Privacy Policy Last updated May 24th, 2018

Moda Operandi, Inc. ("we," "us," or "our) created this Privacy Policy because we care about your privacy and we understand that you want to know how the information you provide to us is used, stored, and shared. This Privacy Policy describes how we gather information from you when you visit the Moda Operandi, Inc. website located at www.modaoperandi.com (the "Site"), access our Mobile App (the "Mobile App"), or purchase our products and services ("Products" and "Services") through the Site.

By visiting our Site, accessing our Mobile App, or purchasing our Products you are accepting the practices described in this Privacy Policy and the accompanying Terms and Conditions. Capitalized terms not defined in this Privacy Policy have the meaning ascribed to them in the Terms and Conditions.

The Information We Collect and Share

Contact and Registration Information

We collect contact information on our Site and Mobile App from visitors and customers who wish to obtain information or support, or to purchase our Products. The contact information you will be asked to provide may include first name, last name, address, telephone number, and e-mail address ("Contact Information"). The Contact Information is used to establish an account, provide the requested Service or information, and to contact prospective and current customers for purposes of direct marketing of our current and future products and services. Such direct marketing shall be sent in response to a request from you to receive marketing emails, newsletters of similar communications, or when you have purchased Products or Services, or expressed interest in such Products or Services (e.g., attending a Showroom or Customer Acquisition Appointment). Customers will also be asked to provide their name and email address in connection with booking a Showroom or Customer Acquisition Appointment.

Billing Information

If you wish to purchase a product or service through the Site, you will be required to provide certain additional information which may include a credit card number, expiration date, card verification value, and similar information ("Billing Information"). Billing Information is collected and processed by our third-party payment processor operating as our agent. Moda Operandi does not directly obtain or process any Billing Information.

Customer CRM Data

We use a variety of tools for marketing purposes. Our B2C customer relationship management database (such as Oracle Responsys or Zaius), manages the storage of customer email addresses and will collect your email address, name, and products currently in your shopping cart in order to create and optimize targeted marketing campaigns. Our sales team uses an internal CRM system, "Stylist Suite", to access order history information as well as product and interaction preferences. Any personal data provided to/or collected, will be used to provide our products and services in accordance with this Privacy Policy. You may request Moda Operandi to manually remove your account information from either platform. To submit a request, please contact privacy@modaoperandi.com and allow us a reasonable time to process your request.

Opt-Out for Direct Marketing; Email Management

You may opt out at any time from the use of your personal information for direct marketing purposes, and/or the transfer of your personal information to third parties for direct marketing purposes by emailing the instructions to privacy@modaoperandi.com . Please allow us a reasonable time to process your request.

You may also manage your receipt of marketing and non-transactional communications by clicking on the "Unsubscribe" link located on the bottom of any Moda Operandi marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional e-mails related to the Site. Please allow us a reasonable time to process your request.

Third-Party Analytics Providers

We use one or more third-party analytics services (such as Google Analytics, Google Optimize and Zaius on the Site and Mobile App) to evaluate your use of the Site and Mobile App, compile reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Site and Mobile App you visit, number of links clicked, search terms and other similar usage data), and analyze performance metrics. These third parties use cookies and other technologies to help collect, analyze and provide us reports and/or data. By accessing and using the Site and Mobile App, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt-out from certain data collection, please visit the sites below. Please be advised that if you opt-out of any service, you may not be able to use the full functionality of the Site and the Mobile App. We may also use a data collection automation and marketing reporting service (such as Funnel.io) for the purposes of automating and centralizing access to our third-party provider data.

For Google Analytics, please visit: https://www.google.com/analytics .

For Zaius, please visit: https://www.zaius.com/privacy-policy/

Remarketing

We partner with the third party advertising companies and marketing organizations listed below to either display advertising on our Site or to manage our advertising on other sites. Our ad network partners use cookies and web beacons (pixels) and may collect data, typically associated with online identifiers, including your email, email hash, user id, session id, cookie id, browser type, mobile device, referring url, member id, city country, demographic data, and information about your activities on this and other web sites to provide you targeted advertising based upon your consumer profile. We use Tealium as our tag management system (tags are another name for web beacons or pixels, which enable us and third parties to recognize cookies on your browser). For more information about Tealium, including how to opt out from certain data collection, please visit https://tealium.com/.

