Effective Date: 8/16/2024

1. Introduction

This Privacy Policy outlines the policies and procedures of Gori Company (“Gori”, “we”, “our”, or “us”) regarding the collection, use, and disclosure of information from customers, visitors and users of our sites, our other online products and our services that link to this Privacy Policy (collectively, the “Services”). This policy applies to information we collect or receive:

  1. While on or using the Services;
  2. When you interact with our advertising or applications on third-party websites and services, if those applications or advertising include links to this policy;
  3. Offline, in accordance with relevant law, including, but not limited to, the California Consumer Privacy Act (CCPA).

By using the Services, you consent to the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction, and other uses of your information as described in this Privacy Policy.

We respect your privacy and are committed to protecting your Personal Identifiable Information (PII) which is any data that can be used to identify a specific person. PII does not include aggregated or anonymized information, provided it does not and cannot identify you.

2. Principles of the Gori Privacy Policy

Gori does not rent or sell your PII. We don't share your PII with anyone except to comply with the law, to provide a service you have requested, to protect our rights, or as provided in this Privacy Policy. We don't store PII on our servers unless required for the on-going operation of one of our Services.

3. What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of PII gathered when you are using or accessing the Services. It also covers our treatment of any PII that our business partners share with us or that we share with our business partners. This Privacy Policy does not apply to the practices of third-parties that we do not own or control, including any third-party websites, services, and applications ("Third-Party Services") that you elect to access through the Services, or to individuals that we do not manage or employ. We encourage you to carefully review the privacy policies of any Third-Party Services you access.

4. Country of Processing

We operate the Services from the United States of America (USA) and our data collection and processing activities take place predominantly in the USA. Accordingly, data collected from users when using our Services is collected in the USA. We store and otherwise process data, including PII, through Third-Party Services which may be located or which may operate in other countries.

5. What Information Do We Collect and How It Is Collected?

While not all information that you provide or that we collect is PII, this policy includes all the information we collect, that you provide, or that is provided to us by Third-Party Services, including PII. In connection with certain aspects of the Services, we may request, collect and/or display some of your PII.

We collect the following types of information from our users:

  1. Contact Information. Your name, email address, phone number and mailing address.
  2. Account Information. Name, username, email address, phone number, billing address, shipping address and account login credentials to Third-Party Services.
  3. User Content. Some features of the Services allow you to provide content to the Services, such as written comments and videos.
  4. Transaction Information. Name, email address, phone number, payment and billing information.
  5. Device Information. IP address, geolocation data, device information, cookie information, browser type, browser version and browser language.
  6. Session Information. Browsing behavior, referring sites, page visits, page exits, clicks, cursor movements, searches on the Services and customer service interaction.
  7. Cookie Information. Account information, Device Information and Session Information as described in this section. More information on Gori's Cookie Policy can be found in section 6,{' '} How We Use Cookies and Similar Technologies.

6. How We Use Cookies and Similar Technologies

We use cookies and similar tracking technologies to track the activity on our Services. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Cookies are typically stored upon your consent when you visit a website. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our websites.

Cookies used on websites are generally for two categories:

  • Functional. These cookies are required to enable basic functionality of a website, such as your ability to sign in to the Services.
  • Performance. These cookies collect information that allows us to improve functionality of our Services and your experience on the Services by tracking usage.

We do not use Targeting cookies or any third-party cookies on our Services for advertising purposes.

You can choose to have your device or browser limit or disable the use of cookies. You can do this through your browser settings on each browser and device that you use. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to features that make the Services more efficient and some of the features of the Services may not function properly.

7. How We Use the Information That We Collect

We and authorized third-parties engaged by us to provide services may use the information we collect on the basis of various legal grounds, which are more fully explained in this section. For example, we may use the information for compliance purposes, in situations where you provide consent for its use, as might be required to perform a contract with you, or for other legitimate business purposes. More specifically, legitimate business purposes may include the following:

  1. To enable us to operate the Services and to enable you to use them efficiently;
  2. Insofar as permitted under applicable law, to communicate with you in relation to our services and legal practice;
  3. To personalize, test, monitor, improve and upgrade the Services;
  4. To assist law enforcement and respond to subpoenas;
  5. To meet our legal obligations and the regulatory requirements to which we are subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third-parties; and
  6. For our internal business purposes, such as compiling and analyzing (on an aggregated and non-personally identifiable basis) usage information for general operational, statistical and business purposes.

