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Privacy Policy

Effective: September 21, 2021

1. Introduction

This Zaffori Ventures, LLC Privacy Policy (“Privacy Policy”) describes how Zaffori™ collects, uses and otherwise processes your personal information that you disclose to us or that we gather in connection with your use of our website (www.zaffori.com) (“Site” or “website”) and our other services (“Services”). Our Site and related software and applications, electronic billboards, network, systems and functionalities are referred to herein as our “platform”.

The terms “Zaffori”, “we”, “our”, and “us” refer to Zaffori Ventures, LLC, a Texas limited liability company. The terms “you” and “your” refer to you, our designer/vendor/retailer/seller who intends and/or is licensed to sell a selection of their goods through our Services, customer who purchases items marketed and/or sold through our Services, a visitor to our website, or other user of our Services.

Zaffori provides an online retail platform/marketplace on which approved designers/vendors/retailers/sellers of apparel and accessories can market and sell a selection of their luxury and designer goods and shoppers can view, review and purchase these goods from those sellers. Zaffori is not the designer, owner, manufacturer, or seller of these goods. Users of our platform may purchase the listed goods from those approved sellers through the use of our website and other Services and by use of a third-party payment service to process payments for the goods purchased. We are not the seller of those goods. We provide or facilitate the fulfillment services, including warehousing, packaging and shipping the orders using third-party delivery services chosen by the customers. We are not responsible for the quality or fitness of the goods.

You agree to comply with all laws, regulations, directives and orders that are applicable to you and your use of our Services. Your use of any of our Services, including, but not limited to, your use of our Site, is your agreement and consent to be bound by our policies, which include the Zaffori Ventures, LLC Terms of Use (“Terms of Use”) and the Zaffori Ventures, LLC Returns & Refunds Policy (“Returns & Refunds Policy”), which policies may be updated from time to time, and a copy of the most current version of said policies may be accessed at www.zaffori.com (these policies are collectively referred to herein as “Policies”); and, users who are also sellers, are bound by said Policies as well as the Zaffori Ventures, LLC Sellers Agreement (“Sellers Agreement”).

When you use our Services, you consent to our collection, use, storage, disclosure, transmission and other processing of your information as described in this Privacy Policy. If you do not want us to collect, use or otherwise process your information as described in this Privacy Policy, please do not use our Services. This Privacy Policy will be updated from time to time and the effective date of the current version will be shown at the top of the page and/or in the footer. A copy of the most current version of this Privacy Policy may be accessed at www.zaffori.com. This Privacy Policy may be made available in multiple languages, but the English language version shall govern your relationship with us and, in the event of any conflict among versions of this Privacy Policy, the most recently updated English language version shall govern and control.

As stated in our Terms of Use, we do not permit vendors/sellers who are under twenty-one (21) years of age to market or sell their goods on our website. Minors (under eighteen (18) years of age) or persons who lack the legal capacity to contract may only use our Services with the permission and under the direct supervision of the adult owner of the account. Children under thirteen (13) years of age are not permitted to use our Services.

We are not responsible for the content, privacy policies or practices of third parties or for third-party websites or apps. At the inception, our focus is to operate in the United States and to only process orders for shipment in the United States and Canada and we will use and otherwise process your information in the United States and other countries in which we operate. Please note that the laws protecting personal data and privacy, including your rights as to your personal data, may differ from those that apply in your country, state or jurisdiction of residence or from which you access our Services. We will transfer your data across jurisdictions only as necessary in our operations and to the extent permitted by applicable laws.

Your use of your devices to access our Site and our other Services will be subject to the privacy policy, terms of use, cookie policy and other policies and legal requirements of your third-party service providers, including, but not limited to, your device provider, wireless service providers, internet service providers and other sites, platforms and services you use to access our Services. We do not control and are not responsible for the content, ads, data processing, privacy policies or practices of those third-party providers, platforms and sites.

All trademarks, tradenames and other intellectual property associated with our Services are the property of Zaffori and its licensors. Reference to third party goods and services, including references to the third party payment processor who processes payments of customer orders on www.zaffori.com, are not meant to indicate any partnership, joint venture, or other relationships between Zaffori and those companies or any sponsorship of Zaffori or our Services by any of those companies.

