Privacy Policy

This Privacy Policy is effective as of 5 February 2024.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY.

If you live in certain countries, additional terms may apply to you and can be found at the end of this Privacy Policy (the "Additional Terms"). These Additional Terms override the other terms of this Privacy Policy to the extent of any inconsistency.

We are committed to protecting your privacy as a user (referred to as "User", "you" or "your"), and we take our responsibility regarding the security of your Personal Data (defined below) very seriously. We will be clear and transparent about the Personal Data we are collecting and what we will do with that Personal Data.

This privacy notice (the "Privacy Policy") describes the types of Personal Data we collect on https://alanahuxtable.com (the “Website”), blog, social media pages, or one of our other products or services, all of which are part of Alana Huxtable’s platform (the "Platform").

Who is responsible for processing your Personal Data?

Alana Huxtable is the "data controller" (i.e., the organisation responsible) for all Personal Data that is collected and used via the platform for the purposes of data privacy laws, principles, and regulations which may apply to you (including the Privacy Act 1988 (Cth) ("Privacy Act"), the applicable Australian Privacy Principles under the Privacy Act, the European General Data Protection Regulation ("GDPR"), the General Data Protection Regulation of the United Kingdom ("UK GDPR") and the Californian Consumer Privacy Act ("CCPA")) (collectively, "Data Privacy Law").

What Personal Data do we collect (including by automated means)?

We may ask for and collect your Personal Data (either directly through your use of the Platform or when you communicate with us in any other way, or indirectly through our third party partners or providers) in a number of ways to provide you with the products or services that you request – please refer to Section 3 below for more information on how we use your Personal Data. We may also collect information from you automatically when you visit our Platform – for more information, please refer to our Cookie Policy addendum below. 

"Personal Data" has the meaning given in the Data Privacy Law applicable to you, and includes any information or opinion relating to you which allows us to identify you, such as your name, phone number, social media name or ‘handle’, postal address, email address, details of products or services you have purchased, payment details and information about your access to our Websites.

Specifically, we may (either directly or indirectly) collect the following categories of Personal Data:

• first and last names, email address and date of birth (which may be required for user accounts (“User Account”), or when purchasing our products on the Platform (“Product”)
• other information such as country of residence and gender, home address and telephone number;
• any data provided by you on the Platform or generated through your use of the Alana Huxtable Platform (e.g. videos watched, topics of personal interest);
• information you provide about yourself and any preferences in your User Account;
• information you provide about yourself which you choose to share with us via a free text field, for example, when giving feedback to us about your experience in the Platform, completing member surveys, etc.;
• information about your purchases of products and services from us or our third party partners who may provide or promote their own products or services through the Platform;
• payment information, such as your transaction details, if you purchase something directly on the Alana Huxtable Platform or from our e-commerce providers (e.g. one of Alana’s ebooks). Note we do not receive or store payment information for your purchases;
• information about your use of the Platform;
• communications with us or information about yourself directed to us via letters, emails, chat services, calls, and social media;
• where you have selected particular services or features on the Platform, your photos, audio, contacts and calendar information, as well as your social network information (including credentials and any information from your public posts about Alana Huxtable or your communications with us);
• when you have sent a referral link to a friend, colleague, or family member or been referred to Alana Huxtable by a friend, we may be able to identify the identity of the person who referred you or who you referred;
• any information you share in a social media post where you tag, use a hashtag, link, or otherwise direct the post to our attention;
• when you have elected to sign up and log into the Platform using a third-party account you created (e.g. through Facebook or Apple), information you have agreed to make available to us (e.g. name, email address, profile information, preferences); and
• your location where the IP address of your computer or device is used to determine your geographic location so that we can customize your experience on the Platform (e.g. language settings).

