LAPINE ASSOCIATES, INC. PRIVACY POLICY

Last Updated Effective: January 1, 2021

Lapine Associates, Inc. helps brands create and distribute promotional merchandise to build and enhance their brand equity. Our affiliate, Effectus Partners, LLC, provides business process innovation services to help clients solve operational and technical challenges.

This Privacy Policy describes how Lapine Associates, Inc., Effectus Partners, LLC and their respective parent, subsidiary and affiliated entities (collectively, “Lapine Associates” or “we,” “us,” or “our”) collect, use, and share personal data collected from visitors to our websites and mobile applications. These websites include www.lapineinc.com, www.effectuspartners.com and https://lapineinc.espwebsite.com (the “Lapine Associates”) as well as websites we build and manage for our customers to help distribute their promotional products (“Brand Websites” and collectively with the Lapine Websites, the “Websites”).

By using our Websites, you are agreeing to the terms of this Privacy Policy. If you are a California resident, please see our California Consumer Privacy Act Disclosure below.

Information We Collect

Registration Information:  When you register for an account on one of our Websites, you will be asked to provide identifying information to create your account (“Registration Data”), such as your:

• First and Last Name;
• Company Name and Position Title;
• Physical Address;
• Email Address; and
• Phone Number.

Information you Voluntarily Provide:   We may receive additional personal information when you interact with our Websites or our services. For example, when you:

• Request quotes, services or support or place an order from one of our Websites;
• Participate in surveys, sweepstakes or other promotional activities online or in any other venue (including on any social media platform);
• Subscribe to our newsletters, programs, promotional emails, white papers or other materials;
• Apply for a job, submit your resume/CV or create a candidate profile;
• Contact us with your questions/comments.

Information from third parties (such as, from your employer or our customers):   We may also receive information about you from third party sources. For example, we may receive information about you from your employer or from one of our customers for whom we manage a Brand Website (each, a “Brand”). We may also purchase marketing data from third parties and add it to our existing user database to better target our advertising and to provide pertinent offers in which we think you would be interested. We may associate this marketing data to the personally-identifiable information that you provide to us.

Your interactions with our website and emails:  As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and click stream data We use this information to analyze trends, to administer the Websites and our services, to improve the content and performance of our Websites and services, to manage your online shopping cart, and to track users’ movements around the Websites. We may also link this automatically-collected data to personal information. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that we may use on our Websites please see our section regarding Cookies below.

How We Use Personal Information

We use the information and data we collect principally in order to operate our Websites and to fulfill your orders and other requests. More specifically, we may use your personal information to:

• Deliver the services and support or carry out the transactions for our products that you have requested
• Send communications to you, such as to respond to your requests and to provide you with product safety information, your transaction status (including order confirmations), information about particular programs in which you have chosen to participate, information about products and services available from us, promotional offers and surveys;
• Provide communications from a Brand in connection with your interactions with a Brand Website;
• Customize, analyze and improve our products, services (including the content and advertisements on our website), technologies, communications and relationship with you;
• Comply with our legal and regulatory responsibilities and to enforce our rights;
• Authenticate users and to provide for the safety and security of our Websites and otherwise prevent fraud and other prohibited or illegal activities;
• Protect the security of our Websites, our businesses, and our products and services; or
• Otherwise, as disclosed to you at the point of collection.

Disclosing Personal Information

With respect to Branded Sites, the information you provide may be shared with the Brand and your information will be subject to both this Privacy Policy as well as the privacy policies of the applicable Brand as well as any other agreements between you and such Brand

Your personal information may also be shared with:

• Your employer if you place orders for our Products on behalf of your company through our Websites;
• Parties who support our business, such as fulfillment services, technical support, delivery services, professional advisors as well as web-hosting providers, analytics providers, customer-relationship management software providers and other information technology providers;
• Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues
• To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

Except as described above with respect to the Brands, we will not disclose your personal information to third parties for their own marketing purposes without your consent.

Choices Regarding Our Collection and Use of Your Information

We may offer you choices regarding the information we collect and how that information is used and shared. These choices may include the ability to access, update or delete information that you have provided to us or information that we have collected through your use of our Websites. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us. To inquire about making any of these requests please contact privacy@lapineinc.com.

If you are a resident of California, you have specific rights in relation to your personal information. Please review the section California Consumer Privacy Act Disclosure  below for more information.

How We Secure Your Personal Information

We will take reasonable steps to protect your personal information as you transmit your information from your computer to our Websites and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free.

