Gwynnie Bee Privacy Policy

This Privacy Policy describes how CaaStle Inc. (d/b/a Gwynnie Bee) (“we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy covers our customer-facing operations in the United States and applies to the personal information that is (i) collected through our website located at www.gwynniebee.com and any other website or mobile application that we operate that links to this Privacy Policy (collectively, the "Site") and (ii) collected in connection with your use of our products and services (collectively, including the Site, the "Services"). This Privacy Policy also includes information about your rights and choices regarding your personal information, and how you can reach us to get answers to your questions. You can skip to a particular topic by clicking on the headings listed below.

This Privacy Policy does not apply to (i) information collected by third parties or websites or applications that we do not control, even if they are linked to or accessible through the Services; or (ii) information that we collect about any individual in their capacity as one of our current or former employees, job applicants, or professional business contacts. For information about our privacy practices with respect to information that we collect about employees, job applicants, and professional business contacts, please visit www.caastle.com.

• How We Collect Information.
• Types of Information We Collect and Why.
• How We Share Information.
• Cookies and Other Tracking Technologies.
• Your Choices.
• How We Protect Information.
• How Long We Retain Information.
• Children's Privacy.
• Other Important Information.
• Contact Information.
• Information for California Residents.

I. How We Collect Information.

We collect personal information in a variety of different ways. The types of personal information that we obtain about you depends on how you interact with us and our Services. When we use the term "personal information" or refer to "your information," we are referring to information that identifies, relates to, describes, or can be associated with, you. As explained in more detail below, we may collect personal information that is directly provided to us by you, obtained from a device associated with you or your household, or provided to us by a third-party source.

• Information Provided by You. We ask you to provide personal information when you create or update your account on the Site, log in to your account, sign up to receive communications and/or marketing materials from us, subscribe to or access our Services, make a purchase, contact customer service, provide feedback, and/or participate in our promotional activities.
  Information Collected from a Device Associated with You or Your Household. We and our third-party partners with whom we work to provide you Services may automatically collect certain of your information when you access or use the Services. Such information may include your Internet Protocol address ("IP address"), device identifier(s), browser type, and information about how you use and interact with the Services.
  We use tracking technologies, such as cookies, web beacons (also known as "pixels"), and other similar technologies (collectively, "Tracking Technologies") to collect this information. A cookie is a small text file that is stored on a device for record-keeping or tracking purposes. Web beacons and pixels are pieces of code embedded in the Services that can collect information about a person's interaction with a particular web page or content, such as whether the person has clicked on a particular link. For more information about Tracking Technologies and how to manage your preferences, see Section IV (Cookies and Other Tracking Technologies) and Section V (Your Choices) below.
  Additionally, we use log files to record certain technical information about how our customers and Site visitors interact with the Services. This Site traffic information may include your IP address, browser type, internet service provider, timestamps, and other clickstream data. Our servers store this information in log files.
  If the information that we collect automatically identifies you or could be reasonably used to identify you, then it is treated as your personal information. In many cases, the information that we collect automatically is only used in de-identified or aggregated forms, and it does not identify any particular individual.
  
• Information Collected from Third-Party Sources. We may receive certain of your information from third-party sources, such as our Service Providers, Brand Partners, and Advertising Networks (each as defined in Section III.A (Categories of Recipients) below) with whom we have partnered to operate and improve our Services.
  We may also obtain information about you from publicly available sources. If you interact with us on social media or use features, such as plug-ins, widgets, or other tools made available by social media platforms or networks in connection with our Services (including to login to our Site), we may collect information that you share with us through those mediums or information that social media platforms and networks share with us. This Privacy Policy does not apply to the collection of information by those third parties. For more information about the privacy practices of social media platforms and other third-party networks, please review the privacy policies and settings of the third-party platforms and networks that you use.
  

II. Types of Information We Collect and Why.

The following provides examples of the types of information that we collect, identifies the sources from which we collect such information, and explains why we collect the information.

