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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 January 1, 2020.

Updates Include:

• Description of new rights available to California consumers under the California Consumer Privacy Act

• Clarifying our practice not to sell personal information for monetary consideration

• Clarifying how personal information is shared for advertising related activities

What type of information does ELOQUII collect?

1. Collection of Personal Information:

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, submit a career profile, or contact us.

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

- Health and health insurance information, such as prescription numbers and health insurance identification numbers

- 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.

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.

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. 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 Navigational Information:

When you visit our Site, we and service providers 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, please visit the Network Advertising Initiative here. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choice.

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.

We will use the Personal Information you provide in a career profile, including in your resume, to assist in your goal of becoming hired by us, and, if hired, we will use the Personal Information submitted for employment and business-related purposes.

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 have been 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 Information with any of our corporate Walmart Inc family companies for any purpose permitted under 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.

Advertising Related Activities. We may share aggregated or pseudonymous information (pseudonymous information includes things like: device identifier, type of device, IP addresses, cookies and other information associated with your browsing and app usage) with other companies, such as publishers, advertisers, measurement analytics providers and others. We do not share information that directly identifies you (information such as name or email address) with these companies.

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?”

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 to the extent required by law.

1. You can ask us what 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 ask us to delete your personal information.

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

More information on each of these requests is below.

1. What personal information do you collect about me? If you make this request, 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. If you choose to delete your personal information, you may not be able to use certain website or in-store functions that require your personal information to operate. Deleting your personal information will not cancel memberships you have purchased.

3. Stop Selling My Personal Information: We do not sell your personal information for monetary consideration. However, under some circumstances a transfer of personal information to a third party, or within our Walmart family of companies, without monetary consideration may be considered a “sale” under California law. For purposes of California law, all categories of personal information are transferred to third parties or within our family of companies. Such transfers may be considered a sale. If you submit a request to stop selling your personal information, we will stop making such transfers. If you are a California resident, to opt-out of the sale of your personal information, click “Do Not Sell My Personal Information” at the bottom of our home page to submit your request.

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 described above, please click “Request for Personal Information” at the bottom of our home page or call 1-844-693-5678.

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 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.

Two Miranova Place Suite 280

Columbus, OH 43215

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.

Two Miranova Place Suite 280

Columbus, OH 43215

operations@eloquii.com

You can also refer to our FAQs:

FAQs about the California Consumer Privacy Act:

• What is the California Consumer Privacy Act?

1. What is the California Consumer Privacy Act (CCPA)? The California Consumer Privacy Act (CCPA) provides residents of California specific rights to their personal information. As of January 1, 2020, customers now have the right to: know what information is being collected about them; know whether their personal information is sold or disclosed for a business purpose; opt out of the sale of their personal information; and delete their personal information.

2. Who is covered? All California residents. If you are unsure you are a resident, you can visit https://www.ftb.ca.gov/file/personal/residency-status/index.html for more information.

3. What information is covered under CCPA? Personal information is protected under the CCPA. Personal information is information that identifies, relates to or describes, or could reasonably be linked with an individual or their household. This includes information like your name, email address phone number, online identifiers such as cookies, your browsing history, geolocation information and inferences drawn from these types of information. For a list of personal information that we collect, please refer to the Privacy Policy.

4. How long will it take t complete my request? We will respond within 45 days of your request. If we need more time, we may take a one-time extension for an additional 45-days to complete your request. We will let know if we need to do this.

• What is Cookie Synching and why is it used?

Cookie synching is used to help us match our customer’s online identities with identifiers used by our trusted partners. This is completed to help us facilitate a more relevant and personalized ad experience for our customers based on the items that they might be interested in purchasing on this website and others that they might visit.

• What are my rights regarding non-discrimination?

ELOQUII 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. If you ask us to delete your data, you may not be able to participate in certain programs or services which require use of your personal information to function.

• How will exercising my rights affect my participation in loyalty programs?

Personal information is collected and used to offer you rewards or loyalty programs. If you exercise your rights to delete or opt-out, you may not be able to participate in these programs because we no longer retain your information. Please know that the value of the information you provide to us is directly related to our ability to provide your rewards. More on ELQ Rewards here.

• What is a sale or share of personal information for non-monetary consideration?

California adopted a new law, the California Consumer Privacy Act, that defines the sale of personal information as the sharing of personal information to another business or third party for monetary or other valuable consideration. In other words, any time we are compensated for sharing your personal information with another company, or if the third party uses the personal information for any purpose other than to provide the service for which we shared it, California considers that a sale. We haven’t sold your personal information for monetary consideration, but we do benefit from sharing your information in two scenarios, advertising technology and when we share data within our corporate family of companies.

 Advertising Technology:We partner with advertising companies (like third party ad servers, advertising agencies, technology vendors, providers of sponsored content, research firms, and other companies) to improve our site’s performance and appeal and help us to provide more customized advertising and marketing for our customers. We give pseudonymous information (such as device identifier, type of device, IP addresses, cookies and other information associated with your browsing) to the advertising companies and allow them to use it to refine their online marketing models and algorithms. In turn, the benefit we receive is that we can better reach the audience we want to market to, which may lead to better revenue for us because we’re serving more effective ads.

 Sharing Within Our Corporate Family of Companies:We’ve always shared personal information within our family of companies which allows us to better understand our customers and provide better products and services. However, under the CCPA, because most of our companies are separate legal entities, some of the sharing we do for the benefit of all our companies is considered a sale.

In both instances, we’ve always disclosed how we share your personal information in our privacy policy. Our practices have not changed, the only difference is the definition of sale in California state law.

• What is the process for verifying my identity?

1. Why do I need to verify my identity?

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

2. What personal information do I provide to verify my identity?

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

a. First Name*

b. Last Name*

c. Middle Initial

d. Email Address*

e. Phone Number

f. Address*

3. How do you verify my identity?

We may verify your identity in a few different ways. We’ve partnered with Experian 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 step.

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.

4. 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 access or delete your information.

• CCPA – What should I know about designating an authorized agent?

1. Who is considered an authorized agent?

An authorized agent is a person who has authorization to request to access, delete or opt out of the sale of personal information on behalf of another person.

2. Do I need anything to submit a request on behalf of someone else?

a. If you are an individual submitting a request on behalf of another person, we require a signed affidavit and a valid power of attorney to submit a request as an authorized agent. Email consumerprivacy@wal-mart.com to receive the Individual Authorized Agent Affidavit.

b. If you are a business submitting a request on behalf of another person, we require you to provide a copy of the authorization you received from the resident and the completed Business Entity Authorized Agent form. Email consumerprivacy@wal-mart.com to receive the Business Entity Authorized Agent form.

3. How do I send you my documentation?

You can email your forms to consumerprivacy@wal-mart.com. Please note, you will have 10 days to provide all required documentation.

*required field

This privacy policy was last updated January 1, 2020.

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