2. Information we Collect or Receive and for what Purposes

Sources and Purposes: We collect your personal information from many sources, including: information that you provide to us (in contracts you sign with us, from creating your account and profile, any seller’s application submitted to us, from your communications with us, and from your transactions over our platform), information provided to us from third-party service vendors (such as payment processing vendors and from delivery and other fulfillment vendors), and information collected from use of cookies. Our overriding purposes for collecting and otherwise processing your personal information is to provide our Services and to continually improve our Services.

From Designers/Vendors/Seller: Sellers who want to sell their goods on our platform must (a) create an account on our Site by establishing a user name and password, (b) agree to our Sellers Agreement, this Privacy Policy, our Terms of Use, our Returns & Refunds Policys and other applicable policies, (c) complete and submit a seller’s application for our approval, (d) establish a seller’s account and seller’s profile with us, (e) obtain a seller’s ID, and (f) otherwise comply with the Sellers Agreement, this Privacy Policy and our other Policies. For these purposes, you will provide to us and/or our third-party service providers (such as the payment processing vendor, banks and other financial institutions, marketing and advertising vendors, IT support vendors and fulfillment vendors such as shipping and delivery services) all or some of the following personal information: name, physical address, email address, phone number, location information, age, information you submit to us on your seller’s application, other identity information (which may include social security number, driver’s license number, passport information, photograph), information about your authorized representatives, corporate/business information, ownership information, financial information, credit history and credit information, payment card information and banking information to process payments (including name and location of bank, other financial information for transfer and/or debit payments, account number, routing number, account name, credit card number, security code, expiration date, billing address, credit balance), personal description and photographs in your seller’s profile, photographs of your goods and you or other persons modeling or displaying your goods, and any personal information disclosed pursuant to your Sellers Agreement with us. We will also collect from you, our platform, or our third-party service providers the following information: information about goods you submit to be listed for sale on our platform; information on goods you ship to our fulfillment center; information on fees and payment of fees assessed for the shipment of goods to our fulfillment center and/or for shipment of goods to your designated address from our fulfillment center; delivery updates and address information which we will use to update the status of your shipments, including shipments to our fulfillment center, to and from customers, and to your designated address; payment status updates which we will use to determine your account status or creditability; information on returns, disposals, recalls, warranty claims and other claims and complaints which we will use to measure your and your goods performance on our platform; and other information disclosed pursuant to your Sellers Agreement with us. We will also collect from you, our platform, use of cookies, and other sources and we process vendor/seller transaction data, including transaction date, shipping and delivery information, inventory status, sales, prices, payment method, revenues, returns, refunds, our commissions, delivery charges, customs duties and fees, regulatory fees, payment processing fees, taxes, payments to you and payment status, and other information disclosed pursuant to your Sellers Agreement with us. We will also collect from you, our platform, use of cookies, customers, visitors, and other sources data and information about you and your goods, including about your rankings, sales, purchases, reviews, returns, claims, other marketing and sales information and other information disclosed pursuant to your Sellers Agreement with us.

From Customers: When you purchase, review and/or return goods sold on our platform and/or establish a customer account with us, you must agree to this Privacy Policy, our Terms of Use, our Returns & Refunds Policy and other applicable policies and you may establish a customer account, user name and password with us or you may elect to check out as a guest. For these purposes, you will provide to us and/or our third-party service providers (such as the payment processing vendor and fulfillment vendors such as shipping and delivery services) some or all of the following information: name, physical address, email address, phone number, location information, age, gender, sizing information, preferences, personal description and photographs in your profile, other identity information, information for your method of payment (such as credit or debit card number, security code, expiration date, credit balance, billing address), credit verification information (such social security number, driver’s license number, passport information). We will also collect from you, our platform, or our third- party service providers the following information: delivery updates and address information which we will use to update the status of your orders and shipments; payment status updates which we will use to determine your account status or creditability; information on returns, frequency of returns, reviews, warranty claims and other claims and complaints which we will use to measure your customer status on our platform. We will also collect from you, our platform, use of cookies, and other sources and process customer transaction data, including transaction date, item(s) purchased, shipping and delivery information, prices, payment method, frequency of transactions, returns, refunds, delivery charges, customs duties and fees, regulatory fees, payment processing fees, and taxes.