Below is a list of remarketing/advertising providers that we use; however, such list may be subject to change based on the campaigns that we run. We will endeavor to update this as much as possible. You may use the link next to the companies listed below to learn more about them and, if available, how to opt-out from such company serving you targeted ads. Please note this does not-opt you out of being served advertising generally. You will continue to receive generic ads].

Advertisers

How to Opt-out from Interest-Based Advertising

You may learn more about interest-based advertising from the below links; further, provided that any such company is a member of the below self-regulatory bodies, you may be able to effectuate your opt-out here as well:

Onward Transfers to Third Parties

Moda Operandi, like many businesses, sometimes hires other companies to perform certain business-related functions. We may disclose personal information to our affiliates and subsidiaries that assist in providing the Services or supporting our Site and the Mobile App. We may disclose personal information to certain third party companies (some of which described above) but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: database management/backup services, shippers (3PLs), mail centers, promotional and marketing partners, sweepstake and contest operators, advertising, payment processing services, customer service, hosting services, IT support services, and sales and customer support companies. These companies are authorized to use your personal data only as necessary to provide these services to us.

Aggregate Data

In an ongoing effort to better understand our users and our Site and Mobile App, we might analyze your information in aggregate form in order to operate, maintain, manage, and improve the Site, the Services, and the Mobile App. This aggregate information does not identify you personally.

We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and the Site to current and prospective business partners and to other third parties for other lawful purposes.

Customer Profiles

We use the information we have about your past purchases to create customer profiles. We use these profiles to deliver personalized user experiences. You may opt out at any time from the use of your personal information for segmentation and profiling purposes, and/or being provided a different customer experience based on your profile by emailing privacy@modaoperandi.com. Please allow us a reasonable time to process your request.

Disclosures to Public Authorities

Moda Operandi is required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, we expect that information that we have collected, including personal information would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon Moda Operandi and its legal successors in interest.

Information Posted On Public Forums

We feature or may in the future feature public forums such as blogs, chat rooms, message boards, bulletin boards, user reviews, virtual closets, and similar activities where you and other users of our Site can communicate with one another (collectively, "Public Forums").You may voluntarily post and share information through the Public Forums available from time to time through the Site, the App, and the Services. NONE of the information you provide to through the Public Forums or through use of these features are protected by this Privacy Policy including any personal information. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE VIEWED, COLLECTED, USED, MODIFIED AND/OR DISCLOSED FOR ANY PURPOSE BY MODA OPERANDI, ITS AFFILIATES AND SUBSIDIARIES, ANY USER OF THE SITE, THE APP OR THE SERVICES, AND THE PUBLIC.

You should think carefully before disclosing any information in any Public Forum on our Site.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as permitted under applicable law.

Your Rights

Upon request to privacy@modaoperandi.com, with the subject line, "Privacy Rights", we will provide you with confirmation as to whether we are processing your personal data, and have the data communicated to you within a reasonable time. You have the right to access, correct, amend or delete your personal data where it is inaccurate or has been processed in violation of this Privacy Policy. Please allow us a reasonable time to respond to your inquiries and requests.

California Residents

Under California Civil Code Section 1798.83, California residents who have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship with (and are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties if you wish to submit a request pursuant to Section 1798.83, please contact Moda Operandi via email at privacy@modaoperandi.com. In addition, Moda Operandi does not monitor or recognize or honor any "do not track" mechanisms or signals.

Children

The Site is not directed to children under the age of 13. We adhere to the Children's Online Privacy Protection Act ("COPPA") and will not knowingly register or otherwise collect personal information from any child under the age of 13. We ask that minors under the age of 13 not submit any personal information to us. If you have reason to believe a child under the age of 13 has provided us with personal information, please contact us as described in the "How to Contact Us" section below and request that such information be deleted from our records.

Links to Other Websites

The Site may contain links to third-party websites. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms and conditions when visiting any other websites.

How we Protect your Information

Moda Operandi takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.

Single Sign-On

Our web site includes social media features, such as the Facebook Like button and widgets, such as the ShareThis button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our web site. Your interactions with these features are governed by the privacy policy of the company providing it.

Changes to Our Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this policy. We may change this Privacy Policy from time to time, and will post any changes on our Site as soon 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 be aware that, to the extent permitted by applicable law, our use of information is governed by the Privacy Policy in effect at the time we use the information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you wish to contact us about this Privacy Policy, you may reach us by email at privacy@modaoperandi.com with the subject line, "Privacy Policy."