Category of Information	Examples of Information	Sources of Collection	Business Purpose(s)
Identifiers	Name, postal address, email address, phone number, unique personal identifier, online identifier, IP address	We collect this information from you directly, collect it from your device or browser, or receive it from third parties, such as when we receive your name and email address from your friends or relatives in connection with our Gift Membership offerings.	We use this information to create your account on our Site, to process your transactions and payments, to ship products to you, to send you transaction information, to provide marketing content and communications, to better understand our customers, to provide customer service, to manage our Referral Program and Gift Membership offerings, to run sweepstakes and other promotional activities, to detect and prevent fraud or other illegal activity, to collect overdue payments, for security purposes, and for legal compliance purposes.
Physical Characteristics	Clothing size(s), clothing fit, and body shape	We collect this information from you directly, typically when you subscribe to or purchase our Services, which may include creating a size profile.	We use this information to process your transactions, to ship products to you, to better understand our customers, to improve our Services, to enhance your experiences with our Services, and to provide customer service.
Payment Information	Credit/debit card number(s)	We collect this information from you directly when you subscribe to or otherwise purchase our Services.	We use this information to process your transactions and payments, to provide customer service, to detect and prevent fraud or other illegal activity, to collect overdue payments, for security purposes, and for legal compliance purposes.
Demographic Information and Certain Protected Characteristics	Gender information, age (general), familial status, household information, estimated income	We collect this information from you directly, derive it from your purchasing or browsing history, or receive it from third parties.	We use this information to confirm that you meet the minimum age requirement to use our Services, to improve our Services, to provide marketing content and communications, to better understand our customers, to conduct consumer research that you consent to participate in, and for legal compliance purposes.
Commercial Information	Products and services rented, purchased, and/or considered, and other purchasing and consumption history or tendencies	We collect this information from you directly, collect it from your device or browser, or receive it from third parties.	We use this information to improve our Services, to provide customer service, to fulfill orders and process transactions, to provide marketing content and communications, to send transactional communications, to conduct research and better understand our customers, to detect and prevent fraud and other illegal activity, for security purposes, and for legal compliance purposes.
Internet or Other Similar Network Activity	Browsing history, search history, and information about your interactions with our Site, Services, emails, advertisements, and other content	We collect this information from you directly, collect it from your device or browser, or receive it from third parties.	We use this information to improve our Services, to enhance our customers' experiences with our Services, to send transactional communications, to provide marketing content and communications, to provide customer service, to conduct research and better understand our customers, to detect and prevent fraud and other illegal activity, for security purposes, and for legal compliance purposes.
Geolocation Data (Metro area)	Physical location within a greater metropolitan area	We collect this information from you directly or from your device or browser.	We use this information to improve our Services, to conduct research and better understand our customers, to provide marketing content and communications, to detect and prevent fraud and other illegal activity, for security purposes, and for legal compliance purposes.
Sensory Data	Audio or visual recorded electronic information, olfactory information, or similar information	We collect this information from you directly when you agree to participate in consumer research surveys or provide us with user-submitted content that includes this information, such as product reviews and customer service feedback. We may also obtain this information from publicly available sources, such as social media platforms on which our Services or content are featured.	We use this information to improve our Services and our customers' experiences with our Services, to conduct research and better understand our customers, to provide marketing content and communications, and to provide customer service.
Professional and/or Education-Related Information	Occupation, estimated income, and educational background or history	We collect this information from you directly when you agree to participate in consumer research surveys or provide us with user-submitted content that includes this information. We also may derive this information from your purchasing or browsing history or receive it from third parties.	We use this information to improve our Services and our customers' experiences with our Services, to conduct research and better understand our customers, to provide marketing content and communications, and to provide customer service.
Inferences Drawn from Personal Information	Inferences drawn from or created based on any of the information identified above	We derive this information from the information that we collect from you directly, from your device or browser, or from third parties.	We use this information to improve our Services and our customers' experience with our Services, to better understand our customers, to provide customer service and tailored recommendations, to provide marketing content and communications, to prevent fraud and other illegal activity, for security purposes, and for legal compliance purposes.

