Effective Date: September 1, 2018

PRIVACY POLICY

This Privacy Policy explains the privacy practices governing information collected through the SonalSystem website (www.sonalsystem.com) (the “Site”) owned and operated by SonalSystem, LLC (“SonalSystem”, “we,” “our” or “us”).

This Privacy Policy applies to the information we collect from or about you from:

• Your use of the Site;

• Your purchase of products available for purchase on the Site (“Products” and each, a “Product”);

• Your signing up for our email list and/or email updates through the Site (the “Email List”);

  and/or

• Your creation of an account through the Site, if/when we make that feature available.

  Please read this Privacy Policy carefully because when you submit information to or through the Site, you are consenting to the collection, processing and retention of your information as described in this Privacy Policy. If you have questions about the Privacy Policy, you can contact us at legal@sonalsystem.com

  If you do not agree with any part of this Privacy Policy, please do not use the Site.

I. Information We Collect

We collect information you voluntarily provide, as well as information that your computer, mobile phone, tablet, console or other device (collectively, “Device”) or browser provides automatically. We use cookies to make the Site perform better for you. You can opt out of the use of cookies, but if you do, some features of the Site will not work correctly. Keep reading to learn more.

When you interact with our Site, we, or our service providers (acting on our behalf), collect “Personal Information” (which is information that relates to you as an identifiable individual) that you provide to us, such as your first and last name, address, email address, and when necessary, credit card or bank information. We also collect content you make available through social media accounts or memberships with third parties. We collect this information when you:

• Purchase something from our store, as part of the buying and selling process;

• Make arrangements to return a Product you have purchased;

• Inquire about our Site;

• Create an account on our Site; or

• Sign up for an Email List or to receive our newsletter and/or advertisements.

  When you browse our Site, we also automatically receive your computer’s internet protocol (IP) address as well as other information that helps us learn about your browser and operating system (“Usage

Information”). Usage information includes your Device type, your unique Device identifier, your location, and the type of browser software and operating system you are using.

We, and/or our third party service providers, use “cookies” (data files placed on a Device when it is used to visit our Site) and other identifiers to collect Usage Information, for security purposes, to enable you to use the Site, to collect information regarding your preferences, to allow you to share content via social media when you are logged in to a particular platform, and to deliver relevant advertising to you.

For example, we use a tool called “Google Analytics” to collect information about use of this Site. Google Analytics collects information such as how often users visit this Site, what pages they visit, and what other Sites they visited prior to coming to this Site. We use the information we get from Google Analytics to improve this Site. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. To opt-out of Google Analytics, please use Google’s opt-out tool: https://tools.google.com/dlpage/gaoptout.

To learn how to reduce the number of cookies you receive, or delete cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser. You can also learn more about cookies by visiting https://ico.org.uk/for-the- public/online/cookies, which includes additional useful information on cookies and how to block cookies using different types of browsers.

The Site also contains “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).

The Site will also feature social buttons from networks such as Facebook, Twitter and Instagram. To do so we embed code that they provide and we do not control ourselves. To function their buttons generally know if you’re logged in. We do not have any access to that information, nor can we control how those networks use it.

If you access the Site via a mobile app, we use additional identifiers, such as the advertising ID provided by Apple or Android, for similar purposes.

Do Not Track. Currently the Site is not designed to respond to “Do Not Track” signals sent from your browser. For more information more about “Do Not Track,” please visit www.allaboutdnt.org.

II. How We Use Your Information

We use the Personal Information we collect about and from you:
• To perform our responsibilities under a contract we have with you. For example:

o If you buy a Product through the Site, we will need to use your Personal Information to process your order and to enable delivery; and

o We will need to use your Personal Information to perform our obligations under our website terms of use.

