PRIVACY POLICY

Introduction

We value your privacy and are committed to protecting your personal data. When you visit our website www.pagerie.com and/or its subdomains (hereinafter: “Site”), make a purchase in our webshop, or sign up for our newsletter, Pagerie (“Pagerie” or “we”) processes personal data. We also process personal data when you apply for a job at Pagerie. Furthermore, we process the personal data of our suppliers. The term “personal data” includes all information about an identified or identifiable natural person. In the processing of personal data, Pagerie qualifies as the controller, according to its meaning in the U.S. Privacy Act of 1974 (USA).

This Privacy Policy aims to inform you how Pagerie collects and processes your personal data and to provide you with information on your legal rights under the U.S. Privacy Act of 1974.

We point out that we do not intend to collect personal data from persons younger than 18 years of age, unless they have permission from their parents or guardians. As we cannot verify if a person is older than 18 years, we strongly advise that parents be involved in their children’s online activities.

Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide the requested data, we may not be able to perform the agreement we have, or are trying to enter into, with you (e.g. to provide for you the products you would like to order). If this is the case, we may need to cancel the order you have placed with us, notifying you beforehand.

It is important to read this Privacy Policy together with our Terms of Use and Terms and Conditions.

Table of Contents

About us

Personal data we collect and purposes for which these data are collected

Legal grounds for processing

To whom do we provide your personal data?

How long do we store your personal data?

Security of your personal data

Your privacy rights

How can you file a privacy complaint?

Changes to this Privacy Policy

About us

Pagerie is a private company, established under American law, based in Los Angeles, CA (The United States of America) and registered with the state of California under file number _____. We trade under the trade name “Pagerie”.

If you have any questions regarding our Privacy Policy or on how your personal data are handled, or if you wish to exercise your privacy rights, please direct your inquiry to info@pagerie.com or contact us using the address below.

Pagerie

8391 Beverly Blvd PO Box #437

Los Angeles, CA

USA 90048

Please note that this Privacy Policy is not applicable to third-party websites connected to this Site through links or applications. Clicking on such links may allow third parties to collect or share data about you. We cannot guarantee that these third parties will handle your personal data in a secure and careful manner, as we do not control these websites and are not responsible for their privacy policies. We therefore recommend you read the privacy policies of these sites before clicking on any links or making use of the websites accessed by such links.

Personal data we collect and the purposes for which these data are collected

Pagerie may collect the following categories of Personal Information:

Customers and potential customers

We may process the following (categories of) personal data of (contact persons of) our (potential) customers if and when necessary for our order administration:

Name and address details (surname, first names, initials, title, gender, address, postal code and place/country of residence);

Date of birth;

Email address;

Payment details;

Order details, including order history.

We process this data for the following purposes:

If applicable: to register you as a new client;

To inform and contact you about your order, our products, ordering methods, payments and applicable conditions;

Delivery of ordered goods;

Dispute resolution, including debt collection;

To comply with our legal and regulatory obligations.

We may process the following (categories of) personal data of (contact persons of) our (potential) customers if and when necessary for our service administration:

Name and address details (surname, first names, initials, title, gender, address, postal code and place/ country of residence);

Telephone number;

Date of birth;

Email address;

Order details;

Payment details;

Service requests;

Other personal data that may be processed in the context of handling the service request, such as order history.

We process this data for the following purposes:

Responding to questions;

Providing service;

Logging data for insight and improvement;

Creating replacement orders;

Dispute resolution;

To comply with our legal and regulatory obligations.

We may process the following (categories of) personal data of (contact persons of) our (potential) customers in our client marketing database:

Name and address details (surname, first names, initials, title, gender, address, postal code and place/country of residence);

Email address;

Telephone number;

Date of birth;

Transactional data such as order history;

For direct marketing messages: email address, IP-address, open ratio and time of opening, click ratio including timestamp regarding visited URLs.

We process this data for the following purposes:

Provision of information about ourselves and our products, including updates on changes to our Terms and Conditions, Terms of Use and Privacy Policy;

Direct marketing relating to our products and/or services, including promotions, contests, prize draws and events connected therewith;

To analyze whether our messages are opened and to establish which parts of our messages are the most interesting for our newsletter subscribers;

Research and development;

Dispute resolution;

To comply with our legal and regulatory obligations.

Pagerie collects Personal Information from the following categories of sources:

• From you or a member of your household

• From other individuals acting on your behalf, such as personal shoppers or assistants

• From devices associated with you or a member of your household, including through cookies, web beacons or similar technologies, when you visit our Sites or online applications, or open our emails

• From other companies affiliated with Pagerie

• From third-party information brokers

Newsletter subscribers

We have a newsletter to inform those interested of our products and/or services, as well as contests, prize draws and other events. The newsletter is event-based, meaning that it will be sent when certain events occur (such as a new product being launched). Your email address will be added to the list of subscribers only with your explicit consent. The newsletter is aimed at driving engagement and may include information about new products, promotions and events. We can measure when, and to what extent, newsletters are opened and on which links in the newsletter you click. Each edition contains a link through which you can unsubscribe from the newsletter.