Under certain U.S. state privacy laws, payment information, such as a credit/debit card number together with any required security code, and account login information, such as a username and password, are considered "sensitive personal information." We only collect payment information and login credentials for accounts you have with us, when you provide them to us. We only use this information to provide you Services, to maintain the security of our Services and your information, or as we may otherwise expressly disclose to you at the time we collect the information. We do not use or disclose any sensitive personal information to draw inferences or build a profile about you or to conduct advertising of any kind. We do not "sell" or "share" for advertising purposes of any kind any personal information that is defined as "sensitive personal information" under applicable U.S. state privacy law(s).

We do not collect or use any personal information for purposes of profiling consumers in furtherance of any decisions that produce legal or similarly significant effects, such as decisions regarding access to financial or lending services, housing, educational or employment opportunities, criminal justice, healthcare, or any other similarly essential goods or resources.

We may use aggregate, statistical and "de-identified" information, which is anonymized and does not specifically identify you or any other individual person(s). We only use such information in a de-identified form and will not attempt to reidentify such information, except as permitted or required by applicable law.

III. How We Share Information.

We may disclose your information to our affiliates and/or to certain third parties as described below.

A. Categories of Recipients

We may share information with the following categories of recipients for the business purposes that are identified in Section II and Section III.B:

• Our Affiliates and in Connection with Business Transactions. We may share information with other companies within the CaaStle corporate family (e.g., sister companies, subsidiaries, joint ventures, or other companies under common control) (our "Affiliates"). If another person or entity acquires, or plans to acquire, our company, business, or assets, we may share information with that person or entity, including at the negotiation stage. Some or all of the personal information that we collect may be part of the assets that are transferred to complete this type of transaction.
• Service Providers. We share information with service providers that we have engaged to assist us with providing and improving the Services and our business operations ("Service Providers"). For example, we use Service Providers to assist with managing our Site, processing payments, fulfilling and shipping orders, providing technical support, conducting surveys and research, analytics, marketing our Services, communicating with our customers, detecting and preventing fraud, collecting overdue payments, dispute resolution, and legal compliance. We share information with Service Providers only as necessary for them to perform their functions.
• Brand Partners. We may partner with other parties, such as fashion companies and retailers, media companies, or digital creators, to jointly offer products or services to our customers ("Brand Partners"). We may share information with a Brand Partner for their direct marketing purposes, if you express interest in our jointly offered products and services. Our Brand Partners may use your information to provide marketing content and promotional offers about other products and services that may be of interest to you. Please note that we do not share text messaging opt-in data with third parties for their marketing purposes.
• Advertising Networks. We partner with advertising networks to provide advertisements that promote the Services on third-party websites and applications that may be of interest to you ("Advertising Networks"). We may share your information with Advertising Networks to provide tailored advertising content. Additionally, these Advertising Networks may collect information about your visits to our Site using Tracking Technologies. Please see Section V (Your Choices) below for information about managing your preferences in relation to targeted advertising.
• Promotion Partners. We may partner with other parties to offer or co-sponsor contests, sweepstakes, giveaways, or other promotions ("Promotion Partners"). If you decide to participate in one of these promotions, the information that you provide to participate may be shared with us and with the relevant Promotion Partner.
• Gift Recipients. If you purchase a Gift Membership, we will email your designated gift recipient (a "Gift Recipient") to notify them that they have received a gift from you. We will share your name with the gift recipient, using the name that you provide us when you purchase the Gift Membership.
• Governmental Authorities and Legal Process. We may disclose information to federal, state, and/or local governmental agencies and authorities, including those related to law enforcement ("Governmental Authorities"), if we are required to do so to comply with the law or legal processes. When permitted, we may disclose personal information to Governmental Authorities in response to their request(s) or in connection with a legal process when we believe that disclosing such information is necessary or advisable to defend against a legal claim or to protect our or others' safety, rights, or property.
• Public. Our Services may provide the opportunity to post reviews, photos, or comments in a public forum, such as our Site or on our social media profile pages. If you decide to submit this type of information through these channels, that information may be publicly available.
• Other Third Parties. We may disclose your information to other third parties when we have your consent or direction to do so.