From all Users (including designers, vendors, sellers, customers and browsers and other visitors): When you visit our platform, browse our Site or otherwise use our Services, you agree to this Privacy Policy, our Terms of Use, our Returns & Refunds Policy and other applicable policies. We will collect and otherwise process the personal information described above that you provide to us while using our Services. In addition, to monitor the safety and security of our platform and to enhance user experience, we use cookies and other tracking technologies and we collect some or all of the following information: internet protocol (IP) address used to connect your computer/device to the internet, location of your computer/device, browsing activities and history (such as Uniform Resource Locator (URL) or Uniform Resource Identifier (URI), click path or clickstream information including date and time, goods you viewed or searched for, downloads, duration of visit or activities).

User Content: The term “user content” or “content” includes the information you post via use of our Site, including, your ratings, reviews, sentiments, feedback, texts, graphics, photos and videos and also product listings for sellers. Your content is intended for public viewing and consumption with no payment or other compensation to you and no privacy right or protection is granted herein to your content. Other users of our Services may review or comment on your posts, may reshare your posts, may create similar posts and share their reviews and comments for other users to see, comment on and/or reshare. Based on your activity or lack thereof on our platform, other users can determine whether you are active or not on our platform. You are responsible for the content you post, including its legality, reliability, and appropriateness. Your posts must comply with the content guidelines in our Terms of Use. Your content must be your original creation. If you use any third-party content, you must duly obtain their permission to use their content. We may use data analytics software to combine sales data, reviews, demographic data and other content you provide and aggregate the data and we use the anonymized, aggregated data to market and enhance our Services.

Communications: If you provide a profile on our website or communicate with us via email or otherwise, you may provide us with your name and email address. We use this data to communicate with you. When you receive an email from us through our website or platform, you can select the unsubscribe option in said email and our system will stop sending you emails, except (a) to communicate or record the exercise of your option to unsubscribe, (b) for sellers pursuant to the Sellers Agreement, or (c) for other legally permitted purposes.

Use by Service Providers and Successors: Our employees and contractors who have a bona fide need to access our servers and review our data to manage, support, maintain and upgrade our website, platform and other systems and infrastructure will have access to and use of your information in order provide said services. In connection with the sale of our assets or a merger or reorganization, we may disclose and/or transfer your information to the buyer or our successor, in which event we will require adequate safeguards from said buyer or successor for the protection of your information similar to those set forth in this Privacy Policy.

Processing in and outside the USA: We are based in the United States but provide Services internationally. Our developers, employees and contractors are located or may later be located in several countries and they will have access to the information we process at or from their locations. Generally, information that we collect in the United States will be processed primarily within the United States. We also utilize third-party tools and services, through which some of your information may be transmitted or otherwise processed within and outside the United States, including the following: (a) internet and other communications lines and facilities for transmission of data; (b) cloud-based storage services whose servers may be located in multiple countries, for storage, access and other processing; (c) email and document file hosting services whose servers may be located in multiple countries; and (d) vendors and service providers to manage, support, maintain and upgrade our websites, platform and other systems and to provide payment processing services and delivery and other fulfillment services.

Information we do not Collect: We do not knowingly collect or otherwise process personal information of children.

Marketing: Except for use of sellers personal information pursuant to the Sellers Agreement, in the event we use any of your personal information to market our Services to you, we will secure your consent for such use where required and you will also have the opportunity to opt out of our use of your personal information for marketing purposes.

Ads: Application platforms, social media sites, internet browsers and businesses that are allowed to post ads and otherwise advertise and market on our platform may post ads and other content that will be displayed on and viewed by users on our Site. You may be able to set your user preferences on your devices to opt out from or manage advertising preferences and, in some instances, you will not be able to avoid viewing the ads or other content while browsing or using our platform or Services. We do not control what device settings or preferences, wireless service providers, internet service providers, internet browsers, application platforms and your device providers make available to you to manage targeted advertising and other content. Your use of your devices on these wireless service providers, internet service providers, internet browsers and application platforms and your use of social media sites will be subject to the privacy policy, terms of use, cookie policy and other policies and legal requirements of those providers, browsers, platforms and sites. We do not control and have no responsibility for the ads and content that your device providers, wireless service providers, internet service providers, internet browsers, application platforms or social media sites post or permit third parties to post on their platforms or while you are using our Services or platform and we do not undertake any obligation to monitor or sensor those ads and content. You are solely responsible for setting your user preferences on your devices to control what content is viewed through your devices.