In particular, email sent to or from our Websites may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use login credentials on our Websites, it is your responsibility to safeguard them.

We use a third-party vendor to process credit card transactions. Our online payment sites along with our processing partner reside on secure web servers that encrypt the data between the customer and the processing vendor. By using this service, Lapine Associates does not collect any credit card numbers or store such information.

Links to Other Web Sites

You should be aware that when you are on the Websites you could be directed to other sites beyond our control. For example, if you “click” on a link to one of our Brand partners, the “click” may take you off the Website onto the Brand’s official website. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a website that is linked to one of our Websites, you should consult that site’s privacy policy before providing any personal information. Please note that we are not responsible for the privacy practices of third parties.

Collection and Use of Children’s Personal Information

Lapine Associates takes children’s privacy seriously. We sell products intended for purchase by individuals over the age of 16. If you are a child 16 or younger, you are not authorized to make a purchase from our Websites without consent from your parent or legal guardian.

If we become aware that personal information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database. If any parent, guardian or other responsible adult becomes aware that we have collected personal information from a child under the age of 13, please contact us at privacy@lapineinc.com.

How We Use Cookies and Other Tracking Technologies

As with many websites, our Websites and other services (such as our email updates) use a standard technology called a “cookie” and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Websites and services. These technologies automatically identify your browser whenever you interact with our Websites and services.

We use cookies and other tracking technologies to:

1. Improve the user experience on our Websites;


2. Store the authorization token that users receive when they login to the private areas of our Websites. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's account to make orders;


3. Track anonymous site usage.

There are different types of cookies and other technologies used on our Websites and services, notably:

• “Session cookies” – These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).


• “Persistent cookies” – These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.


• “Web Beacons/Pixels” – Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

Lapine Associates Cookies.

We may place our own cookies on your computer to track certain information about you while you are using our Websites. For example, we may place a session cookie on your computer each time you visit our Websites. We use these cookies to allow you to log-in to your account. In addition, through these cookies we are able to collect information about how you use the Websites, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Websites and the URL you next visit (even if those URLs are not on our Websites). We may also utilize email web beacons to monitor whether our emails are being delivered and read. We also may use these tools to help deliver analytics to our Brand partners to give them insight into the Brand Websites.

Analytics/Performance Cookies

We also uses the following analytic tools to help us analyze the performance of our Websites as well as how visitors use our Websites:
Google Analytics – For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.  This will allow you to download and install a Google Analytics cookie-free web browser.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from our Websites you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It’s also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser’s “Help” function or alternatively, you can visit http://www.aboutcookies.org  which explains, step-by-step, how to control and delete cookies in most browsers.

Third-Party Ad Serving & Audience and Traffic Measurement Services

The Websites may use third party network advertisers to serve advertisements you may see. Network advertisers are third parties that display advertisements based on your visits to the Websites and other websites you have visited. Third-party ad serving enables us to target advertisements to you for products or websites you might be interested in. In addition, we may share this information with the Brands to allow them and their network advertisers to serve ads based on your interests to you.

Our Websites are in compliance with the Ad Choices Self-Regulatory Program for Online behavioural Advertising. The goal of Ad Choices is to provide you with information about how online advertising works and the choices you have.

You may visit the  http://www.aboutads.info/choices  page to learn more about online behavioural advertising and to see your opt-out choices from companies that are participants in the Self-Regulatory Program for Online behavioural Advertising.

Please note that if you choose to opt out, you will still see ads, but these ads will not be customized based on your interests generated from your visits over time and across different websites. In addition, the preferences you select on the  http://www.aboutads.info/choices  page may not apply to mobile devices. Due to the differences between using apps and websites on mobile devices, opt-outs will need to be set for both browsers and apps.

Do-Not-Track

Some browsers have incorporated a Do-Not-Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our Websites.

Social Media Features

Our Websites may include social media features, including the Facebook “Like” button and Twitter “Follow” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Websites. Your interactions with these features are governed by the privacy policy of the company providing it.

Users Outside the United States

Lapine Associates is located in the United States. The Websites are directed solely towards users who reside in the United States. If you choose to use the Websites from outside the United States, you are consenting to the collection, storage, processing, and transfer of your information in and to the United States, pursuant to the laws of the United States.

Notwithstanding the forgoing, Lapine Associates will honor the following requests from users:

• If the processing of personal data is based on your consent, the right to withdraw consent for future processing of that data.
• The right to request from us access to and rectification of your personal data.
• Subject to reasonable limitations, the right to request restriction of the processing of your personal information.
• Subject to reasonable limitations, the right to request erasure of your personal data.
• You may contact Lapine Associates using any of the methods described in the “Contacting Us” section of this Privacy Policy below to exercise these rights. We may require you to verify your identity to exercise any of these rights.