B. Why We Disclose Information

The table below indicates the categories of personal information that we may disclose in a variety of contexts. Please note that, because this list is comprehensive, it may refer to types of information that we collect and share about other people, and not about you. The types of information that we collect and share about you will depend on how you interact with us and the Services. For example, we do not collect or share employment or education information about our customers who simply interact with us by accessing or purchasing our Services. If you agree to participate in a consumer research survey or feedback interview with us, however, we may collect and share information about your employment or education history with a Service Provider that helps us conduct consumer research and data analytics.

We do not receive money in exchange for sharing your personal information, and we have not sold personal information in exchange for money in the past twelve (12) months. However, like many other companies in the e-commerce and retail space, we share certain personal information with third parties with whom we have partnered to provide, improve, and/or advertise our Services. In certain instances, if you express interest in the products and services that we jointly offer with our Brand Partners, we may share some of your personal information with those Brand Partners for their direct marketing purposes. Under certain U.S. state law(s), these disclosures may be considered a "sale" or "sharing" for cross-context behavioral advertising purposes (also referred to as "targeted advertising"). The table below provides a list of the categories of information that we may disclose or that we have disclosed in the past twelve (12) months that may be considered a "sale" or "sharing" for cross-context behavioral advertising purposes under applicable U.S. state privacy laws(s). Please note, we do not knowingly sell or share the personal information of persons under sixteen (16) years of age.

Category of Information	Categories of Recipients to Whom We Disclose Personal Information for Business Purpose(s)	Categories of Recipients with Whom We Share Personal Information for Valuable Consideration or for Cross-Context Behavioral Advertising Purposes
Identifiers	Our Affiliates Service Providers that provide us with services related to the business purposes identified in Section II above Brand Partners whose branded products, services, or content are featured or accessible through the Services Advertising Networks Promotion Partner(s), if you have provided your information in connection with a promotion that we are co-sponsoring with the Promotion Partner(s) Gift Recipients for whom you have purchased a Gift Membership, only as necessary to identify the gift purchaser by the name provided Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Brand Partners whose branded products, services, or content are featured or accessible through the Services Advertising Networks
Physical Characteristics	Our Affiliates Service Providers that provide us with services related to the business purposes identified in Section II above Brand Partners whose branded products, services, or content are featured or accessible through the Services Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Not Applicable
Payment Information	Service Providers that provide us with services related to the business purposes identified in Section II above Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Not Applicable
Demographic Information and Certain Protected Characteristics	Our Affiliates with whom we work to achieve the identified purposes Service Providers that provide us with services related to the business purposes identified in Section II above Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Not Applicable
Commercial Information	Our Affiliates with whom we work to achieve the identified purposes Service Providers that provide us with services related to the business purposes identified in Section II above Brand Partners whose branded products, services, or content are featured or accessible through the Services Advertising Networks Promotion Partners Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Brand Partners whose branded products, services, or content are featured or accessible through the Services Advertising Networks
Internet or Other Similar Network Activity	Our Affiliates with whom we work to achieve the identified purposes Service Providers that provide us with services related to the business purposes identified in Section II above Brand Partners whose branded products, services, or content are featured or accessible through the Services Advertising Networks Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Brand Partners whose branded products, services, or content are featured or accessible through the Services Advertising Networks
Geolocation Data (Metro Area)	Our Affiliates with whom we work to achieve the identified purposes Service Providers that provide us with services related to the business purposes identified in Section II above Advertising Networks Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Advertising Networks
Sensory Data	Our Affiliates with whom we work to achieve the identified purposes Service Providers that provide us with services related to the business purposes identified in Section II above Brand Partners Public, if you share such information in a public forum, such as publishing a product review on our Site, or if you otherwise provide consent to making such content publicly available	Not Applicable
Professional and/or Education-Related Information	Our Affiliates with whom we work to achieve the identified purposes Service Providers that provide us with services related to the business purposes identified in Section II above	Not Applicable
Inferences Drawn from Personal Information	Our Affiliates with whom we work to achieve the identified purposes Service Providers that provide us with services related to the business purposes identified in Section II above Brand Partners Advertising Networks Governmental Authorities and in connection with legal processes, only as necessary or appropriate to comply with applicable law or address potentially unlawful activity	Advertising Networks