3.1 Why and how do we use your Personal Data?
Your Personal Data may be used for the following purposes:
• To provide the products and services you request
• to create and set up your User Account;
• to fulfil any orders for products that you place on the Platform, including to communicate with you about the orders and to process information for our internal accounting, billing and audit purposes;
• We may also use this information to calculate further information about your activity so that this can be provided to you as part of the functionality of the Platform;
• if you choose to post on our social media pages, the information that you share will be public information that can be accessed by anyone whether or not they are a part of the Alana Huxtable community. As the information posted to these pages is public information, it will also be indexed and accessible via third party internet search engines, websites and apps. For further information about how content posted in the Forum is publicly available, please refer to our Forum Community Guidelines.

3.2 Communicate information about our products and services and for other promotional purposes:
With your consent, or as otherwise permitted by applicable Data Privacy Law, we will use your Personal Data to provide information that we believe is of interest to you, prior to, during, and after your interactions with us, including marketing communications and news concerning our products, services, events and other promotions. You can opt-out at any time after you have given your consent to such communications.In providing tailored promotion materials to you, Alana Huxtable may use the personal information collected through your use of the Platform, such as the user preferences you set and profile data you submit, and any activity data generated through your use of the Platform.

3.3 Customer service communications:
We use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us (e.g. to respond to your inquiries when you reach out to us). From time to time, we may also conduct customer surveys to gauge satisfaction with our Platform and the services and products that we provide.

3.4 Administrative or legal purposes:
We use your Personal Data to operate our business, including for statistical and marketing analysis, systems testing and to diagnose technical and service problems, maintenance and development of our Platform, or in order to deal with a dispute or claim. We may also perform data analysis based on the data we collect from you for statistical and marketing analysis purposes – for example, we may use information about how users of our Platform search for and find specific topics to better understand the best ways to organize and present the content that we offer.

3.5 Security, health, administrative, crime prevention/detection and legal purposes:
We may use your Personal Data to verify your information and identity, and to protect against, identify and prevent fraud and other unlawful activities. We may also share your Personal Data with government authorities or enforcement bodies for compliance with legal requirements, or as otherwise required or permitted by applicable Data Privacy Law.

3.6 Other purposes:
We may also use your Personal Data in other ways, and where we do so, we will provide specific notice at the time of collection and obtain your consent unless otherwise permitted by applicable Data Privacy Law.
We will only process your personal data where we have a legal basis to do so, which will depend on the reasons for which we have collected and need to use your personal data. In most cases we will need to process your personal data so that we can enter into contracts with you under our terms of use (when orders for products are made), and to fulfil the provision or delivery of goods or services to you on the Platform (including subscriptions to and products on the Platform).

Our processing of your Personal Data for the above purposes is done pursuant to the following legal basis:
• to comply with a legal obligation;
• the processing is necessary for the performance of a contract with you, such as providing you with our services on the Platform;
• if it is in our legitimate interests to do so as a business (e.g., for administrative purposes or to improve the functionality of our Platform);
• where you have consented to our using your personal data (e.g., for the collection of data for marketing related uses);
• where you have made such information public; and
• to protect your vital interests or those of another person (e.g. in case of a medical emergency).

Where we receive your Personal Data as part of providing our services to you based on a contract, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide our services to you.

Personal details including about your nationality or physical or mental health are considered “sensitive” Personal Data under applicable Data Privacy Law. We will process any such data only if you have given your explicit consent, or it is necessary (for instance, if you request special assistance), or if the sensitive Personal Data has been manifestly made public by you (e.g., by posting information about your personal experiences or mental health on our social media pages), or otherwise in compliance with applicable Data Privacy Law.

The Platform may require information about your challenges, personal experiences, and mental or physical health to provide certain functions or services. As described more fully below, you may always contact us at the details in Section 11 with any questions or requests about your Personal Data.
• How do we protect and manage your Personal Data (including international transfers and retention periods)?

4.1 Encryption and security

We follow strict security procedures in the storage and disclosure of your Personal Data, which are designed to protect it against misuse, unauthorised access, modification or disclosure and accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting Personal Data and credit card details so that they can be securely transferred over the internet.

