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PRIVACY POLICY

Effective February 14, 2019

K. Noelle Holdings dba Home & Aura ("Home & Aura") provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of www.Home & Aura.com ("Site") and our mobile applications ("Apps"). This Privacy Policy applies only to information that you provide to us through this Site and the Apps. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site and Apps. You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Home & Aura Terms of Use, accessible at Terms.

As used in this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

INFORMATION, COLLECTION AND USE

Our primary goals in collecting information are to provide and improve our Site, Apps, services provided on the Site and Apps, including features and content (collectively, the "Service"), to administer your Home & Aura account ("Account") and to enable users to enjoy and easily navigate the Site and Apps.

PERSONALLY IDENTIFIABLE INFORMATION

In the course of using the Service, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your name, email address, phone number and credit card number and other billing information ("Personal Information").

We collect Personal Information in connection with your registration to join our Service. You can register to join via the Site or Apps or by logging into your account with certain third party social networking sites ("SNS") (including, but not limited, to Facebook and Twitter) via our Site or Apps. If you decide to register by logging into an SNS, we will obtain the Personal Information you have provided to the SNS (such as the name you provided the SNS, profile picture, email address and other information you make publicly available via the applicable SNS) from the account you have with such SNS and use that information to create your Account and you will become a registered user of Home & Aura ("Registered User"); the information we obtain may depend on the privacy settings you have with the SNS. The Personal Information an SNS has about you is obtained by the SNS independent of our Service. Other services including the SNS follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other services you use.

We also collect other information that you provide as part of registration and your use of the Service ("Non-Identifying Information").

We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) to provide the Service, complete your transactions, and respond to your inquiries.

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (e.g., combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (e.g., your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Home & Aura Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site, Apps and Service are used.

We also use your Personal Information to contact you with Home & Aura newsletters, email updates, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please click 'Unsubscribe' at the bottom of your email (no login required) or update your Account's 'Notifications' section by logging into your Account and clicking on the 'Notifications' tab when you are on your user settings page.

LOG DATA

When you visit the Site or Apps, whether as a Registered User or a non-registered user just browsing (any of these, a "Home & Aura User"), our servers automatically record information that your browser sends whenever you visit a website or mobile app ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site or Apps, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site, Apps and the Service and for the Site's technical administration, to increase our Site's or Apps’ functionality and user-friendliness, and to better tailor it to our visitors' needs. For example, some of this information is collected so that when you visit the Site again, it will recognize you and serve information appropriate to your interests. We also use this information to verify that visitors to the Site or Apps meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.

COOKIES

Like many websites, we use "cookies" to collect information. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your registration ID and login password for future logins to the Site. Second, we utilize session ID cookies to enable certain features of the Site or Apps, to better understand how you interact with the Site and/or Apps and to monitor aggregate usage by Home & Aura Users and web traffic routing on the Site or Apps. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site or Apps and then close your browser. You can instruct your browser, by changing the settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site, Apps or all functionality of the Service.

PHISHING

Identity theft and the practice currently known as "phishing" are of great concern to Home & Aura. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your Account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission's website.

INFORMATION SHARING AND DISCLOSURE

Registered Users Information. When you register to join the Site and submit your Personal Information to create a profile webpage, Registered Users will see the name you have chosen to identify yourself on the Site ("Required Member Identifiers"). You can choose what other Personal Information you provide as part of your profile ("Other Member Information"). Providing Other Member Information is voluntary and should correlate with the degree of interaction you want to have with Registered Users.

Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Service Providers. We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., payment processing services, maintenance services, database management, security and fraud purposes, web analytics and improvement of the Site's and Apps’ features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We will use commercially reasonable efforts to contractually ensure that these third parties provide the same or comparable level of protection with respect to Personal Information as set forth herein.

Compliance with Laws and Law Enforcement. Home & Aura cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Home & Aura or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

Business Transfers. Home & Aura may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

CHANGING OR DELETING YOUR INFORMATION

All Registered Users may review, update, correct or delete the Personal Information in their registration profile through their profile page. If you would like us to delete your record in our system, please contact us at info@HomandAura.com with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

SECURITY

Home & Aura is very concerned with safeguarding your information. We are not in the business of providing information security. We do employ limited data security measures, such as encryption, on some but not all systems. Do not provide your information if you are concerned with its disclosure.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable laws and regulations on security breach notification) to you via email or conspicuous posting on this Site in compliance with applicable laws and regulations and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

INTERNATIONAL TRANSFER

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Home & Aura transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

FOR EEA AND SWISS INDIVIDUALS

Home & Aura complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, as applicable (collectively, the "Privacy Shield Framework") as set forth by the US Department of Commerce regarding the collection, use and retention of personal information transferred from European Economic Area (EEA) member countries and/or Switzerland, as applicable, to the United States. Home & Aura has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program and to view our certification page, please visit https://www.privacyshield.gov. The Federal Trade Commission has jurisdiction over Home & Aura’s compliance with the Privacy Shield Framework.

Home & Aura is accountable for information that it receives under the Privacy Shield Framework and subsequently transfers to a third party. Home & Aura may transfer information provided by Home & Aura Users to third parties described above in this Privacy Policy. Home & Aura is responsible under the Privacy Shield Principles if third parties to whom it transfers information to process this information on Home & Aura’s behalf do so in a manner inconsistent with the Privacy Shield Principles. In cases of onward transfer to third parties of personal data of EEA or Swiss individuals received pursuant to the EU-US Privacy Shield or the Swiss-US Privacy Shield, respectively, Home & Aura is potentially responsible. Home & Aura may also be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EEA and Swiss individuals have the right to access the personal data that Home & Aura maintains about you, as that term is defined in the Privacy Shield Framework, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please email info@HomeandAura.com.

In compliance with the Privacy Shield Principles, Home & Aura commits to resolve complaints about our collection or use of your personal information. EEA and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Home & Aura at: info@HomeandAura.com. For any complaints that cannot be resolved with Home & Aura directly, Home & Aura commits to cooperate with EEA data protection authorities and the Swiss Federal Data Protection and Information Commissioner, as applicable and comply with the advice given by EEA data protection authorities and/or Information Commissioner with regard to data transferred from the EEA and Switzerland, as applicable. A binding arbitration option may also be made available to you in order to address Privacy Shield complaints not resolved by any other means.

Retention of personal information of EEA individuals will be handled in accordance with Home & Aura’s data retention policy. Where Home & Aura processes personal data of EEA individuals as a data controller, such individuals: (i) may have the right to request access to and rectification or erasure of personal information by emailing info@HomeandAura.com; (ii) may restrict the processing of personal information, object to processing, and/or exercise the right of data portability; and (iii) may have certain rights to withdraw consent without affecting the lawfulness of processing and the right to lodge a complaint with a supervisory authority. For any requests or information regarding the rights set out above, please contact us by emailing us at info@HomeandAura.com.

LINKS TO OTHER SITES

Our Site and Apps may contain links to other websites. If you click on another third party link, you will be directed to that third party's website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

OUR POLICY TOWARDS CHILDREN

The Site and Apps are not directed to people under the age of 18. We do not knowingly collect personally identifiable information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@HomeandAura.com. If we become aware that a child under 18 has provided us with Personal Information, we will delete such information from our files.

If you have any questions regarding our legal policies, please email us: info@HomeandAura.com

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