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PRIVACY POLICY


Mejuri Inc., Mejuri (US), Inc., Mejuri (UK) Ltd., and Mejuri Australia Pty Ltd and their respective subsidiaries and affiliates (“Mejuri”, “we”, “us”, “our”) recognize the importance of your personal information. This Privacy Policy sets out how Mejuri uses and protects information that it collects from its customers, visitors and users (collectively, the “Users”) through, or in association with, its website with a homepage located at www.mejuri.com (https://mejuri.com/ca/en)and its Mejuri Mobile App (collectively, the “Sites”), its products and services that may be offered from time to time via the Sites, its related social media sites, or otherwise through Users’ interactions with Mejuri (the Sites, products, services, and social media pages, collectively, the “Services”), why it collects that information, how it uses that information, and to whom and in what capacity it shares that information. By accessing the Services, using features of the Services, and/or submitting information to Mejuri, you are bound by all terms and conditions in the Terms of Use (the “Terms of Use”) (https://mejuri.com/ca/en/company/terms) and this Privacy Policy.

California residents, see our California Privacy Notice (https://mejuri.com/ca/en/static/terms-ccpa) (the “California Privacy Notice”) for more information about certain legal rights.


INFORMATION WE COLLECT


Information you provide: When you register an account or complete a transaction through the Services, we collect some “Personal Information” (thatis, any information that can be directly or indirectly associated with you), such as your name, title, email address, phone number, address, date of birth, billing information and other similar information. You may also provide us with certain Personal Information of other people (e.g., if you are sending a gift to someone else).


Device Identifiers: When you access the Services by or through a device, wemay access, collect, monitor and/or remotely store one or more “device identifiers”, including device ID and device type. Device identifiers allow us to uniquely identify your device and are used to enhance the Services (including sending updates and information from the Services). A device identifier may also be used in conjunction with other Personal Information.


Analytics: When you access our Services, we may collect information (either directly or using third party services) using logging and cookies which can sometimes be correlated with Personal Information. We use this information to monitor and analyze use and interest in the Services. See the section on “Service Providers” for more detail in this respect.


Log data: As with most website and technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address of your device, the address of the web page visited before using the Services, the purchases that you make, the products you view, browser type and settings, the date and time the Services were accessed, information about browser configuration and plugins, language preferences and cookie data. It may also include your device’s GPS signal or information about nearby Wi-Fi access points and base stations that may be transmitted to us when you use certain Services and enable the location function on your device.


Cookie and Tracking Information: A cookie is a text file stored locally on a User’s device by the User’s web browser, which enables the browser to remember passwords, orders, preferences, and other information when visiting a website. We use cookies and similar technologies such as pixel tags and web beacons that help us collect certain usage data about you (such as your preferences and to process shopping cart items) (“Usage Data”), which may become Personal Information due to direct association with you. The Services may also include cookies and other similar tracking technologies including those of third parties, which may collect information about you via the Services and across other sites and online services, including social media platforms. Our use of cookies and similar technologies such as pixel tags and web beacons is generally for operational purposes, website performance purposes, enhancing functionality of the Services and advertising. For more details about how we use these technologies, please see the section on “Service Providers” below. To adjust your tracking preferences in iOS, visit Settings > Privacy & Security > Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads.


USE OF INFORMATION


We generally use information that we collect for the purposes of fulfilling our contractual obligations to you, in furtherance of our legitimate interests in operating the Services and our business and/or where you have consented to such usage.More specifically, Mejuri uses Personal Information:


To provide, update, maintain and protect the Services and our business. This includes use of Personal Information to support delivery of the Services, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at your request. Mejuri may use your email address or phone number to send you notices (including any notices required by law, in lieu of communication by postal mail). If you correspond with Mejuri by email, we may retain the content of your email messages, your email address and our responses.


To personalize your experience and improve customer service. This includes Personal Information to understand your buying/shopping preferences so that we may be able to advertise other products that you might be interested, to notify you of items left as uncompleted transactions in your shopping cart, and related communications. Your information also helps us to more effectively respond to your customer service requests and support needs. Given this is related to direct marketing, we have a legitimate interest in collecting and using your email and information about your abandoned shopping cart to communicate with you about you uncompleted transaction.


As required by applicable law, legal process or regulation. Mejuri may in certain instances be compelled by law to process your Personal Information to comply with a binding order. We will only do so to the extent reasonably required by that order.


To communicate with you by responding to your transactions, requests, comments and questions. If you contact Mejuri, Mejuri may use your Personal Information to respond.


To send emails and other communications. Mejuri may send you service, technical and other administrative emails, messages and other types of communications. Mejuri may also contact you to inform you about changes in our products, and important notices, such as security and fraud notices.