We may combine or aggregate any PII we collect for any of the above purposes.  We anonymize your PII in such a way that you may not be re-identified by us or any other organization.

8. How We Share Your PII

When you access or use the Services, we collect, use, share, and otherwise process your PII as described in this Privacy Policy. Gori does not disclose PII to any Third-Party Services without your consent or as part of your normal operations in using the Services. If you access Third-Party Services, such as Google through the Services to login to the Services or to share information about your experience using the Services with others, these Third-Party Services may be able to collect information about you, including information about your activity using the Services, and they may notify your connections on the Third-Party Services about your use of the Services, in accordance with their own privacy policies. Please review those policies carefully to understand how those parties will treat your information. Outside of such mechanisms, the Services do not disclose PII to any Third-Party Services.

We may disclose your PII when it is necessary:

  • For us to provide the Services to you.
  • To protect the vital interests of yourself or others.
  • For compliance with a legal obligation (such disclosures may be carried out without notice to you)
  • In the public interest.
  • For the purposes of our legitimate interests or those of a third-party.

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Services or otherwise through the Services. Such content becomes publicly available and can be collected and used by others.

We do not use your email address or other PII to send marketing messages unless you've opted in to receive such messages. We may use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major changes in the Services or for customer service purposes). We use both your PII and certain non-PII to improve the quality and design of the Services and to create new features, functionality, and services.

Gori will not share PII about you with other people or companies without your consent except to provide products or services you've requested and under the following circumstances: Gori may be required to disclose PII under special circumstances, such as to comply with legal processes or to establish or exercise our legal rights.

Gori reserves the right to disclose PII and/or non-PII that Gori believes is appropriate or necessary to enforce our Terms, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Services, and to protect the rights, property, or personal safety of Gori, our users, or others.

Third-Party Services. We may share your information, including PII, with Third-Party Services who perform various functions to enable us to provide our Services and help us operate our business, including, but not limited to, postal and delivery carriers, as well as platforms and software that provide the following: shopping and payment processing; website design; email, telephone and SMS (text messaging) communications; advertising; fraud detection and prevention; customer care; third-party surveys; or analytics.

Carrier Services. Use of carrier services via our Services is at your own risk. We are not responsible for your use of carrier services. Your use of carrier services is as a direct customer of the specific carrier of your choosing and you agree to be bound by the terms and conditions of that carrier for use of services. By providing information to certain carrier services, you understand and consent to the collection, use, processing disclosure and transfer of such information and which they may have different data protection practices. Your interactions with these carrier services are governed by each carrier's privacy policy referenced in the following privacy statement sections.

For more information regarding other specific carriers you may use via our Services, please see the privacy policies provided by each specific carrier you select.

United States Postal Service (USPS) Privacy Statement. We collect certain information about you on behalf of the USPS. The USPS also may send us tracking information from their scans of your mail and packages in the mailstream. Our uses for the information include informing you about the status of your mail and packages through options like USPS tracking, fraud detection and aggregating the information to help the USPS and us provide you better service. Information collected on behalf of USPS is used for the regulatory oversight function of USPS.

As part of our providing services of the USPS, the USPS requires that you agree to the following USPS Privacy Act Statement and to provide information about yourself that will be maintained in a Privacy Act System of Records by the USPS.

Privacy Act Statement: Your information will be used to facilitate the purchase of USPS postage and fulfill transactional reporting requirements for USPS postage systems. Collection is authorized by 39 U.S.C. 401, 403, and 404. Providing the information is voluntary, but if not provided, your transaction may not be processed. The USPS does not disclose your information to third-parties without your consent, except to facilitate the transaction, to act on your behalf or request, or as legally required. This includes the following limited circumstances: to a congressional office on your behalf; to financial entities regarding financial transaction issues; to a USPS auditor; to entities, including law enforcement, as required by law or in legal proceedings; and to contractors and other entities aiding us to fulfill the Services (service providers). USPS shall use the aforementioned information in accordance with the USPS Privacy Policy:

