CALIFORNIA CONSUMER PRIVACY ACT

MILANI COMMITMENT TO OUR CONSUMERS

New Milani Group LLC(“Milani”) offers and maintains this website, located at www.milanicosmetics.com, including all of its subdomains and subparts (collectively, “our website”). Milani respects the privacy of everyone who visits our website. Our Privacy Policy is an extension of our commitment to combine the highest-quality products and services with the highest level of integrity in dealing with our customers. Milani is committed to building a lasting and meaningful relationship with our customers, and we respect the privacy of our users.

This policy was developed to inform visitors to our website about how Milani collects, uses, discloses, and safeguards our customers’ information. Our customers’ privacy is important to us and we hope you take the time to read this Privacy Policy carefully.

CHANGES TO OUR PRIVACY NOTICE

Milani reserves the right to amend this privacy notice at our discretion and at any time and for any reason. When Milani makes changes to this privacy notice, it will post the updated notice on the Website and update the notice's effective date. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Website. No specific notices will be sent to users. Your continued use of Milani Website following the posting of changes constitutes your acceptance of such changes.

COLLECTION OF YOUR INFORMATION

Milani Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, the Website may have collected the following categories of personal information from its consumers within the last twelve (12) months:

 

 

Category

 

Examples

 

Collected

 

A. Identifiers.

 

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

 

Yes

 

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code

§ 1798.80(e)).

 

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

 

Some personal information included in this category may overlap with other categories.

 

Yes

 

C. Protected classification characteristics under California or federal law.

 

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

Yes

 

D. Commercial information.

 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

 

Yes

 

E. Biometric information.

 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait,

or other physical patterns, and sleep, health, or exercise data.

 

No

 

F. Internet or other similar network activity.

 

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

 

Yes

 

G. Geolocation data.

 

Physical location or movements.

 

Yes

 

H. Sensory data.

 

Audio, electronic, visual, thermal, olfactory, or similar information.

 

No

 

I. Professional or employment-related information.

 

Current or past job history or performance evaluations.

 

No

 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34

C.F.R. Part 99)).

 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

 

No

 

K. Inferences drawn from other personal information.

 

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Yes

 

USE OF PERSONAL INFORMATION

Milani does not sell your personal information. We consider this information to be a vital part of our relationship with you. We share information with the third parties (vendors, agencies and businesses) that help us run our sites, our business, and retail our products to further Milani’s mission. We do not sell your data or permit use of your personal information for independent use without your consent. We share information to the extent we need to prevent fraud, when required by law or authorities, and in the event of a sale of our company.

Collecting your personal information allows Milani to provide you with a more efficient and customized experience, Specifically, we may use the personal information we collect from you for one or more of the following business purposes:

1. Milani uses your name and address information only to fulfill customer needs, such as order fulfillment, billing, and delivery. If you send us an email, we may use your email address and other information you submit to provide customer service to you.

2. We may also use your personally identifiable information or Automatic Data to administer our internal business activities, such as to design and arrange our website in the most user-friendly manner and to continually improve our website to better meet the needs of our customers and prospective customers, to better understand visitors to our website, to manage your account, to provide customer service, or to make available other products and services to our customers and prospective customers.

3. If you choose to receive email or text messages from Milani, we may use your personally identifiable information to send you information and updates about Milani cosmetic products, tips, promotional offers and giveaways, as well as changes to our Website, new services, and special offers we think you will find valuable. We will do this only with your permission. If you do not wish to receive text messages from Milani, please text STOP to the last message received and you will be automatically removed. If you do not wish to receive email messages, please click the Unsubscribe link at the bottom of any email to be removed. If you are having any issues with opting out of communication, please email customerservice@milanicosmetics.com for assistance.

4. You may notify us at any time of your desire not to receive these communications, or Opt Out, by clicking on a response box when you receive such an offer, or by emailing your request to unsubscribe to: customerservice@Milanicosmetics.com.

     

    SHARING PERSONAL INFORMATION

    We may share your personal information with the following categories of third parties:

    1. Sharing Information with Parent Companies, Subsidiaries, And Affiliates

    We may share your personally identifiable information with our parent companies, subsidiaries, and/or affiliates for purposes consistent with this Privacy Policy. Our parent companies, subsidiaries, and affiliates will be bound to maintain that personally identifiable information in accordance with this Privacy Policy.

    1. Sharing Information with Successors

    As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personally identifiable information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Milani (or its assets) will continue to have the right to use your personally identifiable information and other information in accordance with the terms of this Privacy Policy.

    1. Sharing Information with Agents, Consultants, and Related Third Parties

    We, like many businesses, sometimes engage other companies to perform certain business-related functions. These companies include our marketing agencies, database service providers, backup and disaster recovery service providers, email service providers, payment processors, and others. When we engage another company to perform such functions, we may provide it with personally identifiable information, Automatic Data, or aggregate information about our customers, sales, website traffic patterns, and related website information, in connection with its performance of such functions. However, Milani does not collect or store credit card information or internet protocol addresses directly; rather, we employ a third party payment processor who may collect, store, and use such information. We take measures to select product or service providers that are responsible and afford privacy protections to their customers, such as those that comply with the Payment Card Industry Data Security Standards. However, we cannot make any representations about the practices and policies of these companies.