To process transactions, including, billing, account management and other administrative matters. We will use your information to process transactions. This includes processing discount codes provided by our third-party brand ambassadors. We may need to contact you for invoicing, account management and similar reasons, and we use account data to administer accounts and keep track of billing and payments.


To investigate and help prevent security issues and abuse and to otherwise monitor the Sites for violations of our policies or applicable laws. To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities and/or attempts to harm our users.


For marketing purposes. Mejuri may use the information we collect, including Personal Information, to market our products and services to new and existing customers, and to understand our audience. Mejuri may also use your Personal Information to send you marketing messages and may provide such information to third parties to send you information about our products and services. If you don’t want to receive these messages, you can opt out by following the instructions in the message or by submitting your request through this form. This includes determining your level of engagement with email or promotional marketing materials that are sent to you, including whether you opened an email or promotional marketing materials and/or otherwise engaged with it.


To improve our Sites. We continually strive to improve our Sites’ offerings based on the information and feedback we receive from our users and visitors.


We also use Information as otherwise described in this Privacy Policy, permitted by law, or as we may notify you.


The legal basis for the associated processing of your Personal Information is Art. 6 (1)(f) GDPR (balancing of interests, based on our legitimate interest in constantly and profitably improving the content, functionality and attractiveness of the Sites by analyzing your usage) as well as Art. 6 (1)(b) GDPR (performance of a contract) and Art. 6 (1) a) GDPR (your consent).


INFORMATION SHARING AND DISCLOSURE


Mejuri may share, transfer and/or disclose your Personal Information to or with third parties to provide the services or products requested by you, and under the following circumstances:

  • Mejuri shares certain Personal Information with its shipping company, credit card processing company, payment service provider(s), email service provider(s) and other third parties necessary to fulfil an order placed through the Services. These third parties are contractually or otherwise legally prohibited from using your Personal Information for promotional purposes or from selling your Personal Information. These third parties include, but are not limited to, our brand ambassadors with whom your email addresses are shared so that they may track their commissions. These third-party service providers may have access to information about you if itis needed to perform their functions for us, but they are not authorized by us to use or disclose such information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence.

  • Mejuri may share Personal Information and other information we collect with our Service Providers and other third parties in connection with our marketing and business development efforts. Again, these third-party service providers may have access to information about you if it is needed to perform their functions for us, but they are not authorized by us to use or disclose such information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence.

  • Mejuri shares certain information that is traditionally not considered Personal Information (such as device, analytics, and Usage Data) for purposes of better understanding the usage of the Services by Users and improving on that experience.

  • Mejuri reserves the right to disclose Personal Information: as permitted or required by law; when Mejuri believes disclosure is necessary to protect our rights or to comply with a legal process; and/or in the event it is necessary to prevent, investigate or take action regarding unlawful, illegal or suspicious activities that violate the Terms of Use or this Privacy Policy.

  • Mejuri may share your Personal Information in response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request.

  • Mejuri may share your Personal Information third parties to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or violations of our policies or the law.

  • Mejuri may transfer Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Mejuri about Mejuri’s Users is among the assets transferred.

All information voluntarily shared by you through forums, comments, or blog posts is publicly available and your username may be visible by other Users. Mejuri is not responsible for any information you submit that can be read by other Users and can be used to send you unsolicited information by other Users.


Mejuri may, from time to time, choose to post certain Personal Information about a User for promotional or Service-related purposes; prior to posting saidinformation, Mejuri will obtain the User’s consent via email.


RETENTION OF DATA


Mejuri will retain your Personal Information for as long as is reasonable or appropriate for the purposes set out in this Privacy Policy. We will also retain and use your Personal Information to the extent necessary or reasonable to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.


Mejuri will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.


TRANSFER OF DATA


Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.


If you are located outside the United States, please note that we transfer data, including Personal Information, to the United States and process it there.


By using the Services, you understand and acknowledge that your Personal Information will be transferred to and processed in the United States, which may have different data protection rules than in your country.


Mejuri will take steps reasonably designed to treat your Personal Information securely and in accordance with this Privacy Policy, as further described below.


YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)


If you are a resident of the European Economic Area (EEA) or of the United Kingdom (UK), you have certain data protection rights under the GDPR and the UK GDPR respectively. Mejuri aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.


If you wish to be informed about what Personal Information we hold about you, and/or if you want it to be removed from our systems, please request those details by completing this form (https://mejuri.com/ca/en/company/dsar).


In certain circumstances, you have the following data protection rights:

  • Request access to your Personal Information(commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you where we are the data controller and to check that we are lawfully processing it.

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

  • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information 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 Information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be explained to you, if applicable, at the time of your request.