https://about.usps.com/who/legal/privacy-policy/full-privacy-policy.htm

FedEx Privacy Statement: Participant acknowledges and agrees that their identity, contact information, account information and FedEx shipping information and data may be provided by FedEx to Gori and by Gori to FedEx. FedEx shall use the aforementioned information in accordance with the FedEx Privacy Notice:

https://www.fedex.com/en-us/trust-center/privacy.html

UPS Privacy Statement: Participant acknowledges and agrees that their identity, contact information, account information and FedEx shipping information and data may be provided by UPS to Gori and by Gori to UPS. UPS shall use the aforementioned information in accordance with the UPS Privacy Notice:

https://www.ups.com/us/en/support/shipping-support/legal-terms-conditions/privacy-notice.page

9. How Long We Retain Your Information

Some features of the Services allow you to provide content to the Services, such as written comments. All content submitted by you to the Services may be retained by us indefinitely, even after you deactivate your account, unless the content contains PII, in which case you can request that the content be provided to you and/or deleted. We may continue to disclose such content to third-parties in a manner that does not reveal PII, as described in this Privacy Policy.

Because we need your PII to provide you the Services, we generally keep your PII, including sensitive PII, while you use the Services or until you tell us to delete your information. We may also keep PII to comply with legal obligations or protect our or other's interests.

10. Data Security and Change of Control

Your Account information is password-protected. Gori uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your PII. We cannot ensure or warrant the security of any information you transmit to Gori and you do so at your own risk. If Gori learns of a security system breach, we may notify you electronically so you can take appropriate protective steps. Gori may post a notice to the Services if a security breach occurs.

11. What Information of Yours Can You Access?

As required by applicable laws, and subject to any permitted exceptions and limitations, we will comply with any verified data subject access request you submit with respect to your PII. Please submit a verifiable data subject access request to us as described in section 18, Contact Us.

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings. California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of PII which we share with our affiliates and/or third-parties for marketing purposes, and providing contact information for such affiliates and/or third-parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:

ATTN: Data Protection Officer
1047 S Placentia Avenue
Fullerton, CA 92831

12. What Rights Do You Have Over Your Information?

You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features. You can deactivate your Account. Please note that we will need to verify that you have the authority to deactivate the Account, and activity generated prior to deactivation will remain stored by us and may be publicly accessible.

You can ask us to confirm whether or not your PII is being processed and, if so, to provide you with access to the information and an explanation of the purposes of the processing, the categories of personal data concerned, the categories of recipients of the data, and the period for which the data are stored. You can also withdraw your consent or object to the processing of your PII, request that we correct or erase your PII, or obtain a copy of your PII from us.

Depending on where you live, how you use the Services, and subject to certain exceptions, you may have some or all of the following rights:

  • Right to Know: The right to request that we disclose to you the PII we collect, use, or disclose about you, and information about our data practices;
  • Right to Correct: The right to request that we correct inaccurate PII that we maintain about you;
  • Right to Delete: The right to request that we delete PII that we have collected about you;
  • Right to Opt-Out: The right to opt-out of the sale or sharing of their PII; and
  • Right to Non-Discrimination: The right to non-discrimination for exercising your CCPA rights.
  • Right to Limit. The right to limit the use and disclosure of PII collected about you.

To exercise your rights, including the "right to know" and "right to delete," please submit a request by emailing our Data Protection Officer at{' '} dsar@goricompany.com .

13. What Are Your California Privacy Rights

California Civil Code Section § 1798.83 permits California residents with whom we have an established business relationship to request certain information regarding our disclosure of PII to Third-Party Services for their direct marketing purposes. To make such a request, please send an email to dsar@goricompany.com, or write us at:

Gori Company
ATTN: Data Protection Officer
1047 S Placentia Avenue
Fullerton, CA 92831

For more information about California resident privacy rights, including the rights of California residents under the CCPA, please see the following section,{' '} California Consumer Privacy Act.

14. California Consumer Privacy Act

The following disclosures are made pursuant to the CCPA. These disclosures supplement any privacy notices we previously or contemporaneously provided to you. The below chart reflects the categories of PII we have collected from California consumers over the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, and the categories of third-parties with whom we shared that information.

