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PRIVACY POLICY

INTRODUCTION

Ethika, Inc. (“us,” “we,” or “Company”) is committed to respecting the privacy rights of its customers, visitors and other users of the Company websites (collectively, the “Website”). We created this Website Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the Website, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Website, and not to any other websites that you may be able to access from the Website, each of which may have data collection, storage and use practices and policies that differ materially from this Privacy Policy.

INFORMATION COLLECTION PRACTICES

TYPES OF INFORMATION COLLECTED

Traffic Data Collected

We may automatically track and collect certain categories of information when you visit our Website, including, but not limited to: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Website; (4) domain name and Website access times; and (5) types of web browsers used to access the Website (collectively, “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Website. We also use “cookies” to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Website.

Personal Information Collected

In order for you to access certain premium, services and to purchase products that we offer via the Website, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes, but is not limited to, the following categories of information: (1) Contact Data (such as your name, mailing address, and e-mail address); (2) Financial Data (such as your account or credit card number); and (3) Demographic Data (such as your zip code, age, and income). If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards or forums, or otherwise complete online forms, surveys or contest entries, any information provided in such communication may be collected as Personal Information.

USES OF INFORMATION COLLECTED

Company Use of Information

We use Contact Data to send you information about our company or our products or services, or promotional material from some of our partners or affiliates, or to contact you when necessary. We use your Financial Data to verify your qualifications for certain products or services and to bill you for products and services. We use your Demographic Data to customize and tailor your experience on the Website, displaying content that we think you might be interested in and according to your preferences.

Sharing of Personal Information

We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Demographic Data with advertisers and other third parties only on an aggregate (i.e., non-personally-identifiable) basis. We share Contact Data with other companies who may want to send you information about their products or services, unless you have specifically requested that we not share Contact Data with such companies. We also share Contact Data and Financial Data with our business partners who assist us by performing core services (such as hosting, billing, fulfillment or data storage and security) related to our operation of the Website. Those business partners have all agreed to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to Company. If you do not want us to share your Contact Data with any third parties, please email us at privacypolicy@ethika.com or select the “opt out” box on our online forms, but please understand that such a request will likely limit your ability to take advantage of all of the features and services we offer on the Website. In addition, we maintain a procedure for you to review and request changes to your Personal Information; this procedure is described in below.

User Choice Regarding Collection, Use and Distribution of Personal Information

You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Website; however, you will not be able to access and use those portions of the Website that require your Personal Information. If you do not wish to receive information and promotional material from us or from some of our partners, you may select the appropriate “opt-out” option each time we ask you for Personal Information.

CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms & Conditions. Your Personal Information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit you Personal Information via secured and encrypted channels if you use a similarly equipped web browser.

User Ability to Access, Update and Correct Personal Information

We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may visit your personal profile. Through your personal profile you may: (a) review and update your Personal Information that we have already collected; (b) choose whether or not you wish us to send you information about our company, or promotional material from some of our partners; and/or (c) choose whether or not you wish for us to share your Personal Information with third parties.

Lost or Stolen Information

You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.

Public Information

The Website contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information.

CHILDREN'S PRIVACY

The Website may include features or material that may be appealing to children under the age of 13. We are strongly committed to protecting the safety and privacy of children who visit our Website. We do not knowingly collect personal information online from children under 13 and have adopted techniques to age-screen users on our Website to ensure compliance with this Privacy Policy and the Children's Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations under United States federal law protect the privacy of children using the Internet. Our Website may include material and features that we believe to be unsuitable for children under 13 and which are not necessarily monitored. We strongly encourage all parents to talk to their children about online safety and to monitor their children’s use of the Internet.

VISITORS AND SUBSCRIBERS OUTSIDE THE UNITED STATES

Our Website and the servers that make the Website available worldwide are located in the United States. The Internet laws in the United States govern all matters relating to the Website. Any information you provide in subscribing to our Website or registering or ordering at our Website will be transferred to the United States. By visiting our Website and submitting information, you authorize this transfer, processing and use. We adhere to the US-EU Safe Harbor Privacy Principles (“EU Safe Harbor”) with respect to certain personally identifiable information that we receive from customers and employees in the European Union. We have various other business units, service offerings and data collections which are not covered by this Privacy Policy, nor by our participation in the EU Safe Harbor, and we make no EU Safe Harbor representations with respect to any data collected or used in these business units, service offerings or data collections. For further background about the EU Safe Harbor, please refer to the U.S. Department of Commerce’s Website at http://www.export.gov/safeharbor.

CHANGES IN CORPORATE STRUCTURE

In developing our business, we may engage in the sale of certain assets and the company itself, or parts of it, may be sold, merged or otherwise transferred. In such transactions and changes in ownership, user information, whether personally identifiable or otherwise, may constitute one of the transferred assets. We will use commercially reasonably efforts to notify affected users in accordance with the procedure for changing this Privacy Policy described below.

UPDATES AND CHANGES TO PRIVACY POLICY

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Website and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Website.

CONTACT INFORMATION

If you have any questions about this Privacy Policy or our privacy practices, please e-mail us at privacypolicy@ethika.com. Please include the URL of the Website and/or specific page within the Website involved in your request.

Or you can contact us by mail at:

1001 Avenida Pico, Ste. C-525
San Clemente, CA 92673
Attn: Privacy Policy Department