3. Cookies and Tracking Technologies

Our Use of Cookies: If we are using cookies or other tracking technologies on our platform to track your activities on our Site, you will see a pop-up notice to that effect and would have an opportunity to accept or refuse the use of cookies with respect to your use of our Site; and, if you reject the use of cookies, you may not be allowed to proceed further on the Site or your use of the Site will be limited.

A cookie is a text file sent by a web server to a web browser and that is stored by the browser on your computer hard drive. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. The deployed cookie may be stored on the browser on the user’s computer hard drive. There are electronic images known as web beacons, including in marketing email messages, to help deliver cookies from websites, count users who have visited those sites, deliver services, analyze the effectiveness of promotional efforts and determine if a marketing email message is opened. Most browsers allow the user to refuse to accept cookies. A user can set his/her browser to refuse all or some cookies or to alert the user when websites set or access cookies. Disabling or refusing cookies will have a negative impact upon the usability of the website, as some parts of the website may become inaccessible or not function properly. By use of cookies and other tracking technologies, data about a user’s use and visits to the website can be collected, including internet protocol (IP) address, referral source, browsing history, length of visit, geographical location, items and number of pages or content viewed, copied or downloaded. Information obtained from the use of cookies and similar tools is usually used in connection with the administration of a website, to improve the website’s usability, to help in the administration and protection of the website’s services, analyze usage, improve user experience, for marketing purposes, to recognize the user’s computer when the user visits the website, and to personalize the website for the user.

Third-party Cookies: Application platforms, wireless service providers, internet service providers, internet browsers and social media sites and other sites you visit may use cookies and other tracking technologies pursuant to their cookie policies, privacy policies, and terms of use posted on their respective platforms and sites. You should read those policies before accessing those platforms or sites. We do not control the providers, application platforms or other sites’ use of cookies and other tracking technologies. You may be able to reject or opt out from the use of cookies or to delete cookies from your browser.

Third-party links: Our website and platform may provide links or references to third-party websites, plug-ins and applications. Third-party advertisements may also be displayed in association with our website and links may be provided to said third-party sites, services and goods. The publications of said ads and provision of said links do not mean that we endorse the third-party ads, services, goods, content, data processing or protection mechanisms or their cookie policies, privacy policies or terms of use. We do not control any third-party websites or data collection or processing activities. If you visit third-party sites, download their applications or enable the links, you will probably enable third parties to collect, share and otherwise process your personal data. You assume all risks by visiting third-party websites or using or enabling applications or links. You are encouraged to read the cookie policies, privacy policies and terms of use of every website you visit.

4. Information Protections and Risks

Protections: We have committed to maintaining reasonable technical, organizational and physical safeguards to protect your personally identifiable information that we collect and use, against unauthorized access, use, reproduction, alteration, disclosure, dissemination and destruction, taking into account the nature of the data, our use of the data and the threats posed.

Risks: Unfortunately, no data transmission over the Internet, no electronic storage of data and no website, system or facility is fully secure or immune from cyberattack or compromise. You understand that any message or information you send to us may be read or intercepted by others. Accordingly, and despite our efforts to protect your information, we cannot guarantee or warrant absolute security of your information.

5. How Long do we Keep your Information

We retain your contracts, other transaction data and related communications for as long as you maintain an account with us and as long as we are required or advised by our legal counsel to maintain those records to enforce those contracts and for legal compliance, which may be three to seven years in most cases. We may retain your ratings, reviews and sentiments and posts indefinitely, including for as long as you maintain a username and password or an account on our Site or for as long as we deem appropriate to satisfy our legal rights and obligations. We may retain your name and email address until you opt out or unsubscribe to communications from us or for a longer period to satisfy our legal rights or obligations, including under a Sellers Agreement for sellers. We may retain your personal information for the period necessary to fulfill the purposes for which the information was given to us and for a reasonable time period thereafter or indefinitely to support our compliance with this Privacy Policy and applicable laws, including retaining evidence of your consent and your opt out, unsubscribe, erasure and other rights requests. We may delete your information if we believe that the information is incomplete, inaccurate, or that our continued use and storage of such information is contrary to our obligations. In some instances, we may anonymize, pseudonymize or aggregate your information so that the data is no longer identified with you, but the data may remain in our archives for research or statistical purposes and may remain indefinitely for such purposes or if we determine it is not practical or possible to delete it.

