1. OVERVIEW

This privacy policy (“Policy”) applies to Diva Lure Co., Ltd. and its subsidiary and affiliate companies (collectively, “Diva Lure,” “we,” “us,” or “our”). We strive to deliver outstanding products and services and value our customers’ business and loyalty. We recognize that privacy is an important issue. We developed this Policy to explain our practices regarding the personal information we collect from you or about you on this website or via apps, through written or verbal communications with us, when you purchase our products through partners, or from other sources.

By accessing or using our websites or mobile applications (“apps”) or submitting information to us, or otherwise agreeing to this Policy, e.g. in the context of registering for any of our products or services, you understand and consent to our collection and use of your personal information as described herein.

2. What Information We Obtain

Information you provide when you use the Digital Services, including when you sign up for newsletters, order subscriptions, create an account or register for a membership through the Digital Services. This may include your contact, payment or demographic information. Information you submit when you choose to participate in a survey, sweepstakes, contest, promotion, event or similar initiative. Information you give us about others, such as a friend’s contact information when you order a gift subscription.

Information collected by automated means such as cookies or pixels. This may include information about your device and browser, including IP address or mobile device advertising identifiers, as well as information about how you and others use, interact with or respond to the Digital Services. This collection may take place while you are using a Digital Service or while the Digital Service is running in the background of your device.

Precise location information associated with your device when location services are active. Information we obtain from other sources, such as business partners, data suppliers and social media platforms.

3. PERSONAL INFORMATION FROM OTHER SOURCES

We may collect personal information about you from a number of sources in addition to those means of collection indicated above including offline or through sources unrelated to your receipt of our websites or apps. For example, from publicly accessible sources (e.g., property records); directly from a third party (e.g., credit reporting agencies or customer due diligence providers); or from a third party with your consent (e.g., your bank). We may merge or co-mingle that personal information with the personal information we maintain about you and other data collected on or through our website.

4. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION
We collect your personal information for the following reasons:

Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
Debugging to identify and repair errors that impair existing intended functionality;

Short-term, transient use, provided the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;

Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on our behalf;

Undertaking internal research for technological development and demonstration; and

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

5. LIMITED USE

We will only use your personal information for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.

If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.

PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.

6. HOW WE SHARE PERSONAL INFORMATION

In order to provide you with the best products and services, we share your personal information among our affiliates, service providers, and other third parties as described in this section.

Related Organizations. We may share some or all of your personal information with parent and subsidiary companies and companies under shared corporate control for the purposes described in Section 4 above.

Service Providers. We may from time to time use business partners, suppliers, and sub-contractors (“Service Providers”) to assist us with the provision of services to you (for example, without limitation, website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or improvement of services). These Service Providers have access to your personal information only to perform the respective tasks assigned to them on our behalf, and are obligated not to disclose or use it for any other purpose.

Compliance with Laws. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your personal information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary to comply with any legal obligation, enforce or apply our terms and conditions, respond to claims and legal process, protect our services, members, dealers, our rights and/or the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

Sale or Transfer of Business or Assets. We may share or transfer some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction, or proceeding involving sale, transfer, divestiture, termination or transfer of all or part of one or more license or other agreement(s) regarding the Diva Lure brand, disclosure or another transaction under which a third party assumes control of all or a portion of our business or assets. In the event of any of the foregoing or in any insolvency, bankruptcy, or receivership, personal information may be transferred as a business asset. If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.

Other Legitimate Business Purposes. We may also disclose your personal information when it may be necessary for other legitimate purposes as reasonably determined by us, in which case we will notify you of such use via telephone, email, and/or a prominent notice on our website.

7. COOKIES AND OTHER TRACKING TECHNOLOGIES

The tracking technologies we utilize include the following:

Cookies. We may use different types of cookies when providing different types of web-related services. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable important service features. We use both session ID cookies and persistent cookies. Session ID cookies are used to maintain your browser state as you browse through services, and they expire when you close your browser. A persistent Cookie remains on your hard drive for an extended period, and we use that to identify you should you return to services and want to find information you had previously entered or accessed.