• When we have a legitimate interest to do so. For example: o To prevent fraud and protect the security of our Site;
o To enforce our Terms of Use;
o To communicate updates and improvements;

o To develop and optimize our products and services;

o To help us provide and operate the Site;

o To advertise and market to you, which includes displaying targeted ads, offers and content made available to you based on your interests and usage of the Site;

o To analyze the performance of the ads, offers and content on the Website, as well as your interaction with them; and

o To comply with our legal obligations.

• With your consent. For example:

o We send marketing communications to you only if you consent to receive them.

o We do not share your Personal Information with third parties for their direct marketing purposes without your consent.

• As otherwise required by applicable law.

If you consent to a particular use of your information and you change your mind, you may withdraw your consent at any time by contacting us at legal@sonalsystem.com or mailing us at the address below.

III. How We May Share Your Information

Service Providers. We may share your Personal Information with third parties that perform functions on our behalf (“Service Providers”) to carry out your requests, confirm, process, or fulfill your purchase(s) of Product(s), communicate with you, or make various features of the Site available to you. These Service Providers may help us to host or operate the Site, analyze data and/or provide website analytics, provide customer service, conduct marketing (including, but not limited to, email marketing), process payments, or administer surveys or questionnaires.

Our online store is hosted on Shopify Inc., which provides us with an e-commerce platform to sell our products and services. If you choose to pay with a credit card to complete your purchase, then Shopify stores your credit card data. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy .

We share your Personal Information with other service providers that we have engaged to perform business-related functions on our behalf. This includes service providers that: (a) conduct research and analytics; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) host the Site; (f) maintain databases; (g) send or support online or mobile advertising; and (h) otherwise support or help us provide the Site.

Business Transfers. We will share your Personal Information if we are acquired by or enter into a merger with another company, or otherwise reorganize our business. However, in such event, any acquirer of that information will be subject to the provisions of our commitments to you in this Privacy Policy.

Legal Disclosure. We may transfer and disclose information, including your Personal Information, to third parties to comply with a legal obligation or subpoena, when we believe in good faith that the law requires it, at the request of governmental authorities conducting an investigation, to verify or enforce our Terms of Use, Privacy Policy or other applicable policies, to respond to an emergency or otherwise to protect the rights, property, safety, or security of the Site, third parties, visitors to the Site or the public.

IV. Your Privacy Choices, Rights, and Access

You may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, to delete information we have collected and maintained about you, or not to send you newsletters, updates, emails or other communications by:

• sending us an email at legal@sonalsystem.com; or

• following the removal or unsubscribe instructions in the communication that you receive.

  If you wish to verify, correct, or update any of your Personal Information collected through the Site, or request access to all information that we have collected and maintain about you, you may contact us at the email or address included in the Contact Us section below. In accordance with our routine record keeping, we may delete certain records that contain Personal Information that you have submitted through the Site. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups or other technology- related reasons.

  If you are in the European Economic Area, you have certain rights related to the Personal Information we hold about you:

• Access. You have the right to access the Personal Information we hold about you. If you wish to obtain a copy or description of the Personal Information we hold about you, please contact us using the contact details set out below. We may ask you to verify your identity and to provide further details about your request.

• Accuracy/Rectification. We will do our best to ensure the Personal Information we retain about you is accurate. We may from time to time send you an email update to remind you to tell us about any updates or changes to your Personal Information. You have the right to request that any inaccurate Personal Information is corrected and any incomplete information is completed by contacting us using the contact details set out below.

• Deletion/Erasure and Processing Restriction Requests. You have the right to request that we delete Personal Information that we hold about you. You also have the right to ask us to stop processing your Personal Information, subject to certain exceptions. If you would like us to erase or stop processing the Personal Information that we hold about you, please contact us using the contact details set out below.

• Portability Requests. You have the right to request that we provide certain parts of your Personal Information to you or transmit it directly to another company that processes Personal Information. If you would like us to transfer your Personal Information, please contact us using the contact details set out below.