6. Consent & Parental Responsibility

Consent to Process: You consent to our use and other processing of your information pursuant to this Privacy Policy. Do not disclose your information to us unless you have freely given your consent for us to process your information pursuant to this Privacy Policy. Your consent may be given in several ways, including when you establish an account with us, when you complete or update your profile on any of our Site or platform, by you clicking an “opt-in”, “I agree”, “I consent” or other similar buttons on our Site or platform, or when you transact business with us. In some instances, you will give your consent to another individual, entity or company, such as your authorized representative, employer or other controller of your information from whom we receive your information and, in these instances, we will assume that your consent was freely given to such person or entity and that said consent includes your consent for us to process your information pursuant to this Privacy Policy.

Children & Parental Responsibility: We do not knowingly permit persons under thirteen (13) years of age to use our Site or platform. We do not knowingly collect or otherwise process personal information of children. Do not provide your consent or personal information if you are under thirteen (13) years of age. In any event, we have no obligation and we do not intend or desire to contract with you unless you are of the age set by applicable law for you to be bound by a contract with us. Minors (under eighteen (18) years of age, but not younger than thirteen (13) years of age) or persons who otherwise do not have the legal capacity to contract to use our Services may only use our Services through an account owned by their parent or legal guardian and/or with said parent or legal guardian’s consent and direct supervision. Said parent or legal guardian is responsible for any and all activity on our website or platform conducted by a minor or persons who otherwise do not have the legal capacity to contract.

7. California Residents

The State of California enacted the California Consumer Privacy Act of 2018 (“CCPA”) that gives California residents certain rights related to the collection, use and sharing of their personal information. The CCPA only applies to certain companies and activities. As of the date of this Privacy Policy, the CCPA does not apply to Zaffori. Zaffori does not sell your personal information and will not do so in the future without giving you the required notice and opportunity to opt out of the sale. Zaffori does not offer financial incentives to others in connection with the collection, use or disclosure of your personal information. To the extent that the CCPA becomes applicable to Zaffori, if you are a California resident, you will have certain rights with respect to your personal information, including the right to (a) request to know what personal information Zaffori has collected about you and to access that information and (b) request the deletion of your personal information, subject to certain exceptions that allows us to retain said information. We will not discriminate against you for exercising your rights under the CCPA. Under the California Shine the Light Law, California residents have the right to request certain companies to disclose what personal information the companies share with third parties for those third parties’ marketing purposes. Zaffori does not disclose your personal information to third parties for marketing purposes.

8. Nevada Residents

Nevada enacted SB 220 under which website operators are required to provide a way for Nevada consumers to opt out of certain sales (as defined in the statute) of certain personally identifiable information about them that the website operator collects. Zaffori does not sell your personal information and will not do so in the future without giving you the required notice and opportunity to opt out of the sale. When and to the extent that this law becomes applicable to Zaffori, if you are a Nevada resident, you may submit your opt out requests to the Data Security Office via the email provided below in this Privacy Policy.

9. Virginia Residents

Virginia enacted the Consumer Data Protection Act (“CDPA”) to go into effect January 1, 2023. The CDPA applies to certain data controllers who target Virginia consumers and processes personal data of a stated threshold volume of Virginia consumers. Zaffori does not target Virginia consumers and does not sell your personal information and will not do so in the future without giving you the required notice and opportunity to opt out of the sale. As of the date of this Privacy Policy, the CDPA does not apply to Zaffori. To the extent that the CDPA becomes applicable to Zaffori, Virginia residents will have the right (a) to know what personal information Zaffori has collected about them and for what purpose, (b) to correct inaccuracies in their personal data, (c) to have personal data deleted, (d) to obtain portable copies for automated transfer, and (e) to opt out of targeted advertising, profiling, and sale of personal data.

10. European Residents Subject to GDPR

The European Union General Data Protection Regulation (“GDPR”) imposes certain obligations upon certain companies conducting business in the EU and provides certain rights for data subjects with respect to their personal data. The GDPR defines the term “personal data” as follows: any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Generally, we are authorized to, and will, process your personal data if at least one of the following applies: (a) you gave consent to process your personal data for one or more specific purposes; (b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; (c) processing is necessary for compliance with a legal obligation to which the data collector, controller or processor is subject;

(d) processing is necessary in order to protect your vital interests or the vital interests of another natural person; and (e) processing is necessary for the purposes of the legitimate interests pursued by the data collector, controller or processor, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where the data subject is a child.