IV. Cookies and Other Tracking Technologies.

We and certain of our third-party partners use cookies and other Tracking Technologies to gather information when you interact with our Site, mobile applications, and/or email communications. Some Tracking Technologies help us maintain the security of our Site and your account, prevent crashes, fix bugs, save certain of your preferences, and assist with basic site functions. These Tracking Technologies are referred to as "strictly necessary" because they are necessary for our Services to work properly. We use "performance" cookies and other Tracking Technologies to assess the performance of our Services, for data analytics purposes, and to help us understand how our customers and Site visitors interact with the Services. We use "functional" cookies and other Tracking Technologies to personalize your experience with our Services and offer enhanced functionality when you access or use the Services. For example, we use "functional" Tracking Technologies to maintain your preferences over time and recognize you when you return to the Services.

We also permit certain of our third-party partners to use "advertising" cookies and other Tracking Technologies on our Site for analytics and advertising purposes, including to help manage and display advertisements, to tailor content to your interests, and/or to send targeted communications, such as abandoned shopping cart reminders. Our third-party partners may use information accessible through these Tracking Technologies to provide advertising about products and services tailored to your interests, and such advertisements may appear on our websites or other, third-party websites that we do not control. These third parties may also collect information over time and across other websites, in addition to our Site. Under certain privacy laws, this may be considered "targeted," "cross-context behavioral," or "interest-based" advertising. You may opt-out of these "advertising" Tracking Technologies by clicking the "Do Not Sell or Share My Personal Information" link in the footer of our Site's homepage and following the instructions to set your preferences. Please see Section V (Your Choices) and Section XI (California residents) below for more information about your options.

You may also block or delete cookies from your device by modifying your browser settings. Please note that the Services may not function properly for you if you block or delete certain cookies. To find out more information about cookies generally, including information about how to delete cookies, please visit https://allaboutcookies.org/.

V. Your Choices.

As permitted or required under applicable law, you may exercise the rights described in this section. Please note that some of your rights may vary depending on your country, province, or state of residence.

• Access to Your Personal Information. You may request us to confirm whether and how we have processed your personal information. If required by law, upon request, we will grant you access to the personal information that we have about you. In some cases, you may have the right to request that we provide you a copy of your personal information in a portable format. Please note that we will deny a request to access personal information if we are unable to verify that it is you or someone legally authorized to act on your behalf who is making the request. You may submit a request to access your personal information by doing one of the following:
  1. Clicking the "CLICK HERE TO SUBMIT A REQUEST" link at the bottom of this Privacy Policy and completing the online request form; or
  2. Contacting us by email at gwynnie@gwynniebee.com or by phone at 855-GWYNNIE (855-499-6643)
  