Categories of Personal Identifiable Information Collected Sources of Collection Business/Commercial Purpose for Collection Categories of Third-Parties Receiving Personal Identifiable Information
Identifiers: Name, username, mailing address, IP address, email address and account name. You. Devices you use to access our Services. To provide you with our Services and respond to your questions. To understand the Services considered by our customers and to make improvements to our offerings. To identify and repair errors that impair existing or intended functionality. To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. Partners and Third-Parties in Connection with Investigations, Safety and Complying with Legal Obligations.
Customer records information: Name, signature, mailing address, telephone number, bank account number and other financial information. You. Devices you use to access our Services. To provide you with our Services and respond to your questions. To understand the Services considered by our customers and to make improvements to our offerings. To identify and repair errors that impair existing or intended functionality. To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. Partners and Third-Parties in Connection with Investigations, Safety and Complying with Legal Obligations.
Internet or other electronic network activity information: Information regarding your interaction with our Services. You. Devices you use to access our Services. To provide you with our Services and respond to your questions. To understand the Services considered by our customers and to make improvements to our offerings. To identify and repair errors that impair existing or intended functionality. To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. Partners and Third-Parties in Connection with Investigations, Safety and Complying with Legal Obligations.
Geolocation data. You. Devices you use to access our Services. To provide you with our Services and respond to your questions. To understand the Services considered by our customers and to make improvements to our offerings. To identify and repair errors that impair existing or intended functionality. To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. Partners and Third-Parties in Connection with Investigations, Safety and Complying with Legal Obligations.

15. Changes and Updates to This Privacy Policy

This Privacy Policy may be revised periodically with or without notice to you and this will be reflected by the "Effective Date" above. Please revisit this page to stay aware of any changes. In general, we only use your PII in the manner described in the Privacy Policy in effect when we received the PII you provided. Your continued use of the Services constitutes your agreement to this Privacy Policy and any future revisions. For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of the PII you have already provided to us, we will attempt to obtain your consent before implementing such revisions with respect to such information.

16. What If You Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to{' '} support@goricompany.com . We will make every effort to resolve your concerns.

17. Data Privacy Framework

Gori's Privacy Policy conforms to the EU-U.S. Data Privacy Framework Principles ("DPF Principles") as set forth by the U.S. Department of Commerce, declares Gori's commitment to complying with the DPF Principles and is enforceable under U.S. law. Please visit{' '} https://www.dataprivacyframework.gov/list {' '} to check the current status of Gori's certification with the U.S. Department of Commerce's International Trade Administration (ITA) that it participates in and complies with the DPF Principles. To learn more about the DPF program, please visit{' '} www.dataprivacyframework.gov .

In compliance with the DPF Principles, this Privacy Policy sets out:

  • The types of PII we collect ("What Information Do We Collect and How It Is Collected?")
  • The purposes for which we collect and use PII ("What Information Do We Collect and How It Is Collected?")
  • The types of third-parties to which we disclose PII, and the purposes for which we do so ("Information Sharing And Disclosure")
  • The right of individuals to access their PII ("What Information of Mine Can I Access")
  • The choices and means we offer individuals for limiting the use and disclosure of their PII ("What Rights Do I Have Over My Information")
  • Our liability for onward transfers to third-parties

Gori is responsible for the processing of PII it receives under the DPF and subsequently transfers to a third-party acting as an agent on its behalf, if any. Gori complies with the DPF Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

E.U. data subjects may contact us for the handling of complaints, access requests, and any other issues arising under Data Privacy Framework as specified in section 18, Contact Us. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) https://www.jamsadr.com/dpf-dispute-resolution. As further explained in the DFP Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Gori is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, Gori may be required to disclose PII in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

18. Contact Us

If you have any questions or comments about this policy, concerns about our processing of your PII, need to access your PII or have any other question related to data protection and privacy, please submit your request by emailing{' '} dsar@goricompany.com {' '} or writing to us at the following address:

Gori Company
ATTN: Data Protection Officer
1047 S Placentia Avenue
Fullerton, CA 92831

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