Privacy Notice

Effective date: September 11, 2024

Pelegon LLC (“Company”, “us”, “we”, or “our”) respects your privacy and takes your personal data seriously. Please read the following to learn more about our policy regarding treating personal data collected through the Website as well as when you are contacting the Company by other means such as email or phone (“this Policy“). Capitalized terms not otherwise defined herein, shall have the meaning assigned to them in the Terms of Use available here [link to the Terms of Use]. This Privacy Notice is hereby incorporated into our Terms of Use and is an integral part thereof.

Contents:

1. What personal data we collect, how, and how is it being processed
2. How we share your personal data
3. Data transfers and global processing
4. Data subject rights
5. Cookies and similar technologies
6. Security of processing
7. Data retention
8. Changes to this privacy notice
9. General

What Personal Data We Collect, How, and How is it Being Processed

1. The following table describes what personal data we collect through the Website or when contacted by other means, and for what purposes it may be processed: 

Instance in which personal data is collected	Categories of personal data that are processed	Purposes of processing
When you contact us by phone	Name, phone number, email address, physical address, Order information (order ID), any other information you may choose to provide us	To contact you in relation to your message and for further communications with respect thereto To process any requests or inquiries that you make in our communications To manage and track our customer communications To send you marketing communications regarding our Products (subject to your consent, if required under applicable law)  to send newsletters and updates, subject to applicable laws. To create analytics and statistical data for our internal business requirements (improvement of services, increase efficiency etc.) If applicable, to provide you with a promotion code.
When you contact us by email
When you fill out a "Contact Us" form on the Website
When you contact us by filling out “Leave us a message” on the Website	Name, email address, content of your message and any information provided within the files you chose to attach to the message
When you sign up for our marketing communications through the designated form on our Website	Email address	To manage and track our customer communications To send you marketing communications regarding our Products (subject to your consent, if required under applicable law)  to send newsletters and updates, subject to applicable laws. To create analytics and statistical data for our internal business requirements (improvement of services, increase efficiency etc.) If applicable, to provide you with a promotion code.
When you use our chat feature on the Online Store	Full name, email address, order ID [ensure to complete if there is any additional information to be collected]	To contact you in relation to your message and for further communications with respect thereto To process any requests or inquiries that you make in our communications To manage and track our customer communications  to send newsletters and updates, subject to applicable laws. To create analytics and statistical data for our internal business requirements (improvement of services, increase efficiency etc.) To send you marketing communications regarding our Products (subject to your consent, if required under applicable law), to send newsletters and updates, subject to applicable laws.
When you make a purchase of our Products	Email address  phone number. Full name and shipping address 4 last digits of your payment Card, type of card, token of payment method .	To process your purchase in our accounting and inventory systems. To deliver the Products to you and track shipments. To manage warranty in relation to your purchase To record your consent to our terms and conditions of engagement. To send you product information, updates or other transactional messages regarding our services related directly to the product you have purchased. To respond to your queries to customer support. BI/analytics To conduct customer surveys To re-engage you in case you have not completed the purchase To contact you occasionally with marketing communications regarding our Products and Services, to send promotions, newsletters and event invitations subject to applicable laws (for example, where required, subject to your consent).
Quiz	information related to disabilities or health condition [please include a consent checkbox for processing of health related information for the purposes ]	improve product selection process for user BI/analytics and provide personalized purchase recommendations.
When you choose one of the accelerated checkout solutions available on the Website.	Address, full name, email address, Your choice of check out method We will not save any payment details (credit card, etc.)	To process your purchase in our accounting and inventory systems.
When you choose to complete the purchase of the Products using your Amazon account	Address, full name, email address, Your choice of check out method We will not save any payment details (credit card, etc.)	To process your purchase in our accounting and inventory systems.
When you activate your warranty by filling out designated form on the Website.	Full name, Order ID, email address, phone number.	To handle warranty issues or returns/replacements.
Data that you provide passively (by using the Website, by navigating the screens, clicking on buttons etc.) This data is collected using third party services by means of placing cookies, pixels or web beacons. For more information, please look at the Cookies section.	Your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.	To improve, modify and update services and content offered on the Website.  To monitor and ensure the orderly and proper operation and development of the Website and associated services. To improve and customize the user experience and the content that is presented on the Website. For marketing analytics. To support our marketing efforts and to allow providing you with customized content. To support development of additional features in the Website.  To improve and customize the user experience.

1. You are not obliged under any applicable law to provide us any of the above information and you may be able to opt not to disclose your personal data to Company. However, not providing Company with certain data may mean that we cannot provide you with certain functionalities or process any requests or in some cases sell or deliver the Products altogether. It is your responsibility to ensure that all personal data submitted to Company is correct.
2. In addition to the above uses of your personal data, we will also process your personal data for the following purposes: 
1. We use all the above personal data to operate, maintain, and provide to you the Website and to provide you with the services as requested by you.
2. To prevent, detect and fight fraud or other illegal or unauthorized activities.
3. To ensure legal compliance – from our side (to legal requirements that apply to us and to our obligations under the Terms of Use) and from your side (compliance with legal requirements applicable to you and with the Terms of Use).
3. We will not use your personal data for any personal profiling and automated decision making regarding you based on such profiling. 
4. We limit access by our employees to your information only to those who were specifically authorized by the Company to access your information, as part of their job. 
5. We use anonymized, aggregate data, in order to gain insight on how you and other users use the Website and try and improve them, as well as to plan our marketing and advertisements.