    1. Sharing Information with Strategic Partners

    We may enter into strategic marketing alliances or partnerships with third parties for the purpose of providing you information regarding products and services that we think will be of interest to you. In these circumstances, Milani may communicate with you on behalf of a strategic partner, but strategic partners will not be given access to your personal information. In connection with strategic marketing alliances or partnerships, we will retain all ownership rights to the information, and we will not share your personal information. Sharing Information through Social Media you may connect to Milani through your accounts on third party services like Facebook, Twitter, or Instagram, in which case we may collect, use, disclose, transfer, store, and retain information relating to your account with such third party services in accordance with this Privacy Policy.

    1. Legally Compelled Disclosure of Information

    We may disclose your personally identifiable information if required to do so by law (including without limitation, responding to a subpoena or request from law enforcement, a court, or a government agency) or in the good faith belief that such action is necessary (a) to comply with a legal obligation; (b) to protect or defend our rights, interests or property or that of third parties; (c) to prevent or investigate possible wrongdoing in connection with our website; (d) to act in urgent circumstances to protect the personal safety of users of our website or the public; or (e) to protect against legal liability.

     

    DISCLOSURE OF PERSONAL INFORMATION FOR BUSINESS

    Milani may disclose your personal information to a third party for a business purpose.

    In the preceding twelve (12) months, Milani has disclosed the following categories of personal information for a business purpose:

    For Business Purposes

    We share the following categories of personal information for a business purpose, as we have in the preceding 12 months:

    • identifiers, including your first and last name, billing address, mailing address, email address, and internet protocol address;

    • commercial information, including purchase and order management information;

    • internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with our website.

    We disclose your personal information for a business purpose to the following categories of service providers/third parties:

    • order management and shipping processors;

    • payment processors;

    • customer service providers;

    • shopping experience service providers;

    • marketing service providers (including for purposes of targeted advertising);

    • product review program providers.

    For Advertising

    We work with third-party platforms, including platforms operated by social networks, such as Google, and Facebook, in order to show you targeted advertisements or to measure the effectiveness of our advertisements. We may share your email address and telephone number and have these third-party platforms match your information with the data they may have. This matching enables us to deliver targeted advertisements to you. 

    With Your Consent

    We may disclose personal information collected from, and about, you (including your personal information) with companies, organizations or individuals with your express consent.

    For Legal Reasons

    We may also share personal information collected from, and about you with third-parties if we are legally required to do so, or if we have a good-faith belief that access, use, preservation or disclosure of the personal information is reasonably necessary to:

    • comply with any applicable federal, state, or local law, regulation, civil, criminal or regulatory inquiry, investigation legal process or enforceable governmental request;

    • respond to legal process (such as a search warrant, subpoena, summons or court order);

    • cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believes may violate federal, state, or local law; or

    • exercise or defend legal claims, protect against harm to our rights, property or safety or the rights, property or safety of third-parties, our consumers, or the public as required or permitted by law.

    In Connection with a Sale or Merger

    If we directly or indirectly undergo a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets, we may disclose or transfer personal information collected from, and about, you (including your personal information), to the successor organization in the transition. We will make reasonable efforts to let you and others know if your personal information has been disclosed or transferred in connection with a business transition.

    Aggregated, Non-Personally Identifiable Information

    We share aggregate, non-personally identifiable information with our service providers in order for those service providers to enhance and optimize their services and for statistical analysis, research, and other purposes.

     

    SECURITY OF YOUR INFORMATION

    Milani uses administrative and technical security measures to protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

     

    YOUR RIGHTS AND CHOICES

    The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

    Access to Specific Information and Data Portability Rights

    You have the right to request that Milani discloses certain information to you about Milani’s collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

    • The categories of personal information we collected about you.

    • The categories of sources for the personal information we collected about you.

    • Our business or commercial purpose for collecting or selling that personal information.

    • The categories of third parties with whom we share that personal information.

    • The specific pieces of personal information we collected about you (also called a data portability request).

    • If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.


    Deletion Request Rights

    You have the right to request that Milani delete any of your personal information that Milani collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

    We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

    1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

    1. Debug products to identify and repair errors that impair existing intended functionality.

    1. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

    1. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §

    1546 et. seq.).

    1. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

    1. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

    1. Comply with a legal obligation.

    1. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.


      Exercising Access, Data Portability, and Deletion Rights

      If you are a California resident and wish to exercise the access, data portability, and deletion rights described above, please click here.

      Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

      You may only make a verifiable consumer request for access or data portability twice within a

      12-month period. The verifiable consumer request must:

      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

      • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

      We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

      Making a verifiable consumer request does not require you to create an account with us.

      We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

       

      Response Timing and Format

      We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to [90] days), we will inform you of the reason and extension period in writing via email.

      Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

       

      Personal Information Sales Opt-Out and Opt-In Rights

      If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

      To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing customerservice@milanicosmetics.com.

      Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing customerservice@milanicosmetics.com.

      You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

       

      Non-Discrimination

      We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

      • Deny you goods or services.

      • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

      • Provide you a different level or quality of goods or services.

      • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


      Other California Privacy Rights

      California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of Milani Website who reside in California to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please

       

      Contact Information

      If you have any questions or comments about this notice, the ways in which Milani collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

       

      Phone: 1 (866) 789-8002

      Website: www.milanicosmetics.com

      Email: customerservice@milanicosmetics.com

      Postal Address: 10000 Washington Blvd., Suite 210, Culver City, CA 90232