  
• Changes to Your Personal Information. In most cases, we rely on you to update and correct your personal information. Most of our websites allow you to modify your account profile. If our Site does not permit you to update or correct certain information, you may contact us by email at gwynnie@gwynniebee.com or by phone at 855-GWYNNIE (855-499-6643) to request that your information be modified.
• Delete Your Personal Information. You may request information about how long we keep a specific type of information, or request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that, in many situations, we may deny all or a portion of the request because we need to keep your personal information on file to continue providing you with Services, comply with our legal obligations, resolve disputes, enforce our agreements, protect against fraudulent or other unlawful activity, or for another one of our business purposes. We may also deny the request if we are unable to verify that you or someone legally authorized to act on your behalf is making the request. You may submit a request to delete your personal information by doing one of the following:
  1. Clicking the "CLICK HERE TO SUBMIT A REQUEST" link at the bottom of this Privacy Policy and completing the online request form; or
  2. Contacting us by email at gwynnie@gwynniebee.com or by phone at 855-GWYNNIE (855-499-6643)
  
  
• Opt-Out of "Sales" and/or Processing Your Personal Information for Targeted Advertising Purposes. As described in Section IV (Cookies and Other Tracking Technologies) above, our use of "advertising" Tracking Technologies may be considered a "sale" or "sharing" of personal information for targeted advertising purposes under applicable law. You may opt out of these Tracking Technologies by doing one of the following:
  1. Accessing the privacy preference center and setting your preferences via this link: Do Not Sell or Share My Personal Information, which is also accessible via the footer of our Site's homepage. Please note that, in some cases, your opt-out preferences may only be linked to your device or browser identifier. If you visit our Site from another device or using another browser (or after your original browser's cookies have been erased), you may need to renew your opt-out choice;
  2. Visiting our Site and broadcasting a legally-recognized opt-out preference signal, such as the Global Privacy Control (GPC) on the browser(s) and/or browser extension(s) that you use to access our Site, to the extent that such browser(s) and/or browser extension(s) support the signal you are using. Please note that, in some cases, your opt-out preference signal may only be linked to your device or browser identifier. If you visit our Site from another device or using another browser (or after your original browser's cookies have been erased), you may need to renew your opt-out choice. For more information about how to use the GPC browser signal, please visit https://globalprivacycontrol.org/;or
  3. Emailing us at gwynnie@gwynniebee.com with your opt-out request.
  
  As described in further detail in Section III (How We Share Information) above, we may also share certain personal information with our third-party partners for direct or targeted advertising purposes, using means other than advertising Tracking Technologies. Under applicable law, disclosing information for these purposes may be considered a "sale" or "sharing" of personal information for targeted advertising purposes. You may opt out of having your information "sold" or "shared" for these purposes, by means other than Tracking Technologies, by doing one of the following:
  1. Submitting an opt-out request using this link: Opt-Out Request Form, which is also linked within the privacy preference center that is accessible via the "Do Not Sell or Share My Personal Information" link in the footer of our Site's homepage; or
  2. Emailing us at gwynnie@gwynniebee.com with your opt-out request.
  
  
• "Do Not Track." "Do Not Track" is a privacy preference that users can set in certain web browsers. Our Services are not, at this time, configured to recognize or respond to "Do Not Track" signals transmitted by web browsers.
• Promotional Emails. You can stop receiving promotional emails by following the unsubscribe instructions in the e-mails that you receive. If you decide not to receive promotional emails, we may still send you service- and transaction-related communications.
• Promotional Text Messages. If you receive a text message from us that contains promotional information, you can opt-out of receiving future text messages by replying “STOP.” We do not share text messaging opt-in data with third parties for their marketing purposes.
• Push Notifications. We may send you push notifications through our mobile applications. You may opt out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. If applicable, you may opt out of this collection by changing the settings on your mobile device.
• Revoke Consent. If you revoke your consent for the processing of personal information, we may no longer be able to provide you Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us as described below.

Please note that, in many instances, we are only obligated to respond to verifiable consumer requests. And, in some of those instances, we are required by law to verify that the request is actually being made by you or by an agent who is legally authorized to act on your behalf, before we can grant the request.