4.2 International transfers of your Personal Data

Alana Huxtable operates businesses in multiple jurisdictions, some of which are not located in the EU, EEA, or the UK). The Personal Data that Alana Huxtable collects from users will be stored in Australia and/or the United States of America and might also be shared with third party data recipients (e.g., e-commerce and logistics providers such as WooCommerce, and customer support providers such as Zendesk) that may not be located in the EEA, UK, Australia or the United States of America. Therefore, the Personal Data that you provide to Alana Huxtable may be transferred internationally to countries other than the country in which you initially provided your data.

While countries outside the EU, EEA and the UK do not always have strong data privacy laws, we take measures to protect your Personal Data as described in this Privacy Policy and in compliance with applicable Data Privacy Law. We also require all third party data recipients (including our service providers) to process your information in a secure manner and in accordance with the GDPR and other applicable Data Privacy Law (e.g., through the signing of the EU Standard Contractual Clauses). If you have further questions about this or would like to request to view copies of the applicable safeguards (where required), please contact us at the details in Section 11 below.

4.3 Retention of your Personal Data

We will not retain your data for longer than is necessary to fulfil the purposes for which it is being processed. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it, and whether we can achieve those purposes through other means.

We also consider the periods for which we might need to retain personal data in order to meet our legal obligations, or to deal with complaints and queries, and to protect our legal rights in the event of a claim being made.

In general, this means that we will likely keep your Personal Data for as long as your User Account is open. Following closure of your User Account, however, we may still retain a limited portion of your Personal Data so that we can maintain a continuous relationship with you if and when we are in contact with you again, and to comply with our internal processes and any legal obligations.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimize over time the personal data that we use, and if we can fully anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

Who do we share your Personal Data with?
We may share your Personal Data with the following people for the purposes described in this Privacy Policy:

• Global Digital Tech Holdings and other companies and members within iFIT;
• where you have selected particular services or features on the Platform (e.g. scheduling your quotes, sharing your personal experiences and challenges on social media platforms), other Users of the Platform;
• if you purchased one of our Products or joined Alana Huxtable via a referral link sent to you by one of your contacts (like a friend, family member, or colleague), we may let that contact know you’ve created an Alana Huxtable account or bought our products, and provide them a referral bonus as a result;
• third party social media platforms in various circumstances, including where:
• you are able to access third party social media services through our Platform or before coming to our Platform;
• you connect your User Account to your social media account, in which case we will receive from the social media platform the Personal Data you choose to share, based on the preferences and settings on your social media account. We will use this information in order to improve and personalize your use of our Platform;
• third party social media sites have placed cookies or pixels on our website;
• you post or otherwise participate in competitions, events, or direct your social media posts to us via a hashtag, tag, link, etc.; and
• we use social media plugins on our Platform (e.g., a “share” or “like” button), and your use of these plugins, may result in the disclosure of certain of your information to the social media platform in question, and possibly presented on your social media profile, to be shared with others in your network – however, we will only share your Personal Data with these social media platforms if you have provided your express consent for us to do so.
• Please refer to the privacy policy of those third-party social media platforms to find out more about these practices;
• other companies, contractors or agents that assist us in providing services to you, including our online e-commerce platform that allows us to sell and deliver our products and services to you (which may include WooCommerce), support ticketing, legal services, debt collection, administration services, customer services and information technology support;
• only where you have provided consent, other companies, contractors or agents in connection with our marketing efforts, or marketing platform providers;
• government authorities, law enforcement bodies and regulators for compliance with legal requirements, or where otherwise required by applicable Data Privacy Law;
• our legal and other professional advisers in order to enforce our legal rights in relation to our contract with you; and
• Where you choose to post information on our social media pages, the information that you share will be public information which can be viewed by anyone (whether or not they are a part of our community). Information posted on social media will be indexed to third party internet search engines (such as Google), websites and apps. For further information about how information posted in the Forum is used, please refer to our Forum Community Guidelines.
• We may also transfer your Personal Data to potential buyers in the event that we sell or transfer all of a part of our business or assets (including in the event of a reorganization or dissolution / liquidation), under strict non-disclosure restrictions, and solely in order to allow a buyer to determine whether to proceed with the transaction, or where such a determination is made, to complete it.

