Privacy Policy

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Privacy Policy

Privacy Policy for PassinGrass Clothing

Privacy Policy

Last updated: December 14, 2022

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Free Privacy Policy Generator.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to PG EMPIRE, LLC, 2150 Portola Avenue Suite D 298 Livermore, CA 94551.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: California, United States
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to PassinGrass Clothing, accessible from https://www.passingrassclothing.com
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Free Privacy Policy website article.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential CookiesType: Session CookiesAdministered by: UsPurpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By email: contact@passingrassclothinggmail-com

Privacy Policy For Our Dropshipper

Welcome to Printful’s Privacy Policy!

Printful, Inc. (“we”, “our”, “us”, or “Printful”) respects the privacy of its users and is fully committed to protect their personal data and use it in accordance with data privacy laws. This Privacy Policy describes how we collect, use, and process any personal data that we collect from you—or you provide to us—in connection with your use of our website (www.printful.com) or our mobile apps and our print-on-demand services (collectively, “Services”). By accessing or using our Services, you signify your understanding of the terms set out in this Privacy Policy.

We do not knowingly collect, maintain, disclose, or sell the personal information about users under the age of sixteen (16). If you are under the age of 16, please do not use our Services. If you are under the age of 16 and have used our Services, please contact us at the email address below so that we may delete your personal information.

If you use our Services only for your personal use, you are to be considered as the “User” and for the purpose of the General Data Protection Regulation (“GDPR”) and the UK General Data Protection Regulation (as defined by the UK Data Protection Act 2018 as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019), we are the data controller.
If you use our Services to execute orders and deliver products to third parties, you are to be considered as the “Merchant” and with regard to your contact details and the other data listed in Section 1 below, we are the data controller. Where we act on a Merchant’s behalf to fulfil an order with regard to the Merchant’s customer, we are a data processor: please see our Data Processing Terms.

Note that while our Services may contain links to other websites or services, we are not responsible for each respective website’s or service’s privacy practices and encourage you to be aware of this when you leave our Services and carefully read the privacy statements of each and every website and service you visit. This Privacy Policy does not apply to third-party websites and services. If you wish to contact Printful regarding your personal data or this Privacy Policy, please contact us at privacy@printful.com.

1. Information we collect

1.1. Information collected about Users and Merchants and how we use it

Where you are a User and it is necessary to fulfil our contract with you for the purposes of providing, maintaining, or improving our products and Services (including, to the extent permitted by applicable law, any matters in our legitimate interests with respect to the Services), we will confirm your identity, contact you, provide customer support (including via chat, in the comment section of our blog, or other platforms, where you may reach us), operate your account with us and invoice you. For the aforementioned purposes, we collect information that may contain the following personal data:

  • Name;
  • Company name;
  • Shipping information;
  • Email address and phone number;
  • Payment and billing information (payment method details, first and last digits of your payment card);
  • Order handling information

If you have given your consent when registering your account, when subscribing to our newsletter or blog, or shared your email address or other personal data with us to receive any other information (for example, our list of sub-processors), we will process your email address to send you the informative and/or promotional materials, to which you have subscribed to, for example, newsletters, advertisements of our Services and other information about our Services that you have requested. At any point in time you can unsubscribe from receiving the above-mentioned information in our email footers and through your notification settings on Printful. For Merchants, we will not use the contact details of your customers to directly market or advertise our Services to them.

We obtain location information you provide in your profile or your IP address. We use and store information about your location to provide features and to improve and customise the Services, for example, for Printful’s internal analytics and performance monitoring; localisation, regional requirements, and policies for the Services; for local content, search results, and recommendations; for delivery and mapping services; and (using non-precise location information) marketing.

When you call our customer support phone line, we may monitor or record the call to ensure the quality of our customer support. If you have a Printful account, we will retain the recording for as long as you have an account. If you do not have an account, we will delete the recording within 12 months or retain it, if it will be needed to resolve disputes between you and us.

By using cookies and similar technology on our website, we may collect data such as information on your device, your preferences and information filled while visiting our website, your interaction with the website, and other information used for analytical, marketing, and targeting activities (including unique visits, returning visits, length of the session, actions carried out in the webpage). Learn more about how we use cookies on our website and how to opt out of interest-based advertising by clicking here.

As it is in our legitimate interests to ensure our network security, give you access to and to improve our Services, we also collect the following technical usage data:

  • How and when you access your account;
  • Information about the device and browser you use;
  • IP address and device data.

1.2. Information collected about our Merchant’s Customers

Where we act on a Merchant’s behalf to fulfil an order with regard to the Merchant’s customer (i.e. an end user of our Services), we are a data processor and we collect information relating to the Merchant’s customer, such as personal data relating to the end user of our Services, any personal data in the printing content (where applicable), personal data revealed during the use of any Printful services, including name, email address, phone number, shipping address, and other information about the Merchant’s customers.