• Withdrawing Your Consent to Receive Marketing Messages. You may ask us to stop using your Personal Information for advertising or marketing purposes at any time. If you wish to do this, please follow the removal instructions in any communication you receive, or send us an email to legal@sonalsystem.com with “UNSUBSCRIBE” in the subject line.

• Damages. You may have the right to claim compensation for damages caused by our breach of any data protection laws.

  In addition, if you are in the European Economic Area and you have any complaints about how we use your Personal Information, you have the right to lodge a complaint with the data protection authority in

your country. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

For further information on each of the above-mentioned rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

V. Links to Other Websites

The Site may contain links to other websites, maintained by third parties. These links are provided only as a convenience to you. SonalSystem has no control over, and is not responsible for any content, products or services offered by or found on third party sites, or their privacy policies. Links to third party sites do not constitute an assumption of liability for or sponsorship, endorsement or approval of these sites or the content contained on these sites. The information practices on those websites may be different from ours and are not covered by this Privacy Policy. We encourage you to consult the privacy notices on those websites.

VI. Children

We do not knowingly collect information from children under 13 years of age. If we learn that a child under the age of 13 has provided us with any Personal Information without first receiving their parent or guardian’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site. We will then dispose of such Personal Information in accordance with this Privacy Policy. If you believe we may have any information from or about a child under the age of 13, please contact us at legal@sonalsystem.com.

VII. Accessing our Site Globally – Transfer of Data

The Site is governed by and operated in, and in accordance with the laws of the United States. We make no representation that the Site is governed by or operated in accordance with the laws of any other nation. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. The laws of the United States may not protect the privacy of your information at the same level as provided by the laws of your country. In an effort to safeguard individual privacy, we will only transfer personal information from the European Economic Area to the United States if one of the following applies: we have entered into an agreement using standard contract clauses (approved by the European Commission or a data protection authority) with our service provider or Affiliate regarding the transfer; the service provider that transfers the data is certified under the EU-US Privacy Shield Framework; another lawful data transfer mechanism is available; or you give your express consent to the transfer.

VIII. Storage of Your Information

We will generally store information associated with your account until it is no longer necessary to provide services to you, until you ask us to delete it, or until your account is deleted, whichever comes first; but there are some exceptions to this general rule. We will retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, process warranty claims, distribute important product information (such as recall information), enforce our agreements, and take other actions permitted by law.

You can request deletion of your Personal Information at any time by contacting us using the contact details set out below. Note: If you request that data we maintain about you be deleted or erased, no one (neither us nor you) will be able to recover that information later.

IX. Your California Privacy Rights

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). We comply with this law by giving users the ability to tell us not to share personally identifiable information with third parties for their direct marketing purposes. To make such a request, send an email to legal@sonalsystem.com. We may need additional information to process your request.

X. Security: We Cannot Guarantee the Security of the Site

We take seriously our obligation to safeguard the confidentiality, security and integrity of personal information collected from our users. As you can see, the Site uses an SSL (or “secure sockets layer”) certificate, which provides secure, encrypted communications between a website and internet browser.

We also have appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your Personal Information to those who have a genuine business need to know it. You should be aware, however, that no system is completely secure from hackers and network failure and error, and we cannot guarantee the confidentiality, security and integrity of information maintained on our Site for that reason.

In other words, although we will use all reasonable efforts to safeguard the confidentiality of your Personal Information, we cannot guarantee that your information will always be secure.

Email is not a secure form of communication. Please do not send us your credit card number, social security number or other Personal Information via email.

We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

XI. Changes

We may update and post revisions to this Privacy Policy from time to time and will update the Effective Date when we do so. If our Privacy Policy changes in a way that significantly affects how we handle your Personal Information, we will not use the Personal Information we currently maintain without providing you notice or obtaining your consent, where appropriate. We encourage you to review this page for the latest information about our privacy practices.

XII. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us by email at legal@sonalsystem.com or write us at:

SonalSystem LLC
6688 Nolensville Rd. Suite 108-133 Brentwood TN 37027
United States