When you sign up to our newsletter, we process the following personal data:

Your email address;

IP-address;

Open ratio and time of opening;

Click ratio, including a timestamp of visits to URLs in our newsletters.

We process this data for the following purposes:

To send you our newsletter;

To analyze whether our newsletter is opened and to establish which parts of our newsletter are the most interesting for our newsletter subscribers;

Dispute resolution;

To comply with our legal and regulatory obligations.

Site users

When you visit our Site, we analyze your use of it through cookies and similar technologies. You can set your browser to (partially) disable or opt out of cookies. Please read our Cookie Policy for more information about the use of cookies.

We may process the following (categories of) personal data of all our Site users (whether you make a purchase or not):

Information on how you use and interact with our Sites, as well as on the amount of time that you spend on it;

Basic information relating to the request from your browser when you visit the Sites. These data may include information such as your last visit date and time, the duration of your visit, the time stamp of the browser request, your IP address and basic HTTP header information (such as referral URL and user agent), information about the website you have previously visited, as well as demographic information, including your location.

We process this data for the following purposes:

Analyzing and improving the use of the Site, including optimizing your operation and experience of the Site

Marketing purposes (advertising)

Dispute resolution

To comply with our legal and regulatory obligations

Suppliers

We may process the following (categories of) personal data of persons from whom we purchase products or services or who work at our suppliers, if and when necessary in our supplier administration:

Name and address details (surname, first names, initials, title, gender, address, postal code and place/country of residence);

Other contact data (telephone number, email address and similar data required for communication);

Information about your company such as company name, business address, postal code, business email address and telephone number;

In some cases, depending on the type of service provision: a certificate of good conduct and data relating to an identity document;

Data in view of making orders or purchasing services;

Data for calculating and recording fees and expenses and making payments, including bank account numbers;

Other data, the processing of which is required or necessary to comply with applicable legislation.

We process these data for the following purposes:

Placing orders and purchasing services;

Calculating and recording income and expenses and making payments;

The collection of receivables, including placing those receivables in the hands of third parties and other internal management activities;

Arranging the transport of goods and services to be delivered to the parties involved;

Maintaining contact between ourselves and customers or suppliers;

Dispute resolution and audits;

Cooperating in the levy or collection of taxes;

To comply with our legal and regulatory obligations.

Job applicants

If you apply for a job at Pagerie, we may process the following (categories of) personal data, if and when necessary, in dealing with your job application:

Surname, first names, initials, title, gender, address, postal code, city;

Telephone number, e-mail address and similar information required for communication;

Date of birth, place of birth, nationality;

Content of your CV, and details of your educational attainment, employment history, references and availability;

Your reasons for applying;

information regarding the position for which you have applied;

Bank account number (for expense allowance only).

We process this data for the following purposes:

The assessment of the suitability of the person concerned for a position that is or may be vacant (recruitment and selection), including dealing with related questions and complaints;

Dealing with any expenses incurred;

Internal checks and business security services;

To comply with our legal and regulatory obligations.

Legal grounds for processing data

We process your personal data on the basis of one or more of the following legal grounds:

• When this is necessary for the performance of an agreement to which you are a party or for the performance of pre-contractual acts at your request, e.g. needing to process your information to be able to handle your order;

• When this is necessary to comply with a legal obligation;

• When this is necessary to promote our legitimate interests or the interests of a third party, e.g. to manage our relationship with you;

• With your consent, e.g. when you sign up to our newsletter.

If our processing of your personal data depends on your consent, we will request this separately from you. You may withdraw this consent at any time, but please note that such a withdrawal does not affect the lawfulness of the prior processing of your personal data

If you have specific questions about the legal grounds on which certain personal data are being processed, we would be happy to provide you with additional information – and you are always welcome to contact us via info@pagerie.com

To whom do we provide your personal data?

We do not disclose your information to third parties (‘recipients', as defined in privacy legislation), unless necessary for the proper performance of the purposes described in this Privacy Policy. For example: to fulfill your order, we need to share your data with payment providers and transportation companies. We may share personal data with our service providers, such as hosting providers, e-mail services and (other) software suppliers, payment service providers, transportation companies, lawyers etc. Furthermore, we may share your data when necessary to defend the rights or property of Pagerie, or its customers and employees, and the personal safety, property or other rights of the public.

The third parties to whom the personal data is made available are obliged to treat your personal data confidentially. If these parties are regarded as 'processors' (as defined in privacy legislation), we will ensure that a data processing agreement is concluded with them that meets the requirements set out in the U.S. Privacy Act of 1974.