To verify a request, we may ask you to confirm your identity by logging into your Gwynnie Bee account (if applicable), or to provide information that we can use to confirm your identity, such as your name, email address, the last item you purchased or rented from us, and/or other verifiable information. We also may implement other authentication procedures that are appropriate based on the nature of the request. If we collect any new personal information (that we have not already collected for another purpose) to verify a request, we will only use that information to verify the request and to comply with any legal obligations we have to retain a record of the request. Even if we are able to verify a request, we may nevertheless deny the request because we are either required or permitted to by law. For example, if you have a subscription with us, we are permitted to deny a request to delete your personal information because we need to keep the information on file to continue providing you Services. In some instances, you may have the right to appeal our decision to deny a privacy rights request. To appeal a decision to deny a request, please contact us at gwynnie@gwynniebee.com or at 855-GWYNNIE (855-499-6643)] and reference the nature, format, and date of your original request and describe the basis for your appeal and any other details that are relevant to our review of your appeal.

To designate an authorized agent to make requests on your behalf, please contact us (or have your authorized agent contact us) using one of the available methods for submitting requests as described above in this Section V. If we receive a request from your agent, we may reach out to you directly to confirm their authority to make the request on your behalf. We do not discriminate against individuals who exercise any of their privacy rights under applicable law.

VI. How We Protect Personal Information.

We maintain reasonable and appropriate physical, electronic, and procedural safeguards that are designed to help protect your personal information from unauthorized access, use, and disclosure. Although we work diligently to protect the personal information that is in our possession, no method of transmission over the internet or security system is 100% secure, and we cannot guarantee that our security measures will prevent all unauthorized persons from illegally accessing personal information. In the event that we are required by law to inform you of a breach of your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

If our Site permits you to create an account, you will be prompted to create a password and/or to login using credentials from a third-party network or social media platform, such as Google or Facebook. You are responsible for maintaining the confidentiality of your password and login credentials, and you are responsible for any access to or use of your account by someone else, whether or not such access or use has been authorized by you. You should notify us of any actual or suspected unauthorized use of your password or account.

VII. How Long We Retain Information.

We retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or other reporting requirements, unless a longer retention period is required or permitted by applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, and applicable legal requirements.

VIII. Children's Privacy.

Our Services are not intended for or directed toward children under the age of 13. If we become aware that a child under the age of 13 has provided us with personal information, we will delete the information from our records. If you are the parent or legal guardian of a child whose information you believe has been provided to us without your consent, please contact us at gwynnie@gwynniebee.com.

IX. Other Important Information

The following additional information relates to our privacy practices:

• Transmission of Information to Other Countries. CaaStle Inc. is located in the United States. The Services are hosted in the United States and are intended for and directed to consumers in the United States. If you do not reside in the United States and submit personal information to us, your information may be processed in a country where privacy laws may be less stringent than the laws in your country of residence. Nonetheless, where possible, we take steps to treat personal information using the same privacy principles that apply under the law of the country in which we first received the information. By submitting your personal information to us, you agree to the transfer, storage, and processing of your information in a country other than your country of residence, including, but not necessarily limited to, the United States.
• Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own or control. In the event that we provide links to other websites or applications that we do not control, whether or not those other websites or applications refer to our products, Services, or branding, this Privacy Policy does not apply to those other websites or applications. Visitors to those websites and applications are advised to read the policies on those websites and applications.
• Changes to This Privacy Policy. We may modify this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Site, with the effective date posted at the top of the Privacy Policy. If we make changes that materially affect your privacy rights, we will use reasonable efforts to notify you of such changes. By visiting the Site or using the Services after the effective date, you are deemed to have notice of our then-current Privacy Policy.

X. Contact Information.

If you have any questions, comments, or concerns about our privacy practices, please contact us by one of the following methods:

By e-mail, at gwynnie@gwynniebee.com ,
By phone, at 855-GWYNNIE (855-499-6643), or
By writing to us at the following address:

CaaStle Inc.
5 Penn Plaza, Fl. 4
New York, NY 10001
Attn: Legal Department

XI. Information for California Residents.

California law requires us to disclose the following information with respect to our privacy practices. If you are a California resident, this section applies to you, in addition to the rest of this Privacy Policy.