We also contract with analytics services, third-party affiliate services, and third-party advertising companies to collect similar information. These cookies allow the ad servers to recognize your computer each time they send you an online advertisement and compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

You may disable cookies through your web browser. For information about opting out of these collection services, please see the section titled Your Choices below.

Web Beacons/Tags. We automatically collect aggregate anonymous information through files embedded in our services and emails known as “web beacons.” We may deliver a web beacon to you through our services from an advertising network with which we have contracted. Web beacons allow third parties to provide anonymized and aggregated auditing, research, and reporting for us. Web beacons also allow us to send email messages in a format users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by web beacons to personal information.

Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash cookies are different from browser cookies because of the amount and type of data and how the data is stored. The cookie management tools provided by many popular browsers will not remove Flash cookies. To learn how to manage Flash cookie privacy and storage settings, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html .

Analytics. We may use analytics tools or similar tools provided by third parties to help analyze how you and other users utilize our services. Analytics tools use cookies and other tracking technologies to collect information such as how often users visit services, what pages they visit, and what other websites they used prior to visiting our services. We use the information we get from analytics tools only to improve services. Analytics tools collect the IP address or other unique identifier assigned to you on the date you visited services. We do not combine the information generated through the use of analytics tools with your other personal information. Analytics tools provided by third parties plant a persistent cookie on your web browser to identify you as a unique user the next time you visit our website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy. To learn about how Google use data related to website analytics when you use our site or apps, click here: https://policies.google.com/technologies/partner-sites.

YOU GIVE CONSENT FOR US TO SHARE YOUR DATA WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU SERVICES.

8. YOUR CHOICES

You have the following choices with respect to the personal information we hold about you. To protect your privacy and security, we may take reasonable steps to verify your identity before granting requests to access, alter, or delete your personal information.

Access or correct your personal information. You can access a variety of your personal information that we collect by accessing your respective account, by phone, email, or in writing using the information provided in the Contact section below.

Deleting your personal information. You may ask us to delete your personal information at any time by phone, email, or in writing using the information provided in the Contact section below. Please note we may maintain some portions of your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements. We will delete or de-identify all your personal information as described in this subsection 10.2 within 30 days of your request for deletion.

9. OPTING OUT

You can make the following choices regarding your personal information:

Promotional and Other Emails. You may choose during the account registration processes on one of our websites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our services. You can stop receiving these emails by sending a request to the email address in the Contacting Us section below. If you decide not to receive these emails, we may still send you communications related to your current or former membership.

Behavioral Advertising. Our services may use behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our website, or on other websites not operated by us. If you do not want third parties who collect information about your use of our services, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.

PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

Analytics. Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files you may clear the opt-out cookie.

You may learn more about the use of information by, and opting-out of analytics from, our third-party analytics providers by visiting its opt-out page at the following links: www.google.com/policies/privacy/partners/

Cookies. You may disable, or delete cookies in your Web browser, but doing so may impact the usability of the website. To block cookies, you can also browse our service using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari, etc.).

10. INTERNATIONAL TRANSFERS OF INFORMATION

Your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding personal information may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach or other use that is prohibited in your country. By submitting your personal information, you agree to this transfer, storage and/or processing, including all associated risks.

11. EXERCISING YOUR PRIVACY RIGHTS

When exercising the rights or options described in this Policy, the following guidelines apply:

No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

What we may need from you. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

12. INFORMATION SECURITY

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. We make efforts to protect your personal information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If you have questions about the security of your personal information, contact us at the email or regular mail address specified in the Contact section below.

13. DATA RETENTION

We will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

14. THIRD-PARTY LINKS

Our websites or apps may contain links to other websites or apps. We are not responsible for the privacy practices or the content of these other websites or apps. You should read the policy statement of these others websites or apps to understand their policies. When you access a linked websites or apps, you may be disclosing private information. It is your responsibility to keep such information private and confidential.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time, in our sole discretion. When we do so, we will post the new Policy on our website. You should consult this Policy regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.