beacons (also known as “tracking pixels”).

f) “Web beacons” or clear .gifs are small pieces of code placed on a Web page to monitor behavior and collect data about the visitors viewing a Web page. For example, Web beacons or similar technology can be used to count the users who visit a Website or to deliver a cookie to the browser of a visitor viewing that page. We may use Web beacons or similar technology on our Services from time to time for this and other purposes.

3. HOW WE USE YOUR INFORMATION:

I. We use the personal information we collect to fulfill your requests for services, improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients.

II. By providing us your e-mail address, you consent to us using the e-mail address to send you our Website and services related notices, including any notices required by law, in

lieu of communication by postal mail. You also agree that we may send notifications of activity on our Website to the e-mail address you give us, in accordance with any applicable privacy settings. We may use your e-mail address to send you other messages, such as newsletters, changes to our features, new services, events or other information. If you do not want to receive optional e-mail messages, you may modify your settings to opt out.

III. Our settings may also allow you to adjust your communications preferences. If you do not wish to receive promotional email messages from us, you may opt out by following the unsubscribe instructions in those emails. If you opt out, you will still receive non-promotional emails from us about our Services.

IV. Following termination or deactivation of your services, we may (but are under no obligation to) retain your information for archival purposes. We will not publicly disclose any of your personally identifiable information other than as described in this Privacy Policy.

V. At our sole discretion, for any reason or no reason at all, we reserve the right to remove any content or messages, if we believe that such action is necessary (a) to conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities;

to enforce this policy, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our Website; or (c) to exercise or protect the rights, property, or personal safety of the Website, our users, or others.

VI. Business Transfers: As our businesses continue to evolve, we might sell one or more of our companies, subsidiaries or business units. In such transactions, personally identifiable information generally is one of the transferred business assets. In such event, this Privacy Policy may be amended as set forth below or the collection and uses of your personally identifiable information may be governed by a different privacy policy.

VII. Protection of Our Services and Others: We reserve the right to release personally identifiable information to unaffiliated third parties when we believe its release is appropriate to comply with the law, enforce or apply our Terms and Conditions and other agreements, or protect the rights, property or safety of Trader Interactive, our users or others. This includes exchanging information with other unaffiliated third parties in connection with fraud protection and credit risk reduction.

VIII. With Your Consent: Other than as set out above, you will receive notice and have the opportunity to withhold consent when personally identifiable information about you might be shared with unaffiliated third parties.

IX. We may transmit the user data across the various Websites of the Company.

X. User Submissions: If you participate in any online forum/communities, chat sessions and/or blogs, or otherwise post in any user comment field visible to other users of our Services, any information that you submit or post will be visible to and may be read, collected or used by others who use our Services. We are not responsible for any information, including personally identifiable information, you choose to submit in any such user comment field.

4. HOW WE SHARE YOUR INFORMATION:

I. As a matter of policy, we will not sell or rent information about you and we will not disclose information about you in a manner inconsistent with this Privacy Policy except as required by law or government regulation. We cooperate with law enforcement inquiries, as well as other third parties, to enforce laws such as those regarding intellectual property rights, fraud and other personal rights.

II. We will not share the personal information we collect about you with any third party for their own marketing purposes without your consent. We may share your data with our services providers who process your personal information to provide services to us or on our behalf. We have contracts with our service providers that prohibit them from sharing the information about you that they collect or that we provide to them with anyone else, or using it for other purposes.

III. You may decline to submit Personally Identifiable Information through the Services, in which case we may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms of Service, please discontinue use of our Service; your continued usage of the Service will signify your assent to and acceptance of our Privacy Policy and Terms of Use.

IV. WE CAN (AND YOU AUTHORIZE US TO) DISCLOSE ANY INFORMATION ABOUT YOU TO LAW ENFORCEMENT, OTHER GOVERNMENT OFFICIALS, ANY LAWSUIT OR ANY OTHER THIRD PARTY THAT WE, IN OUR SOLE DISCRETION, BELIEVE NECESSARY OR WEBSITE APROPRIATE IN CONNECTION WITH AN INVESTIGATION OF FRAUD, INTELLECTUAL PROPERTY INFRINGEMENT, OR OTHER ACTIVITY THAT IS ILLEGAL OR MAY EXPOSE US, OR YOU, TO LIABILITY.

5. ENSURING INFORMATION IS ACCURATE AND UP-TO-DATE

I. We take reasonable precautions to ensure that the Personal Information we Collect, Use and Disclose is complete, relevant and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. That’s why we recommend that you:

a) Let us know if there are any errors in your Personal Information; and

b) Keep us up-to-date with changes to your Personal Information such as your name or address.

6. HOW WE PROTECT YOUR INFORMATION:

I. We are very concerned about safeguarding the confidentiality of your personally identifiable information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access.

II. By using this Website or the Services or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this Website or Services.

III. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Information. Your sensitive information, such as credit card information, is encrypted when it is transmitted to us. Our employees are trained and required to safeguard your information. We cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Using unsecured wi-fi or other unprotected networks to submit messages through the Service is never recommended. Once we receive your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such

information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps.

IV. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property. However, nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party, including a government’s, request to disclose your information.

V. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us credit card information and/or other sensitive information through email. If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section available on our Website.

7. YOUR CHOICES ABOUT YOUR INFORMATION:

I. You have several choices regarding use of information on our Services:

a) Email Communications: We will periodically send you free newsletters and e- mails that directly promote the use of our Website, or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity

to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly. Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

b) You may, of course, decline to submit personally identifiable information through the Website, in which case, we will not be able to provide our services to you.

Scent For Success

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