Your personal data may be included in the acquisition of Pagerie, in whole or in part; the sale of some or all of Pagerie; a merger or merger involvement; or during a bankruptcy, dissolution or other transition of our business. This means that your personal data may be transferred to a new owner or successor entity to ensure that our services can be continued.

In order to provide our services, it may be necessary for us to transfer your personal data to a recipient in a country outside the United States of America that offers a lower level of protection of personal data than that provided by U.S. legislation. In such a case, Pagerie will ensure that the transfer of personal data is in accordance with applicable legislation, for example by concluding a model contract drawn up and approved for that purpose by the U.S. Commodity Futures Trading Commission.

How long do we store your personal data?

We will not retain your personal data in an identifiable form for any longer than is necessary for the purposes set out in this Privacy Policy.

The personal data in our order administration will in principle be deleted at the latest two years after the order in question has been processed. The personal data used for website analysis are stored for a maximum of 24 months. The personal data in our service administration and client marketing database are retained for five years after closure of the client file. The e-mail address used for your newsletter subscription is removed from our mailing list as soon as you choose to unsubscribe.

The personal data of suppliers will in principle be deleted at the latest two years after the order in question has been processed.

The personal data provided to us for your job application will be retained for up to four weeks after the end of the application procedure. You can choose to provide us with consent to retain your personal data for one year after the end of the application procedure. This enables us to reach out to you if job opportunities which may be of interest to you, become available. The personal data that you have provided in the context of your application will become part of your personnel file when you start working for Pagerie.

In addition to the above-mentioned retention periods, we may need to retain certain personal data in order to comply with statutory retention obligations. For example, in connection with our tax retention obligation for (tax) business operations, we may need to retain certain accounting data for seven years from the end of the year in which the relevant data have lost their current importance.

There may arise a need to comply with an extension of the specific retention periods referred to above, and legal retention periods may become applicable. We may also retain personal data for a longer period of time if necessary for our legitimate interests, such as in the settling of legal disputes.

Security of your personal data

We have security measures in place to reduce the likelihood of misuse, loss and unwanted disclosure of, and unauthorized access to, personal data. Our employees and business partners are bound by confidentiality and by instructions aimed at the adequate protection of your personal data.

We have procedures in place to deal with personal data breaches and will notify you and the applicable regulator of such a breach where we are legally required to do so. If you have any questions about the security of your personal data, or if you suspect or have any indications of misuse, please contact us at info@pagerie.com

Your privacy rights

You have the following rights with regard to the processing of your personal data by us:

• the right to enquire whether we process your personal data and, if this is the case, to inspect your personal data;

• the right to rectification of your personal data if they are incorrect or incomplete;

• the right to have your personal data deleted ("right to be forgotten");

• the right to object to the processing of your personal data or to limit the processing of your personal data;

• the right to withdraw consent for the processing of your personal data at any time, if the processing is based on your consent;

the right to receipt or transfer of your personal data by or to a third party designated by you in a structured, customary and machine-readable form ('right to data portability').

If you wish to exercise any of the rights above, please contact us via info@pagerie.com or via the address mentioned in the ‘About us’ section.

Please be aware that in order to prevent fraud and misuse, we may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request. If you wish to inspect personal data linked to a cookie, please be sure to include a copy of the relevant cookie. You will find the cookie in your browser settings.

Within a month of receipt of your request, we will inform you whether we can comply with your request. This period may be extended by up to two months in specific cases – for example, when a complex request is made. We will inform you of such an extension within one month of receipt of your request. Based on privacy legislation, we can refuse your request under certain circumstances. If we do so, we will explain the reasons for the refusal. If you object to the processing of your personal data for direct marketing purposes, we will always respect this request. You can find more information about your privacy rights on the website of the U.S. Privacy Act of 1974.

Your California Privacy Rights. Under California's "Shine the Light" law, California residents who provide Personal Information to us in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once a calendar year, information about the customer information that we disclosed, if any, to other businesses for their own marketing purposes in the immediately prior calendar year. This request may be sent electronically by email to info@pagerie.com and we will respond to these requests within 30 days. Written requests may be sent to Pagerie, 8391 Beverly Blvd PO Box #437, Los Angeles, CA, USA 90048 Attn: Customer Care. Requests for this information that come to us through other channels may result in a delayed response. Please be aware that not all information-sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

CHILDREN UNDER THE AGE OF 13

The Sites are not directed to children, and we do not intentionally collect or maintain any Personal Information from children under the age of 13 years. If you believe that we might have any Personal Information from or about anyone under the age of 13, please contact us at info@pagerie.com

How can you file a privacy complaint?

If you have a complaint about the processing of your personal data by us, we will do our utmost to resolve it with you. You have the right to lodge a complaint with the competent supervisory authority at any time.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy and will always post the most recent version of this Privacy Policy on our website. If substantial changes are made that could significantly affect one or more data subjects, we will strive to inform the relevant data subjects immediately.

This Privacy Policy was last amended on 06-11-2020.