Your Rights and Choices

Under certain circumstances, by applicable Data Privacy Law you may have the right to:

6.1 Transparency
You have the right to request information about whether we hold Personal Data about you, and, if so, what that information is and why we are holding/using it.

6.2 Access
You may request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

6.3 Correction
You have the right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

6.4 Erasure
You can request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing.

6.5 Object
You may object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

6.6 Automated Decision Making and Profiling
You may also object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your Personal Data or profiling of you.

6.7 Restriction of Processing
You have the right to request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

6.8 Transfer
Request transfer of your Personal Data in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.

6.9 Withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time by contacting us using the details in Section 11 below.

If you wish to exercise your rights related to your Personal Data (including the rights set out above), please contact the Alana Huxtable team using the details in Section 11.

While you will generally not be required to pay a fee to access your Personal Data or to exercise any of your other statutory rights, we may charge a reasonable fee if your request for access is clearly completely unfounded, excessive or decline to comply with such requests where permitted by applicable Data Privacy Law.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it and to prevent unauthorized modification of your Personal Data.

You also have the right to lodge a complaint about our processing of your Personal Data with the body regulating data protection in the country or state / province in which you live. If the GDPR applies to our processing of your Personal Data, you have the right to lodge a complaint with a supervisory authority if you are not satisfied with how we process your Personal Data. Specifically, you can lodge a complaint in the Member State of the European Union of your habitual residence, place of work, or of the alleged violation of the GDPR.

• Cookies
A "cookie" is a small file stored on your device that contains information about your device. You have certain options with respect to the use of cookies and other tracking technologies on our site, including for the purposes of online interest-based advertising. For more information about the cookies we use, please refer to our Cookie Policy which forms part of this Privacy Policy.
You may also set your browser to send a Do Not Track (DNT) signal. Please note that our Websites do not have the capability to respond to DNT signals received from web browsers at this time.

• Links to other websites
Our Platform may provide links to other websites for your convenience and information. These websites may operate independently from us. If you visit any website linked to our Platform, you are subject to that website’s own privacy policies. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.

• Children
Users must be of legal age in their respective countries and not under 16 years old. Individuals are not allowed to sign up for a User Account on the Platform without verifying that they are 16 years of age or older. To the extent we identify any User that appears to be below the age of 16 years, we will reach out to that User to verify their age.
• Updates to this Privacy Policy

Alana Huxtable may revise and update this Privacy Policy at any time in its sole discretion by posting an updated Privacy Policy on the Platform. All such changes to the Privacy Policy are effective immediately when posted to the Platform and apply to all access to and use of the Platform thereafter.
• How to contact us?

We welcome questions and comments about this Privacy Policy and our privacy practices. If we receive a complaint from you about how we have handled your Personal Data, we will investigate and determine what action we should take to resolve the complaint. We will contact you within a reasonable time and may request more information to assist us with our investigation. We aim to resolve all complaints in a timely manner.

If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your Personal Data, please contact the Alana Huxtable team at the following email address: support@AlanaHuxtable.com. Alternatively, you can contact the Alana Huxtable team by completing a contact form through the Alana Huxtable website.
For the purposes of the Australian Privacy Act 1988 (Cth), you can contact our Privacy Compliance Officer at: support@AlanaHuxtable.com.

With reference to Article 37 of the GDPR and the UK GDPR, you can contact us directly or enquire with the relevant bodies in these jurisdictions.