  • Object to processing of your Personal Information 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 Information 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 Information.This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your Personal Information to you or to a third party.We will provide to you, or a third party you have chosen, your Personal Information 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 Information.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 services to you. We will advise you if this is the case at the time you withdraw your consent.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA) or the UK as applicable.


If you wish to exercise any of the rights set out above, please make a request through the form available here (https://mejuri.com/ca/en/company/dsar), unless you wish to complain to a Data Protection Authority in which case you should contact the Authority directly.


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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure designed 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.


For users in the European Economic Area, the United Kingdom, or Switzerland, any changes or modifications will be effective upon your express consent as you will be notified of any changes by virtue of a pop-up, banner, or other notification mechanism when you seek to access the Online Services after we issue a change or modification. Upon consent, the revisions on the Online Services shall apply to all use of the Online Services and all acts or omissions occurring after the effective date of the revised Privacy Policy.


CALIFORNIA PRIVACY RIGHTS


California residents, see our California Privacy Notice for more information about certain legal rights.


NEVADA PRIVACY RIGHTS


Nevada law permits our Users who are Nevada consumers to request that their personal information not be sold (as defined under applicable Nevada law), even if their Personal Information is not currently being sold. Requests may be made through this form and are free of charge.


CHILDREN’S PRIVACY


Our Online Services is not intended for children under 13 (16 in the EEA and 18 in the UK). No one under age 13 (16 in the EEA and 18 in the UK) may provide any information to or on the Online Services. We do not knowingly collect personal information from children under 13 (16 in the EEA and 18 in the UK). If you are parent or guardian and learn we have collected or received personal information from a child under 13 (16 in the EEA and 18 in the UK) without verification of parental consent, please contact us using this form and we will delete that information.


PROTECTING YOUR INFORMATION


Mejuri implements security measures designed to maintain the security of your Personal Information. These security measures are implemented both during transmission of Personal Information and once received. The security of your Personal Information is important to us. Certain sensitive information submitted, such as credit card information, is encrypted using secure layer technology (SSL). However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.


THIRD PARTIES


In some instances, the Services might contain links to other third-party sites and services. When you access these other sites or services, you are leaving the Services. Mejuri is not responsible or liable for the activities on, security or privacy practices of, or content on third party sites. We encourage you to read the privacy statements posted on each such third-party site or service.


SERVICE PROVIDERS


We may employ third party companies and individuals to facilitate the Services and our provision of products and services through the Sites, to provide the Services on our behalf, to perform services related to the Services(as discussed above), to assist us in analyzing how our Services are used, and to assist us with business development and marketing efforts related to the Services (“Service Providers”). These Service Providers may have accessto your Personal Information only to perform these tasks on our behalf. Some Service Providers may retain aggregated, anonymized data sets in which the individual may no longer be identified.


We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. These retailers and charities share information about their customers and supporters and what they buy or donate. Epsilon Abacus processes this information as a processor on behalf of these companies to help them understand individuals’ behaviour and preferences. Epsilon combines information provided by participating retailers and charities with third party data. From this combined information, these companies can tailor their communications, sending individuals suitable offers and appeals that should be of interest to them. You can learn more about howEpsilon Abacus processes your personal information in their Privacy Policy, which is available here: https://www.epsilon.com/abacus/services-privacy- policy


SWEEPSTAKES AND COMPETITIONS


We run sweepstakes, competitions and other engagements from time to time and participation may require that you opt in to receive marketing communications from us, among other conditions. You may opt out of receiving marketing or other communications from us at any time by following the steps described below. In the event of any differences between the terms of the engagement and the terms of this privacy policy, the terms of the engagement will take precedence.


COMMUNICATIONS OPT-OUT


You may opt out of receiving marketing or other communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, or by submitting your request through this form (https://mejuri.com/ca/en/company/dsar). Note that, even if you opt out of receiving marketing communications from Mejuri, we will still send you order confirmations and other non-marketing related messages.


EDIT OR DELETE ACCOUNT


If your personally identifiable information changes, you may correct, update, or amend your account by making the desired changes on the account profile page found after you log-in at www.mejuri.com. If you wish to delete/remove or deactivate your account on the Sites, please contact us using the information provided below or submit your request using this form (https://mejuri.com/ca/en/company/dsar).


CHANGES TO PRIVACY POLICY


Mejuri may amend or update from time to time this Privacy Policy in its sole discretion and without prior notice. Any such amendments or updates will be effective upon our posting of the revised Privacy Policy. Your continued use ofthe Services following our posting of any revised Privacy Policy will constitute your acknowledgement and acceptance of the amended Privacy Policy.


EFFECTIVE DATE


This policy was last modified August 15, 2023.


CONTACT INFORMATION


If you have any questions regarding this Privacy Policy, you can contact us at:

60 Bloor St W, Toronto, ON M4W 1J2 Canada, privacy@mejuri.com