PRIVACY POLICY

Chaiboy LLC (“Chaiboy”) appreciates your business and patronage and respects your privacy. Please read this privacy policy (the “Privacy Policy”) carefully as it contains important information regarding who we are, how and why we collect, store, use, and share your personal information. This Privacy Policy also explains your rights in relation to your personal information and how to contact Chaiboy in the event you have a question, issue, or complaint.  

As a general matter, Chaiboy does occasionally collect and use certain personal information relating to you in connection with certain aspects of the goods and services Chaiboy provides. When Chaiboy collects personal information, Chaiboy complies with various laws in the United States and the General Data Protection Regulation (the “GDRP”), which applies across the European Union (including in the United Kingdom), and Chaiboy is responsible as the “controller” of such personal information for the purposes of those laws.

1. Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Chaiboy LLC
Our representative	Samir Kavadi
Our data protection officer	Samir Kavadi
Contact details for data protection officer	info@wearechaiboy.com
Personal information or data	Any information relating to an identified or identifiable individual

2. Personal Information We Collect About You

Chaiboy may collect and use the certain personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household for purposes of delivering Chaiboy’s goods and services:  

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	When you purchase Chaiboy goods and services, the transaction may require that Chaiboy collect (a) your name or company name, (b) your postal address, (c) your Internet Protocol address, (d) your email, (e) your account name, (g) your credit or debit card particulars, including account number, account name, and account address, and (h) you electronic signature or authorization necessary to complete the transaction.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	When you purchase Chaiboy goods and services, the transaction may require that Chaiboy collect certain financial information, including, among other things, bank account number, credit card number, or debit card number.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	When you purchase Chaiboy goods and services, Chaiboy may collect and compile information related to your specific purchase, including, for example, the specific products you purchased, obtained, or considered during your visit and interaction on Chaiboy’s Website.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	When you purchase Chaiboy goods and services or visit Chaiboy’s Website, Chaiboy may collect and compile information related to your specific purchase, including browsing history, search history, and information related to the specific Chaiboy goods and products you browsed on the Chaiboy Website.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	When you purchase Chaiboy goods and services or visit Chaiboy’s Website, Chaiboy may collect and compile information related to your specific purchase, including browsing history, search history, and information related to the specific Chaiboy goods and products you browsed on the Chaiboy Website.

The personal information and data referenced above is required in order for Chaiboy to provide its products and services to you.  If you do not provide personal information Chaiboy may ask for, it may delay or prevent us from providing Chaiboy products and services to you.

3. How Your Personal Information is Collected

Chaiboy typically collects most of this personal information directly from you, when you voluntarily fill out, complete, or otherwise provide such personal information while visiting or browsing or Website, placing an order for Chaiboy products, subscribing to Chaiboy’s mailing list, or otherwise volunteering your personal information.  However, we may also collect information:

• From publicly accessible sources (e.g., property records);
• From a third party with your consent (e.g., your bank);
• From cookies on our Website; and
• Via our Information Technology (“IT”) systems, including: Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, and email and instant messaging systems. 

4. How and Why We Use Your Personal Information

Under data protection laws, Chaiboy may only use your personal information if Chaiboy has a proper reason for doing so including, among other things, the following: 

• To comply with Chaiboy’s legal and regulatory obligations;
• For the performance of our sales transactions with you or to take steps at your request before effectuating or completing a sales transaction; 
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when Chaiboy has a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what Chaiboy uses your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons for using such information
To provide products and services to you	In order to facilitate or effectuate a sales transaction or your purchase of Chaiboy products
To prevent and detect fraud against you or Chaiboy	For our legitimate interests or those of a third party (i.e., to minimize fraud that could be damaging for both Chaiboy and you)
Conducting checks to identify our customers and verify their identity	To comply with our legal and regulatory obligations and to ensure that your purchase is properly authorized by you
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party (i.e., to make sure we are following our own internal procedures so we can deliver the best service to you)
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party (i.e., to be as efficient as we can so we can deliver the best service and products for you at the best price)
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party (i.e., to protect trade secrets and other commercially valuable information) To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business (e.g., performance, customer base, product range or other efficiency measures)	For our legitimate interests or those of a third party (i.e., to be as efficient as we can so we can deliver the best service for you at the best price)
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party (i.e., to prevent and detect criminal activity that could be damaging for us and for you) To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our provision of services to you or to take steps at your request before entering into a sales or services transaction To comply with our legal and regulatory obligations For our legitimate interests or those of a third party (e.g., making sure that we can keep in touch with our customers about existing orders and new products)
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party (e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you)
Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party (i.e., to promote our business to existing and former customers)

5. Promotional Communications

Chaiboy may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products. We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside of Chaiboy’s group for marketing purposes.  You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at [info@wearechaiboy.com];
• Using the “unsubscribe” link in emails or “STOP” number in texts; or
• Updating your marketing preferences on our Website. 

Chaiboy may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With

Chaiboy may share personal information with:

• Our affiliates, including companies within Chaiboy’s group;
• Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
• Other third parties we use to help us run our business, such as marketing agencies or website hosts;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Credit reporting agencies;
• Our bank(s);

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Sold or Disclosed for a Business Purpose

We have not sold or disclosed to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer.  

8. Where Your Personal Information is Held

Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).  Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

9. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, Chaiboy will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

10. Transferring Your Personal Information Out of the EEA

To deliver services to you, when you are located outside of the United States, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), for example:

• With our offices outside the EEA;
• With your and our service providers located outside the EEA;
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law. If you would like further information, please contact Chaiboy (see “How To Contact Us” below).

11. Your Rights Under the GDPR

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances (e.g., if you contest the accuracy of the data)
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information (e.g., processing carried out for the purpose of our legitimate interests)
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

12. Your Rights Under the CCPA

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and contact us via email.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.

13. Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Chaiboy employs encryption of personal information and take reasonable precautions to maximize the safety of all personal information. 

14. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please:

• Complete a request by contacting us via email at info@wearechaiboy.com; 

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly by email, you will need to provide us with:

• Enough information to identify you; 
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

15. How to File a GDPR Complaint

We hope that we can resolve any query or concern you raise about our use of your information.  The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. Contact Chaiboy for additional information. 

16. Changes to This Privacy Notice

This privacy notice was published in March of 2021 and last updated in March of 2021. We may change this privacy notice from time to time so please review the Privacy Policy periodically. 

17. How to Contact Us

Please contact us by mail, email, or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below:

Our contact details	CHAIBOY LLC
Email Address:	info@wearechaiboy.com

18. Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).