ADDITIONAL TERMS
If you live in one of the following countries or states, these Additional Terms apply and override any inconsistent terms in the Privacy Policy:

CANADA
• Section 3.6 (Other purposes) is replaced with the following: "We may also collect, use and disclose your Personal Data in other ways, and where we do so, we will obtain your further consent".
• We will only process your personal data where required to operate the Platform, provide you with products and services, and to operate our business, including for the purposes outlined in this Privacy Policy. In most cases, we will need to process your personal data so that we can enter into contracts under our terms of use (when orders for products are made), and to fulfil the provision or delivery of goods or services to you on the Platform (including subscriptions to the Platform).
• In addition to the purposes set out elsewhere in the policy, Alana Huxtable may collect, use and disclose your Personal Data for marketing and analytics purposes, including to display targeted advertising, based on your interests as inferred from web activity, when you visit other sites around the web or as you use various social media platforms. Please see our Cookie Policy for further details, including how you can control the use of your Personal Data for targeted advertising purposes.
• By using the Platform or otherwise providing us with your Personal Data, you agree to the collection, use and disclosure of your Personal Data as set out in this Privacy Policy.
• We may also collect, use and disclose your Personal Data without your consent, as required or permitted by applicable Data Privacy Law, such as to use or disclose your Personal Data in the case of an emergency that threatens the life, health or security of you or another individual."

• Section 4.2 (International transfers of your Personal Data) is replaced with the following: "Alana Huxtable operates businesses in multiple jurisdictions, some of which are not located in your country of residence. The Personal Data that Alana Huxtable collects from users will be stored in Australia and/or the United States of America and might also be stored or processed through third party service providers (e.g., e-commerce and logistics providers such as WooCommerce, and customer support providers such as Zendesk) in other countries. Therefore, the Personal Data that you provide to Alana Huxtable may be transferred internationally to countries other than the country in which you initially provided your data".

• When transferring Personal Data to a third party service provider, or outside of your home country, we take measures to protect your Personal Data as described in this Privacy Policy and in compliance with applicable Data Privacy Law. Using contractual and other means, we also require all third party data recipients (including our service providers) to process your information in a secure manner and in accordance with the applicable Data Privacy Law in your country of residence. However, when stored or processed in another country, your Personal Data will be subject to the applicable Data Privacy Law of that country, which may not provide the same protections as the applicable Data Privacy Law in your country of residence. If you have further questions about this or would like to request to view copies of the applicable safeguards (where required), please contact us at the details in Section 11.

• The section dealing with the payment of a fee to access your Personal Data in Section 6 is replaced with the following: "While you will generally not be required to pay a fee to access your Personal Data or to exercise any of your other statutory rights, where permitted by applicable Data Privacy Law, we may charge a reasonable fee if your request for access would require an exceptional amount of effort, or may decline to comply with frivolous or vexatious requests".

CALIFORNIA, UNITED STATES OF AMERICA
The Privacy Policy and this Section of the Additional Terms were last reviewed on 3 June 2021. The provisions in this Section are intended to fulfil the requirements of the California Consumer Privacy Act ("CCPA") and shall apply to Users who are resident in California.

To the extent that any terms used in this Privacy Policy and this Section of the Additional Terms are defined in the CCPA, such definitions shall apply. The term "Personal Data" as used in this Privacy Policy and this Section of the Additional Terms shall include "Personal Information" as such term is defined in the CCPA.

The categories of Personal Data collected by Alana Huxtable are described in Section 2 of the Privacy Policy and, for the purposes of the CCPA, correspond to the following categories of Personal Information listed in the CCPA:
Category How We Obtain It

Identifiers: first and last names, email address, home address, telephone number, where you have selected particular services or features on the Platform, social network information. Directly from you or linked third party accounts.
Protected characteristics: age, gender, country of residence, medical conditions or requirements. Directly from you and your devices.

Commercial information: information about your purchases of products and services from us or our third party partners who may provide or promote their own products or services through the Platform. Our own accounting records and from third party partners who may provide or promote their own products or services through the Platform.
Biometric information: physical characteristics such as weight, height, and body measurements such as stride length and apparel size, and photographs identifying your facial features, to the extent you choose to enter these on the Platform. Directly from you, if you choose to enter these on the Platform.

Internet or other similar network activity: information about your use of the Platform and your IP address, including information collected automatically through cookies (refer to our Cookie Policy for more information; Directly from you and your devices.
Geo-location data: where the IP address of your computer or device is used to determine your geographic location so that we can customize your experience on the Platform (e.g. language settings. Directly from you and your device(s).