• California Shine the Light Law. California residents may request information about the categories of personal information (if any) that we share with third parties for those parties' direct marketing purposes. To do so, please contact us by email at gwynnie@gwynniebee.com or by phone at 855-GWYNNIE (855-499-6643).
• Categories of Personal Information We Collect, Sources of Collection, and Purposes for Collection. Please see Section I (How We Collect Information) and Section II (Types of Information We Collect and Why) of this Privacy Policy for a list of the categories of personal information that we collect, the categories of sources from which we collect personal information, and our business purposes for the collection and use of personal information.
• Categories of Personal Information Disclosed, Categories of Recipients, and Purposes for Disclosure. Please see Section III (How We Share Information) of this Privacy Policy for a list of the categories of personal information that we may disclose or that we have disclosed to third parties in the past twelve (12) months for our business purposes and the categories of recipients.
• "Sale" and/or "Sharing" of Personal Information. Under California's privacy law(s), "sale" is broadly defined as the transfer of personal information to a third party for valuable consideration (even if there is no exchange of money), which includes many disclosures of information that go beyond the ordinary concept of a sale. Please see Section III (How We Share Information) of this Privacy Policy for a list of the categories of personal information that we may disclose or that we have disclosed to third parties in the past twelve (12) months that may be considered a "sale" or "sharing" for cross-context behavioral advertising purposes under California's privacy law(s). Please see Section V (Your Choices) above for information about how you can exercise your right to opt out of the "sale" and "sharing" of your information.
• Right to Access. Subject to certain limitations, and in addition to the choices described in Section V of this Privacy Policy, a California resident has the right to request access to the specific pieces of personal information that we collect about them and the right to know the categories of personal information that we collect, disclose, "sell" or "share," our business purpose(s) for doing the foregoing, the categories of recipients to whom or with whom we have disclosed, "sold," or "shared" personal information, and the categories of sources from which we have collected personal information. Please note that we are required by law to verify that a request to access your personal information is being made by you or by an agent who is legally authorized to act on your behalf. Please see Section V (Your Choices) above for more information about how to exercise your right to access your personal information. Please note that we are only required to respond to an individual consumer's request for access twice within a twelve (12)-month period.
• Right to Delete Your Personal Information. A California resident has the right to request that we delete the personal information that we have collected about them. Please see Section V (Your Choices) above for more information about how to exercise your right to request the deletion of your personal information and for information about how we verify your identity.
• Right to Limit the Use of Your Sensitive Personal Information. Under certain circumstances, California residents have the right to limit the use of their "sensitive personal information," as that term is defined by applicable California law. We do not use or disclose sensitive personal information for any purpose that gives rise to a right to limit the use of sensitive personal information under applicable California law. We only use sensitive personal information to provide you Services, to maintain the security of our Services and your information, or as we may otherwise expressly disclose to you at the time we collect the information. We do not use or disclose any sensitive personal information to infer characteristics about you or to conduct advertising of any kind.
• Notice of Financial Incentive. Our Referral Program provides participating customers with certain perks, such as referral credits and promotional offers. We also may conduct other promotional activities, such as sponsoring sweepstakes or contests. When you participate in our Referral Program or one of our promotional campaigns, we may ask you to provide certain personal information, such as your name and contact information. Because these programs involve the collection of personal information, they may be interpreted as a "financial incentive" program under California law. We do not assign a monetary value to the information we collect. Based on our reasonable estimate, the value of personal information that you provide to us is related to the value of the free or discounted product, services, or other benefits that we may provide through the applicable program, less the expense related to offering those products, services, and other benefits to program participants. You may withdraw from participating in our Referral Program and any other promotional campaigns at any time by contacting us at the designated method set forth in the program's rules or in our Terms of Service.

CLICK HERE TO SUBMIT A REQUEST.