PRIVACY POLICY

KOLO.COM
PRIVACY POLICY

Last updated: May 25, 2018
Your privacy is important to Kolo Retail LLC (“we” or “us”), the owner and operator of this kolo.com website and the service provided thereby (all together, the “Service”). To better protect your privacy, we provide this statement explaining our online information practices and the choices you can make about the collection and use of the personally identifiable information that you decide to submit using our Service.

This Privacy Policy covers:


WHAT INFORMATION DO WE COLLECT?
Information that you give us.

Please do not include or send us any sensitive financial, medical or confidential information, such as any person’s social security number, passport number, bank account or credit card numbers or passwords or medical conditions, diagnoses or prescriptions. We do not require such information to provide the Service, we cannot assure protection of such information, and we disclaim all liability for the use or dissemination of such information to the fullest extent permitted by law.

We do not receive or retain any credit card account information that you provide to pay for goods or services purchased via the website. Such information is sent directly to one or more third party credit card payment processors.
 
Information about other people.
In connection with your use of the Service, you might provide personally identifiable information to us that belongs to another person (for example, if you purchase a gift for a friend and provide her name and address with instructions to ship the package directly to her). We presume that if you provide such information to us, you have sufficient permission from that person to do so.
 
Information that you post to online forums, comment boards or other public spaces.
We do or might collect content and information that you post via online forums and communities (for example, photos you post to an area for people to see them, or comments you post in a comment forum in response to one of our posts).

Other information that you provide to us.

We do or might collect any other information and data that you send or communicate to us, including email correspondence, snail mail correspondence, and discussions over the telephone.

Information that we get from other third parties.
We do or might collect information from third parties about you. We might combine or use this information with information that we collect from you or from third parties.

Information that we collect automatically.

We do or might collect certain information automatically when you use our Service, such as (but not limited to):

In addition, if you use our Service via a mobile device (for example, a smart phone or a tablet), we also do or might collect your unique device identifier and mobile device IP address (or MAC address), as well as information about your device’s mobile carrier, and mobile Internet browsers, information concerning your geographic location, and other information described in this Policy.

HOW DO WE USE THE INFORMATION WE COLLECT?
We do or might use the information we collect to:

We also might use it in manners that you have confirmed is acceptable to you.


User Generated Content is Public Information.
The Service might enable you to post content and information to it via its online forums and communities (for example, photos you post to an area for people to see them, or comments that you post in a comment forum). Social media sites, plug-ins and other applications also can enable you to create and submit content concerning our Service. Remember that all of these posts are public and can be seen by and shared with everyone. We cannot prevent or be responsible for such uses. Some social media sites, plug-ins and other applications enable you to adjust your privacy settings, but we don’t monitor or control them or how well they work. Please check those privacy policies and instructions for more information on how your information is used and handled.

If you submit content for publication, we may publish and use your screen name and other information you have provided to us, whether such publication and use is via our Service, the Internet, or elsewhere.

HOW LONG DO WE RETAIN THE INFORMATION THAT WE COLLECT?

[Kolo to comment: We retain your personal information for as long as is reasonably necessary to provide the Service, process and verify orders, exchanges and refunds, and provide customer service.]

Please see below YOUR RIGHTS TO YOUR INFORMATION to learn how to ask us to erase your personal information.

HOW DO WE SHARE AND DISCLOSE THE INFORMATION THAT WE COLLECT?
 
Service providers
Our agents and contractors do or might have access to personally identifiable information to help carry out the services that they are performing for us in connection with our business and providing the Service. We make reasonable efforts to assure that such third parties will honor this Privacy Policy, including by obligating them to do so in our agreements with them.

Third party marketers
We do or might share personally identifiable information with business partners and third parties (for example, other marketers, websites, advertisers, and commercial and not for profit organizations) that want to market products or services to you. We provide you the opportunity to “opt out” of (stop) use of your personally identifiable information for such marketing purposes. Please see the section below called “You can opt out of receiving marketing communications” for details.]

Linked sites
Our Service does or might contain links to third party websites and services whose information practices are or might be different from our own. We are not responsible for, do not vouch for, and have no control over the third parties who might be receiving or collecting information from or about you. Please refer to those third parties’ privacy policies and statements before submitting any information.
 