Sensory Data: audio, electronic, visual, thermal, olfactory, or similar information (e.g., your photos and audio where you have selected particular services or features on the Platform). Directly from you, where you have selected particular services or features on the Platform.

Inferences drawn from other Personal Data: information you provide about yourself and any preferences in your User Account, communications with us or directed to us via letters, emails, chat services, calls, and social media, activity data provided by you on the Platform or generated through your use of the Platform, including activity data generated by the devices that you connect to where you have selected particular services or features on the Platform, contacts and calendar information. Directly from you and your devices.

The categories of third parties with whom Alana Huxtable shares each category of personal data are as follows:

Category Who We Share It With
Identifiers Other companies and members within the Alana Huxtable group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform; third party social media platforms when you connect your User Account to your social media account or use social media plugins on our Platform; other companies, contractors or agents that assist us in providing services to you, including our online e-commerce platform that allows us to sell and deliver our products and services to you; third parties that provide legal services, customer services and information technology support; and credit and debit card companies including third party payment gateway providers.

Protected characteristics Other companies and members within the Alana Huxtable group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform.
Commercial information Other companies and members within the Inpival group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform; other companies, contractors or agents that assist us in providing services to you, including our online e-commerce platform that allows us to sell and deliver our products and services to you; third parties that provide legal services, administration services, customer services and information technology support, and credit and debit card companies including third party payment gateway providers.

Biometric information Other companies and members within the Alana Huxtable group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform.

Internet or other similar network activity Other companies and members within the Alana Huxtable group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform; third party social media platforms when you connect your User Account to your social media account or use social media plugins on our Platform.
Geo-location data Other companies and members within the Alana Huxtable group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform; third party social media platforms when you connect your User Account to your social media account or use social media plugins on our Platform.

Sensory Data Other companies and members within the Alana Huxtable group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform.

Inferences drawn from other Personal Data Other companies and members within the Alana Huxtable group; our trusted third party ancillary partners (identified on our Websites), whose products and services you obtain through our Platform; third party social media platforms when you connect your User Account to your social media account or use social media plugins on our Platform.

We may also disclose your Personal Data to government authorities, law enforcement bodies and regulators for compliance with legal requirements, or where otherwise required by applicable Data Privacy Law and to our legal and other professional advisers in order to enforce our legal rights in relation to our contract with you.

Alana Huxtable processes each category of your Personal Data described above for purposes described in Section 3 of the Privacy Policy. We will not process your Personal Data for purposes which are materially different, unrelated, or incompatible with the purposes set out in the Privacy Policy without providing you notice.

We disclose to third parties all of the categories of Personal Data listed in the table above for a business purpose.

“Sale” of Data:
Alana Huxtable does not “sell” your Personal Information in the conventional sense (i.e., for money). Like many companies, however, we use services that help deliver interest-based ads to you. As part of this process, we may transfer Personal Information to business partners (like Facebook) for their use as they help us deliver interest-based ads. Making Personal Information (such as online identifiers or browsing activity) available to these companies to use outside of Alana Huxtable’s direction may be considered a "sale" under the CCPA.

California Consumer Rights:
Users who are resident in California may have the following rights under the CCPA in addition to the rights set out in Section 6 of the Privacy Policy:
• The Right to “Opt Out”
You have the right to direct us to not “sell” your personal information at any time (the “right to opt-out”). As described above, 
Alana Huxtable doesn’t sell any of your information in the conventional sense. However, Alana Huxtable may provide information about you to third party advertising partners (like Facebook), and this may constitute a “sale” under the CCPA. To exercise the right to opt-out of this kind of information transfer, you may submit a request to us emailing support@alanahuxtable.com. If you change your mind, you can opt in as described below. We will only use personal information provided in an opt-out request to review and comply with the request.