Data subjects have the following rights, subject to certain conditions and limitations: (q) to consent to the processing of their personal data; (r) to request access to their personal data that is being processed; (s) to request rectification (correction) of their personal data; (t) to be forgotten (i.e., to have their personal data erased) in certain instances; (u) to restrict further processing of their personal data; (v) to notification of disclosure, rectification or erasure of their personal data;

(w) to portability (i.e., to have their personal data transferred to them or to another data controller); (x) to object to certain processing of their personal data, including in connection with the data controller’s pursuit of certain legal rights, profiling or marketing; (y) to object to their personal data being subject to automated decision making about them, such as profiling; and (z) to withdraw their consent to process their personal data. If we erase a data subject’s personal data from our system, upon such erasure we will be unable to recreate that data subject’s personal data.

If the GDPR applies to you and in the event the GDPR transfer requirements apply to our extraterritorial transfer your personal data, we will utilize standard contract clauses, rely on the EU adequacy decisions, obtain your consent or other requirements provided by the GDPR or otherwise satisfy the required conditions for said transfers. A data subject may lodge a complaint with a supervisory authority, if the processing of their personal data infringes the GDPR. Should the GDPR apply to you, we would appreciate the opportunity to address your complaint before you escalate the matter to a supervisory authority proceeding, so please contact us with your complaint so that we can address it as soon as possible to mitigate any resulting damages. You may contact our Data Security Office with respect to your legal rights affecting our use of your personal data.

11. Other Jurisdictions

The laws of each jurisdiction for the protection of data privacy may vary and may not offer the same level of data privacy protection as the laws in your home jurisdiction. We will implement reasonable safeguards to protect your data in accordance with applicable law. By using our Services or transferring your personal information to us you consent to our collection and use of your personal information as provided in this Privacy Policy.

12. Overriding Requirements

Applicable laws may provide compelling, legitimate grounds for processing personally identifiable information, personal data, and user content for the establishment, exercise or defense of legal claims, which override your interests, rights and freedoms. The data privacy laws in some countries may be less stringent than the laws of your country and the government, law enforcement and courts of some countries may be able to access your personally identifiable information, personal data and user content in certain circumstances. Some court orders, subpoenas, administrative agencies’ orders, or contracts may require us to take certain actions with respect to personally identifiable information, personal data and user content, including disclosing your personally identifiable information or personal data, that may be contrary to your requests and instructions and we may have to defer to the foregoing laws, orders or contracts in certain circumstances. Where we deem appropriate and permissible, we will seek protective orders to protect your personally identifiable information or personal data from such compelled disclosures. As a processor, we may be required to follow the instructions of the controller. A third-party contract under which we receive your personally identifiable information or personal data (e.g., a contract with your employer) or applicable laws may require us to retain business records, which may include personally identifiable information or personal data, for a period that is longer than the period allowed under other laws or regulations or that you prefer. We reserve the right to disclose, modify, delete, take down, block, and otherwise use your personally identifiable information, personal data and user content as we deem appropriate to comply with applicable laws, regulations, directives, orders, subpoenas, rules, legal process, and contractual obligations and in responding to claims and complaints relating to infringement, identity theft, misuse and misappropriation.

13. Presumption of Authenticity

We will rely on the data we have in our file to verify the accuracy of, and honor or respond to, your requests or instructions regarding your personal data. We will assume that your request or instruction is authentic if it uses your name or email address that you provided to us or that was provided to us by a third party who had apparent authority to share your data with us, such as your employer. We rely on you to notify us of any inaccuracy in your information and to promptly correct your profile information or request rectification of your information. In some instances, we will request additional data from you to verify the authenticity of your requests, including your request to delete or modify your personally identifiable information or personal data, such as your name, username and password, and email address.

14. Communications – Data Security Office

All requests and complaints regarding our processing or use of your personally identifiable information or personal data must be directed to our Data Security Office using the information provided below. We will respond to your requests for the exercise of your rights in the time required under applicable laws, giving due regard to our overriding obligations.

Zaffori Ventures, LLC
Data Security Office
252 West 38th Street
Suite 501
New York, New York, 10018
sales@Zaffori.com