State of California	Rev. 123D779
VANESSA NAJA  PRIVACY POLICY

(Effective as of 01/23/24)  PRIVACY NOTICE This is the privacy notice of Vanessa Naja. In this document, "we", "our", or "us" refers to Vanessa Naja, affiliates, partners, eomployees and consultants. Our registered office is at Oakland, CA. Vanessa Naja (the “Company”) respects the privacy concerns of the users of its website, www.vanessanaja.com and the services provided therein (the “Site”). Vanessa Naja thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used. Please also review the Terms of Use at www.vanessanaja.com which also govern use of this Site. USE OF INFORMATION As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Vanessa Naja internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.

1. This is a notice to inform you of the Vanessa Naja policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. Vanessa Naja’s Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by Vanessa Naja only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. 
3. Vanessa Naja may also share such information with our business and promotional partners to further those interests. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our new products and promotion. You may always opt-out of receiving future mailings as provided below. 
4. Vanessa Naja does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.
5. Vanessa Naja may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Vanessa Naja rights or property, other users of the Site, or anyone else that could be harmed by such activities.
6. Vanessa Naja regrets if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
7. Vanessa Naja takes seriously the protection of your privacy and confidentiality. Vanessa Naja understands that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
8. Vanessa Naja undertakes to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
9. Our policy complies with the US, & UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
10. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. Vanessa Naja does this now, by requesting that you read the information provided at www.knowyourprivacyrights.org

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website. THE BASES ON WHICH WE PROCESS INFORMATION ABOUT YOU The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law Vanessa Naja shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. INFORMATION WE PROCESS BECAUSE WE HAVE A CONTRACTUAL OBLIGATION WITH YOU When you create an account on the Vanessa Naja website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. We may use it in order to:

1. verify your identity for security purposes
2. sell products to you
3. provide you with our services
4. provide you with suggestions and advice on products, services and how to obtain the most from using our website

Vanessa Naja processes this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. Vanessa Naja shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract. INFORMATION WE PROCESS WITH YOUR CONSENT Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.   If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.   Vanessa Naja continues to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.   You may withdraw your consent at any time by instructing us info@vanessanaja.com. However, if you do so, you may not be able to use our website or our services further.   INFORMATION WE PROCESS FOR THE PURPOSES OF LEGITIMATE INTERESTS   Vanessa Naja may process information on the basis there is a legitimate interest, either to you or to us, of doing so.   Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

  For example, we may process your data on this basis for the purposes of:  

• record-keeping for the proper and necessary administration of Vanessa Naja
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage Vanessa Naja risk
• protecting your interests where we believe we have a duty to do so

INFORMATION WE PROCESS BECAUSE WE HAVE A LEGAL OBLIGATION Vanessa Naja is subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order. This may include your personal information. Specific uses of information you provide to us INFORMATION PROVIDED ON THE UNDERSTANDING THAT IT WILL BE SHARED WITH A THIRD PARTY Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people. Examples include:

• posting a message our forum
• tagging an image
• clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. WE DO NOT SPECIFICALLY USE THIS INFORMATION EXCEPT TO ALLOW IT TO BE DISPLAYED OR SHARED. We do store it, and we reserve a right to use it in the future in any way we decide. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time. Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at info@vanessanaja.com.    COMPLAINTS REGARDING CONTENT ON OUR WEBSITE   Our website is a publishing medium. Anyone may register and then publish information about himself, herself or some other person.   We do not moderate or control what is posted.   OR   We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.   If you complain about any of the content on our website, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.   Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours or that of the person who posted the content that offends you.   If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.   INFORMATION RELATING TO YOUR METHOD OF PAYMENT   Payment information is never stored by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.   At the point of payment, you are transferred to a secure page on the website of PayPal or Stripe or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.   INFORMATION ABOUT YOUR DIRECT DEBIT   When you agree to set up a direct debit arrangement, the information you give to us is passed to paypal or stripe for processing according to our instructions.    We are registered under the direct debit guarantee scheme. This provides for the customer's bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.   SENDING A MESSAGE TO OUR SUPPORT TEAM   When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.   We record your request and our reply in order to increase the efficiency of our business.   We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.   COMPLAINING   When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.   If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.   We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.   AFFILIATE AND BUSINESS PARTNER INFORMATION   This is information given to us by you in your capacity as an affiliate of us or as a business partner.   It allows us to recognize visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.   The Information Is Not Used For Any Other Purpose.   We undertake to preserve the confidentiality of the information and of the terms of our relationship.    Vanessa Naja expects any affiliate or partner to agree to reciprocate this policy.   USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE   Cookies   Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalized experience and the website owner with statistics about how you use the website so that it can be improved.   Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.   Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.   Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.   WHY WE USE COOKIES ON OUR WEBSITE   Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.   PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY   Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.   We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.   If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website. OUR USE OF RE-MARKETING   Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advertisement for our products or services when you visit some other website.   We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.   MALWARE/SPYWARE/VIRUSES   Neither Vanessa Naja nor the Site knowingly permits the use of malware, spyware, viruses, and/or other similar types of software.   LINKS TO EXTERNAL SITES   Vanessa Naja is not responsible for the content or practices of third party websites that may be linked to the Site.  Vanessa Naja is also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices prior to disclosing any information.   DISCLOSURE AND SHARING OF YOUR INFORMATION   Information we obtain from third parties   Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.   No such information is personally identifiable to you.   THIRD PARTY ADVERTISING ON OUR WEBSITE   Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.   They may also use other technology such as cookies or JavaScript to personalize the content of, and to measure the performance of their advertisements.   Vanessa Naja does not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.   CREDIT REFERENCE   To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.   BULLETIN BOARDS AND CHAT AREAS   Guests of the Site are solely responsible for the content of messages they post on the Vanessa Naja forums, such as chat rooms, facebook groups and pages and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances.    Please take care when using these features. Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Vanessa Naja which you no longer wish to receive.    If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at info@vanessanaja.com including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.   DATA MAY BE PROCESSED OUTSIDE THE EUROPEAN UNION   Our websites are hosted in the USA.   We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.   Accordingly data obtained within the US, UK or any other country could be processed outside the European Union.   For example, some of the software our website uses may have been developed in the United States of America or in Australia.   Vanessa Naja uses the following safeguards with respect to data transferred outside the European Union:  

1. The processor is within the same corporate group as our business or organization and abides by the same binding corporate rules regarding data processing.
2. The data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union 
3. Vanessa Naja complies with a code of conduct approved by a supervisory authority in the European Union
4. we are certified under an approved certification mechanism as provided for in the GDPR
5. both our organization and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information

  ACCESS TO YOUR OWN INFORMATION   Access to your personal information  

1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
2. To obtain a copy of any information that is not provided on our website you may send us a request at info@vanessanaja.com
3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

  REMOVAL OF YOUR INFORMATION   If you wish us to remove personally identifiable information from our website, you may contact us at info@vanessanaja.com   This may limit the service we can provide to you.   VERIFICATION OF YOUR INFORMATION   When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.   Other matters   USE OF SITE BY CHILDREN UNDER 13    Vanessa Naja recognizes the special obligation to protect personally identifiable information obtained from children age 13 and under. AS SUCH, IF YOU ARE 13 YEARS OLD OR YOUNGER, THE Vanessa Naja REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE Vanessa Naja. If Vanessa Naja discovers that a child age 13 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.   Vanessa Naja nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:  

1. Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc
2. Know the sites your kids are visiting and which sites are appropriate.
3. Look for Website privacy policies. Know how your child’s information is treated.
4. Check out the FTC’s site for more tips on protecting children’s privacy online
5. Vanessa Naja does not sell products or provide services for purchase by children, nor do we market to children.
6. If you are under 18, you may not use our website.
7. Vanessa Naja collects data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
8. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.

  ENCRYPTION OF DATA SENT BETWEEN US   Vanessa Naja website uses Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.   Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.   HOW YOU CAN COMPLAIN  

1. If you are not happy with our privacy policy or if any complaints then you have should tell us by email. Our address is info@vanessanaja.com
2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. 
3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. 

  RETENTION PERIOD FOR PERSONAL DATA   Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:  

1. To provide you with the services you have requested;
2. To comply with other law, including for the period demanded by our tax authorities;
3. To support a claim or defense in court.

  COMPLIANCE WITH THE LAW   Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.   However, ultimately it is your choice as to whether you wish to use our website.   REVIEW/MODIFICATION OF THIS PRIVACY POLICY   Vanessa Naja may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We solely advise you to print a copy for your records.   If you have any questions regarding our privacy policy, please contact us.