Changes to This Privacy Statement

We will occasionally update this Privacy Policy. If we make changes to this Privacy Policy or make any material changes to how we use your personal information, we will revise this Privacy Policy to reflect such changes and revise this Privacy Policy’s effective date, included at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we are using and protecting your personal information

Other Terms

Your use of our Websites is subject to the Terms and Conditions. If you choose to use our Websites, your visit and any dispute over privacy and data collection is subject to this Privacy Policy and our Terms and Conditions including limitations on damages and application of the law of the State of Connecticut.

Contacting Us

If you would like to contact us for any reason regarding our privacy practices, please write to us at the following address:

Lapine Associates Inc.
Attention: Privacy Information
15 Commerce Road
Stamford, CT 06902 USA
privacy@lapineinc.com

California Consumer Privacy Act Disclosure

This California Consumer Privacy Act Disclosure explains how Lapine Associates, Inc., Effectus Partners, LLC and their respective parent, subsidiary and affiliated entities (collectively, “Lapine Associates” or “we,” “us,” or “our”) collect, use, and disclose personal information relating to California residents (consumers) covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Introduction

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For more information about how we collect, disclose, and secure information relating to these customers, please refer to our general Privacy Policy above. Terms that are used, but not defined, in this CCPA Disclosure are defined in the CCPA.

Collection and Disclosure of Personal Information

In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure:

• Identifiers, such as name, postal address, IP address, account credentials and email address
• Personal information, as defined in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as contact information and financial information;
• Characteristics of protected classifications under California or federal law, such as gender.
• Commercial information, such as transaction information and purchase history;
• Internet or network activity information, such as browsing history and interactions with our website;
• Geolocation data, such as Internet Protocol (IP) location;
• Professional or employment-related information, such as work history and prior employer

The categories of sources from whom we may have collected this Personal Information are

• Directly from a California resident or the individual’s representatives;
• Service Providers, Consumer Data Resellers and other third parties;
• Public Record Sources (Federal, State or Local Government Sources);
• Website/Mobile App Activity/Social Media;

Information from our Brand customers about individuals associated with the Brand (e.g., an employee or a customer of the Brand).

The categories of third parties to whom we may disclose Personal Information for our business purposes described in this privacy disclosure are:

• Your employer if you place orders for our Products on behalf of your company through our Websites
• Service Providers who support our business, such as fulfillment services, technical support, delivery services, professional advisors as well as web-hosting providers, analytics providers, customer-relationship management software providers and other information technology providers;
• Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues;
• Brands who are our customers regarding use of their Brand Websites;

Use of Personal Information

In the past 12 months, we may have used Personal Information relating to California residents to:

• Deliver the services and support or carry out the transactions for our products that you have requested;
• Send communications to you, such as to respond to your requests and to provide you with product safety information, your transaction status (including order confirmations), information about particular Lapine Associates programs in which you have chosen to participate, information about products and services available from Lapine Associates, promotional offers and surveys;
• Provide communications from a Brand in connection with your interactions with a Brand Website;
• Customize, analyze and improve our products, services (including the content and advertisements on our website), technologies, communications and relationship with you
• Comply with our legal and regulatory responsibilities and to enforce our rights.
• Authenticate users and to otherwise provide for the safety and security of our Websites and otherwise prevent fraud and other prohibited or illegal activities;
• Protect the security of our website(s), our business(es), or our products or services; or
• Otherwise, as disclosed to you at the point of collection.

Sale of Personal Information

In the past 12 months, we have not “sold” Personal Information subject to the CCPA, including Personal Information of minors under the age of 16. For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.

Rights under the CCPA

If you are a California resident, you have the right to:

1. Request we disclose to you free of charge the following information covering the 12 months preceding your request:
   1. The categories of Personal Information about you that we collected;
   2. The categories of sources from which the Personal Information was collected;
   3. The purpose for collecting Personal Information about you;
   4. The categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
   5. The specific pieces of Personal Information we collected about you;
2. Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception;
3. Be free from unlawful discrimination for exercising your rights under the CCPA

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity. We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

In some instances, we may not be able to honor your request, and we will advise you of that fact in our response. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.

How to Exercise Your Rights

If you are a California resident, you may submit a request by emailing your request to privacy@lapineinc.com.