How we Share Your Personal Data 

1. No Sale to Third Parties. We do not, and will not, sell any of your personal data to any third party for advertising, marketing or any other purpose. 
2. Service Providers: we employ other companies and people to perform tasks on our behalf and need to share your information with them in order to provide the services to us. The categories of third party recipients of the personal data from us are as follows: cloud hosting services, email campaign automation, marketing automation, social media advertisement, CRM/ERP platforms, shipment process and logistics services, analytics tools and services, web page building tools, payment gateway services, technical support, repair services, messaging platforms, call center services and customer support service providers [Please review the categories of service providers and add/remove as applicable to your operation]. Our service providers do not have any right to use your personal data beyond what is necessary for the purpose of facilitating the functionality thereof in order to provide the Products and/or Services to you and to support our operations. 
3. Compliance with the Law: We may disclose your information if we believe it’s necessary in order to comply with the law, such as to comply with a subpoena, regulation or legal request, respond to a government request, to address fraud or security issues, to protect the safety of any person, to enforce our agreements with you; to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing or to protect our own rights or property. This includes sharing such information with our legal counsels. If you are located in the EU, we may only do so based on legal requirements specified above of EU authorities. 
4. Business Transfers: If we are in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be transferred as part of that transaction to a successor in interest and may be accessed and reviewed by the applicable legal authorities as well as legal counsels and other professional counsels involved such as accountants, and other officers of the government or of the applicable judiciary instance. In addition, your information may be provided for review in the course of due diligence for an investment or other financing of our Company.
5. Anonymized Information: We may provide third parties with aggregated but anonymized information and analytics about our customers however, before we do so, we will make sure that it does not identify you.

Data Transfers and Global Processing

1. The Website may be operated in countries other than your own location, and your personal data may be accessed and/or processed from and/or transferred to countries other than your own location. We may do this where data is accessed/processed:
1. By Company for operational, administrative, compliance purposes or customer support teams in our various locations; 
2. By our service providers, for the purposes we specified under section ‎2.2, “Service Providers”. 
2. Company will take steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Data Subject Rights

1. Depending on your location and on the laws that are applicable to you, you may be entitled to various rights in relation to your personal information, such as right of access, right of erasure etc. Please contact us if you have an inquiry in relation to your personal information processed by us, and we shall process your request based on applicable laws. Although we will make reasonable efforts to accommodate your requests, in some circumstances we may deem your request unfounded or not eligible under applicable law.
2. If allowed by applicable laws, you have the right to withdraw your consent at any time when Company processes your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another lawful bases other than your consent.
3. If you think that the way we process your personal data does not comply with applicable data protection laws, you are of course invited to contact us and we will consider your request, but in any event you may contact the relevant competent data protection authority.

Cookies & Similar Technologies 

1. A cookie is a small text file that is stored in your web browser that allows Company or a third party (such as third-party service providers) to recognize you. Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. 
2. Cookies that we may use can generally be categorized as follows:
1. Strictly Required Cookies: These cookies are necessary to load the Website or to allow users to use Website’s certain features.
2. Analytics Cookies: These cookies track information about how the Website is being used so that we can make improvements and report on our performance. 
3. Functional Cookies: These first party cookies store your Website preferences.
4. Marketing Cookies: These are usually third-party cookies by advertising platforms or networks in order to: (i) deliver ads and tracks ad performance, and (ii) enable advertising networks to deliver ads that may be relevant based upon your activities.
3. We may use additional tracking technologies to help understand user activities and preferences. For example, we use web beacons (also known as clear gifs, pixel tags or web bugs) to track user activities and communicate with cookies. You cannot opt out of web beacons used in webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only. 
4. We use the Analytical cookies on our Website for the improvement of visitors’ experience on the Website. We will update cookies used from time to time. 
5. We may set cookies that monitor links to our Website that we send to you (if you have consented to receiving emails from us or we otherwise are allowed to send those emails to you). These cookies are used to track visitors to our Website sourced from these emails.  To avoid these types of cookies, please follow the explanation below on how to change your browser cookies settings. 
6. In addition we may use tracking technology (pixels) in emails to understand how often our emails are opened and clicked on by our customers. If you do not wish this tracking to be effected, please change your email software or service (such as outlook, Gmail etc.) settings to not automatically download images (to the extent it is not already your default). In some instances, depending on your email or browser settings, cookies in an email may be automatically accepted (for example, when you have added an email address to your address book or safe senders list). Please refer to your email browser or device instructions for more information on this. 
7. You can change your browser's settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. Some useful information can also be found here: https://www.allaboutcookies.org/.  Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Security of Processing

1. We use appropriate physical, management, and technical measures to protect your data from unauthorized access, disclosure, use, modification, damage, or loss. We also provide training on security and privacy protection for employees to raise their awareness of personal data protection. However, please note that no security measure is perfect, therefore, you should take special care in deciding what information you disclose.

Data retention

1. We will retain your personal data for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary with scenario, product, and service. 
2. The standards Company uses to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing Products; maintaining corresponding transaction and business records; controlling and improving the performance and quality of the Website; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention.

Changes to This Privacy Notice

1. We may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page. We may notify you through different channels, for example, posting a notice on our Website or sending you direct notification.
2. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page. 

California and Delaware “do not track” Disclosures

We do not monitor or respond to Do Not Track browser requests. Hence please ensure to change any settings of your browser and/or our Services, whenever you wish cookies to cease.

General

1. If you have any questions or suggestions, to exercise any of your rights, or if you have any other questions or complaints about our use of your personal data and your privacy please contact us at [email address]. 
2. Where your personal data is processed by Company in accordance with this Policy, Pelegon LLC  is the controller of the related personal data and may be contacted via [email address].

***