Privacy Policy - Sulan Rouge

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we use and disclose your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

The website www.sulanrouge.com (the “website or “site”), is operated by Sulan Rouge, LLC (“we or “us”). We are registered with the State of Florida as a Seller of Travel Ref No. ST15578, California Seller of Travel No. 2090937-50, & Washington UBID No. 603189022.

This privacy policy aims to give you information on what information we collect through your use of this website, including any data you may provide through the website when you purchase a product or service and how that information is used and shared.

Changes to the policy – We may update this privacy policy from time to time, in our sole discretion, in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. You are advised to visit this page to see such changes. Your use of the site, and your continued use of the site after this privacy policy has been updated, indicates your agreement and acceptance of this privacy policy, including the modifications made as of the date of your use.

2. CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint or request any information about your personal data, please contact us by the following means:

Full name of Legal Entity: Sulan Rouge, LLC

Email: sulan@sulanrouge.com

Telephone: +1.727.685.7692

Mailing Address: 7901 4th St. N, St. Petersburg, FL 33709

Note that email communications are not always secure, so please do not include credit card information or other sensitive information in any email to us.

3. THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

· Contact Data includes billing address, delivery address, email address and telephone numbers.

· Financial Data includes bank account and payment card details.

· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

· Usage Data includes information about how you use our website and your interest in our products and services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

· Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

· order or express an interest in any of our products or services;

· request marketing to be sent to you; or

· give us feedback or contact us.

· Automatically. We may collect Technical Data and Usage Data, such as cookies, when you visit the site.

· Third Parties. We may receive Identity, Contact and Financial Data from your family, friends, and affiliates when completing forms or corresponding with us on your behalf regarding any of our products or services. Additionally, our partners and service providers, such as Easol in its capacity as our platform provider, may provide us with your Profile, Technical, Usage Data and Marketing and Communications Data.

We may combine information from different sources. For example, we may combine information that we have collected offline with information we collect online, or we may combine information we get from a third party with information we already have.

If you submit any personal data relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this privacy policy.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

· Where we need to comply with a legal obligation.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may share your information with the following entities:

· Third-party vendors who provide services or functions on our behalf, including operation of the website, business analytics, customer service, marketing, and distribution of surveys. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of our website. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.

· In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.

· When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; or to protect and defend the rights, property, or safety of our company, our customers, or others.

· In connection with a (proposed or actual) corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.

7. DATA RETENTION

When you place an order through the website, we will maintain your Order Information for our records. Except to the extent prohibited by law, and subject to this privacy policy, we will retain and use your personal data for as long as it is needed to provide you with any products, services, communications, or access to the site, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. YOUR LEGAL RIGHTS

Depending on your jurisdiction, you may have certain rights with respect to your personal data. If you would like to speak to us about any of your rights, please contact us. Please note that we may request additional information to respond to or fulfill any requests regarding your rights under applicable laws or regulations.

Your California Privacy Rights. [RS1]

California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personal data for direct marketing purposes. We do not share personal data with other people or non-affiliated businesses for their direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send a letter to 7901 4th St. N, St. Petersburg, FL 33709. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.

Additionally, we do not sell your personal data to third parties.

You can always opt out of any subscription for emails, involving any updates, information, postings, news, and/or press releases, by clicking “Unsubscribe” at the bottom of the email. We might still send you some important emails, like responding to you by email if you send us a request or comment.

Your Nevada Privacy Rights.

Although Dividojo does not sell personal information, Nevada residents have the right to submit a verified request directing Dividojo not to sell their personal data. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods noted in Section 2 “Contact Us”.

Your United Kingdom and European Union Privacy Rights.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

· If you want us to establish the data’s accuracy.

· Where our use of the data is unlawful but you do not want us to erase it.

· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

9. THIRD PARTIES

The Site may link to other websites, online services, or social media platforms, and such links are provided for your convenience only. If you decide to access any of the third party websites linked from our Site, you do so subject to the terms and conditions of use and privacy policies of those sites, services or platforms.

We share your personal data with third parties to help us supply our products and services.

Please note, our website is run on the Dividojo platform. Please refer to the Dividojo privacy policy for more details.

We may also share your personal data to comply with applicable laws and regulations or other lawful request for information we receive, or to otherwise protect our rights.

10. SECURITY

We implement commercially reasonable physical, technical, and administrative security measures to protect your personal data. Nonetheless, no such measure is ever 100% effective; therefore, we do not guarantee that your personal data will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such personal data.

If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.

11. CHILDREN

We do not knowingly or specifically collect personal data from users under the age of 18 and no one under age 18 is authorized to submit any information, including personal data, on the site. If we determine that such information has been inadvertently collected on anyone under the age of 18, we will take the necessary steps to ensure that such information is deleted from our systems. If you are a parent or guardian and become aware that your child has provided us with information, please contact us using one of the methods noted in Section 2 “Contact Us”.

12. LINKS TO OTHER WEBSITES

The site may contain links, references, and other forms of connectivity to third party website, apps, or platforms. This privacy policy does not apply to the information (including personal data) collected on any such third party website, app, or platform over which we have no influence or control. We are not responsible for the privacy practices of such websites, apps, or platforms. Accordingly, we recommend that you review the privacy notice and related policies posted on any such websites, apps, or platforms.

Revised: JAN 2022