Sponsors and co-promotions

We do or might offer content or services that are sponsored by or co-branded with identified third parties. As a result, such third parties might obtain personally identifiable information that you provide in connection with such content or services. We are not responsible for, and we do not monitor or control, information provided to or collected by such third parties.

Ad Servers
Third parties (for example, Google) do or might present or serve advertisements, provide us with data collection, reporting, ad response measurement, and Site analytics, and assist with delivery of marketing messages and advertisements. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. They may also obtain information about other applications that you have downloaded to your device, the websites you visit, and other information about you or your device in order to help analyze and serve anonymous targeted advertising on the Site and elsewhere. These third parties also may view, edit, or set their own cookies (we explain cookies below). For more information about third party ad servers at our Site and your ability to opt out of targeted advertising from such third parties, please visit the Network Advertising Initiative and/or the Self-Regulatory Program for Online Behavioral Advertising.

Your opting out of targeted advertising via these programs is intended to stop certain targeted advertising, but still will allow the collection of usage data for some purposes, including research, analytics and internal operations. We are not responsible for the operation of these opt out mechanisms and does not assure that they will work.

Legal and law enforcement purposes
We may disclose personally identifiable information in response to legal process, for example in response to a court order or a subpoena, or in response to requests from law enforcement or other government agencies. We also may disclose such information to third parties in connection with fraud detection and prevention activities, or when we believe it is necessary or appropriate to investigate, prevent, or take action regarding known, suspected or anticipated (i) illegal activities or fraud, (ii) harm or threats to the safety and well-being of any person or property, (iii) violations of our Terms of Service, or (iv) violations of our rights, or the rights of others, or violations of law.

Transfer of our business
We may transfer all information about you in connection with a transaction for the sale or transfer of our company, business, or assets. Such a transaction might be (but is not limited to) a merger, acquisition, asset sale, dissolution, bankruptcy, reorganization, or reincorporation.

COOKIES, WEB BEACONS AND OTHER TRACKING TOOLS.
We and our third party service providers and business partners may send “cookies” to your computer or device or use similar technologies to enhance your experience at our Service. “Cookies” are files that can identify you as a unique user and store your personal preferences as well as technical information (including click through and click stream data). Cookies manage and measure the performance of advertisements displayed on or delivered by or through us

and/or other networks or sites. We do or might use “persistent” cookies (which remain on your computer until you delete them) or “temporary” cookies (which remain only until you close your browser).

We also might use web beacons. These are small strings of code or techniques that deliver a graphic image on a web page for the purpose of transferring data, such as (i) the IP (Internet Protocol) address of the computer that downloaded the page on which the web beacon appears, (ii) the URL (Uniform Resource Locator) of the page on which the web beacon appears, (iii) the time the page containing the web beacon was viewed, (iv) the type of browser that fetched the web beacon, and (v) the identification number of any cookie on the computer previously placed by that server.

Our Service also might use locally stored objects (sometimes referred to as “Flash cookies”) to provide certain content, such as video on demand, video clips, or animation. Adobe’s Flash player and similar applications use this technology to remember settings, preferences, and usage similar to browser cookies. Flash cookies are not managed through your web browser, but you can access your Flash management tools from Adobe’s web site (which website we do not monitor, administer or control).

When corresponding with you via HTML capable email, web beacons tell us whether you received and opened our email.

On their own, cookies or web beacons generally do not contain or reveal any personally identifiable information. However, if you give us personally identifiable information, that information can be linked to the data stored in the cookies or web beacons.

You may adjust your browser to reject cookies from us or from any other web site. Additionally, by setting your web browser to display HTML emails as text only, you may be able to prevent the use of some web beacons. Please review the “Help” section of your browser for more information. Certain Service areas and features might be accessible only with cookies or similar devices activated. As such, your decision to limit or disable cookies or similar devices could adversely affect your ability to use or access certain Service areas and features.

OUR SERVICE CURRENTLY DOES NOT RESPOND TO DO NOT TRACK (DNT) SIGNALS.

Some browsers enable its users to send a “Do Not Track” (or DNT) signal to a website visited by the user to request that the website disable tracking of the visiting user. Our Service currently does not respond to DNT signals.

OUR REASONABLE EFFORTS TO PROTECT YOUR PRIVACY ARE NOT PERFECT
We try to follow reasonable physical, electronic, and managerial procedures designed to safeguard the information that we collect online at the Service. However, we cannot and do not guarantee or assure you that personally identifiable information that we collect will never be stored, transmitted, disclosed or otherwise used in a manner inconsistent with this Privacy Policy.
  