• The Right to “Opt In”
If you change your mind about opting out of the “sale” of your data and would like Alana Huxtable to resume providing your information to these advertising partners, you may contact us at support@AlanaHuxtable.com at any time.
• Access:
Once we receive and confirm your verifiable consumer request, we will disclose the following to you:
• the categories of your Personal Data and the specific Personal Data that we have collected;
• the categories of sources from which your Personal Data was collected;
• our business or commercial purpose for collecting your Personal Data; and the categories of third parties with whom we share your Personal Data, and where such third parties received your Personal Data from us for a business purpose, the categories of your Personal Data that we disclosed to such third parties.
• Under the CCPA, you are only entitled to exercise the Personal Data access right twice a year.
• Deletion:

Once we receive and confirm your verifiable consumer request, we will (and will direct our service providers to whom we have disclosed your Personal Data to) delete your Personal Data unless an exception under the CCPA applies.

The rights set out above do not apply to Personal Data collected from Alana Huxtable's team as part of their employment with Alana Huxtable or Personal Data collected as part of a business-to-business transaction.

To exercise any of the rights set out above, please contact the Alana Huxtable team using the contact details set in Section 11 of the Privacy Policy.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. As set out in Section 6 of the Privacy Policy, we may need to request specific information from you to help us confirm that your request is a verifiable consumer request.

• Exercising your rights under the CCPA:
Verification of your identity to respond to your request to know and delete
To evaluate your request to know or delete, we may request additional information to verify your identity. We will only use the Personal Data you provide us in a request to verify the requestor's identity or authority to make the request.
Please note that you may only make a consumer request to know or data portability request twice within a 12-month period.
• Section 6 of the Privacy Policy is supplemented as follows:

Response Timing and Format of Our Responses
If we need to charge a fee for a request which is excessive, repetitive, or manifestly unfounded, we will explain why we made that determination and provide you with a cost estimate before completing your request.
We will reply to all requests within 30 days, or inform you in writing if additional time is required. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will send our written response by mail or electronically, at your option.

If we cannot satisfy your request, we will also explain why in our response.

Authorized Agent
You may appoint an authorized agent to exercise any of your privacy rights on your behalf, if the authorized agent is a natural person or a business entity registered with the Secretary of State of California.
To appoint an authorized agent, you must also sign a written declaration giving the authorized agent permission to act on your behalf, or you can appoint such agent via a power of attorney pursuant to Probate Code sections 4000 to 4465.
To verify that your authorized agent acts on your behalf, we will ask for this written permission from your agent or for the power of attorney. In case you provided your authorized agent with a written permission, we will require that you also verify your identity and we may also ask you to directly confirm with us that you provided the authorized agent permission to submit the request.

We will deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. We will not discriminate against you for exercising any of your rights under the CCPA. Specifically, unless permitted by the CCPA, we will not:
• deny you access to goods and/or services provided by us on the Platform;
• charge you different prices or rates for the goods and/or services provided by us on the Platform, or imposing penalties on you;
• provide you with a different level or quality of goods and/or services than otherwise generally provided by us on the Platform; or
• suggest that you will receive a different price or rate for, or a different level or quality of, the goods and/or services generally provided by us on the Platform.

Addendum - Cookie Policy

The Platform uses cookies according to the Electronic Communications Act, which came into force on 25 July 2003. A cookie is a small text file stored on your computer that contains information that helps the website to identify and track the visitor. Cookies do no harm to your computer, consist only of text, can not contain viruses and occupies virtually no space on your hard drive. There are two types of cookies: “Session Cookies” and cookies that are saved permanently on your computer.

The first type of cookie commonly used is “Session Cookies”. During the time you visit the website, our web server assigns your browser a unique identifier string so as not to confuse you with other visitors. A “Session Cookie” is never stored permanently on your computer and disappears when you close your browser. To use the platform without troubles you need to have cookies enabled.

The second type of cookie is used to track how visitors move around on the website. This is only used to offer visitors better services and support. On this website we use this type of cookie to keep track of your shopping cart and to keep statistics of our visitors. The information stored on your computer is only a unique number, without any connection to personal information.

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