INTERNATIONAL INFORMATION TRANSFER  

We intend our Service for use solely by users located within the United States. We rely on third parties to provide services and otherwise enable us to provide the Service to you. We cannot control how or where such third parties route, process or store information and data. If you use the Service, you consent to the collection, processing and storage in the United States and elsewhere of your information.

We have not certified with the U.S. Department of Commerce’s Safe Harbor Program to address data transfers from the European Union and Switzerland. U.S. data protection and privacy regulations may not offer the same level of protection as in other parts of the world. We do not assure that your information will be stored, shared or used only within the U.S. 

WE DO NOT PERMIT SPAM OR SPYWARE

We don’t permit use of spam, spyware, malware, or anything else that we do not intend our Service to provide. We don’t send emails to anyone without their permission. If you believe that you have received an unsolicited email from us or encountered spyware or malware on our Service, please write us at privacy@topdrawershop.com so that we can investigate.

INFORMATION REGARDING CHILDREN
The Service is not marketed to or intended for anyone under 18 years old, or anyone under the legal age of majority in his or her state, country or other jurisdiction of residence. Such individuals must not use the Service. We do not knowingly or willingly collect information or data from individuals under such age. If you believe that we inadvertently have collected such information from you, please alert us to such circumstance.

WHAT ARE YOUR CHOICES?

You can “opt out” of receiving marketing communications.
You can “opt out” of receiving (that is, stop) marketing communications from us and from our third party marketers. You can update your preferences for receiving or not receiving marketing communications from us and from third parties by (i) clicking the “unsubscribe” link provided in marketing emails you may receive and following those instructions; or (ii) sending to privacy@topdrawershop.com an email stating UNSUBSCRIBE from your email account to be unsubscribed.

Please allow a reasonable time for our Service to receive and give effect to your updates.

Even if you opt out of receiving marketing communications, we still may use your information to contact you for non-marketing purposes if and as they relate to your use of the Service (for example, for matters concerning your use of the Service, your merchandise orders, exchanges and refunds, updates to our Kolo.com Terms of Service and this Privacy Policy, and other administrative matters).

We do or might share non-personally identifiable information with third parties from time to time as we choose, with or without notice to you, and with no opportunity to opt out.

YOUR RIGHTS TO YOUR INFORMATION

We understand that you have rights in your personal information. We make reasonable efforts to allow you to access, correct or rectify, cause us to erase, or limit our use of your personal information.

Access.                       You may receive or ask us to deliver to another person a copy of the personal information we maintain about you.

Correction.     You may correct erroneous personal information that we maintain about you.

Erasure.         You may ask that we delete the personal information that we maintain for you, and we will make redo so to the

Limit use.      You may ask that we stop of limit use of the personal information that we maintain for you.

Please direct all such requests via email to privacy@ topdrawershop.com.

To help protect your privacy and security, we may take reasonable steps to help verify your identity before fulfilling such requests.

OUR PRIVACY POLICY UPDATES
From time to time, we might update this Privacy Policy. We will notify you about material changes in the way we treat personally identifiable information by placing a notice on our Service, by sending you an email message or SMS text message, or by some combination of these methods. Unless we specify a later date, changes are effective immediately as of the time of their posting. Please periodically check back and review this Privacy Policy to ensure that you remain up to date on our then-current privacy practices.

HOW TO CONTACT US 
If you have any questions or concerns about this Privacy Policy or its meaning or effect, please contact us at:

Email: privacy@topdrawershop.com

Traditional mail:

Attn: Privacy Policy
Kolo Retail LLC
745 Atlantic Ave.
Boston, MA 02111

YOUR PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS)

California’s “Shine The Light” law provides that California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the then-prior calendar year (e.g., any requests submitted in 2017 would receive responsive information concerning sharing activities occurring in 2016).

To obtain this information on behalf of Kolo Retail LLC’s U.S. operations, please send an email message to privacy@topdrawershop.com with "Request for California Privacy Information" as the subject line, and please also place that phrase at the top of your email message. We will send email containing the requested information to the email address from which you write us. Only information sharing within the "Shine the Light" law’s requirements will be included in our response.