If you are a customer of the Merchant (an end user of our Services), the Merchant is the data controller with regard to your personal data and should provide you the information on how your personal data is collected and processed when using our Services. Please read the Merchant’s privacy policy for further information. The Merchant is your contact for any questions you have about how it handles your personal data.

2. Sharing personal data with third parties

In order for Printful to provide you with our Services, we work with third parties who perform services on
our behalf and with whom we share personal data to support our Services (“Service Providers”).

Information you have provided to us during the use of our Services, including technical usage data, is shared for business purposes in our legitimate interests with third parties who provide hosting and server co-location services as well as data and cyber security services.

Information you have provided to us during the use of our Services may be shared with third-party manufacturing services whom we engage to provide our Services to you.

Your email address and other contact details you have provided to us and your messages to our customer service is shared for business purposes in our legitimate interests with communication, email distribution, and content delivery services as well as customer support system providers.

Information regarding your purchases and payments is shared with billing and payment processing services, fraud detection and prevention services, accounting and financial advisors, advisors, so that we can provide our Services
to you.

Information regarding your use of our website and other information received from cookies and similar technology is shared with web analytics, session recording, and online marketing services.

If we provide marketing to you, information on your account, purchases and preferences can be shared with marketing services.

Insofar as reasonably necessary to defend our legal rights, we may share your personal data with our legal advisors.

We will only share personal data to Service Providers that have undertaken to comply with obligations set out in applicable data protection laws.

We may share your personal data with our affiliates (companies within our corporate family), in our
legitimate interests for business purposes.

In certain circumstances, we are required to share information with third parties to comply with legal requirements or requests, as well as to protect our, or a third party’s, lawful interests. We will also disclose your information to third parties in and outside your country only to the extent allowed by applicable law, including:

  • to a prospective purchaser or purchaser that acquires all or substantially all of us or our business;
  • to a third party in the event that we sell or buy any business or undergo a merger, in which case we may disclose your information to the prospective buyer of such business; and
  • to a third party if we sell, buy, merge or partner with other companies or businesses, undergo a reorganisation, bankruptcy, or liquidation; or otherwise undertake a business transaction or sell some or all of our assets. In such transactions, your information may be among the transferred assets.

3. Retention periods

We may retain your personal data for as long as you have a Printful account or any of the abovementioned legal bases for personal data processing still exists. For example, if you unsubscribe from our marketing, newsletter, or blog emails, we will stop the processing of the personal data for such purposes. If you have used our Services without creating a Printful account, we will keep your personal data as long as necessary to comply with our legal obligation to retain information relating to provision of services, for example, for tax purposes.

After terminating your relationship with us by deleting your Printful account or otherwise ceasing to use our Services, we may continue to store copies of your (and in regard to Merchants, your customers’ personal data) as necessary to comply with our legal obligations, to resolve disputes between you and us (or you and your customers), to prevent fraud and abuse, to enforce our agreements, and/or to protect our legitimate interests (to the extent that we are permitted by the applicable law to continue to store copies to protect our legitimate interests).

4. Data subject’s rights

If you are a User or Merchant located in the European Economic Area or the United Kingdom, in accordance with European Union and United Kingdom data protection regulations, you have certain rights with respect to your personal data. You have the right to request access to your personal data; in certain circumstances to correct, amend, delete, or restrict the use of your personal data by logging into your Printful account or by reaching us using the contact information provided below. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we are not required to process your data to meet a contractual or other legal requirement). These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to retain, are permitted by law to retain, or have compelling legitimate interests in retaining (to the extent that applicable law permits us to retain such information based on our legitimate interests).

Furthermore, if you believe that we have unlawfully processed your personal data, you have the right to submit a complaint to the contact information provided below, or to your respective data protection supervisory authority. If you are a customer of a Merchant (an end user of our Services), please direct your concern to the relevant Merchant in the first instance.

5. Information security

We seek to use reasonable organizational, technical, and administrative measures to protect the confidentiality, integrity, and availability of personal data. We encourage you to take care of the personal data in your possession that you process online and set strong passwords for your Printful account, limit access to your computer and browser by signing out after you have finished your session, and avoid providing us with any sensitive information.

6. International transfers of data

All the information you provide may be transferred or accessed by our parent company in the United States our affiliate companies and subsidiaries in other countries, such as Latvia, Poland, Spain, and the UK and our Service Providers (as described above) for the provision of our Services as described in this Privacy Policy. When we transfer your information globally, we take necessary measures to ensure appropriate protection of your information, including, as applicable, entering into the European Commission’s Model clauses for the transfer of personal data to third countries (i.e., the standard contractual clauses) and any equivalent clauses issued by the relevant competent authority of the UK.

7. Privacy Policy addendum for California residents

Under the California Consumer Privacy Act (“CCPA”), California residents are afforded certain rights about the Personal Information (as such capitalized term is defined under the CCPA) we have collected about them, which we have described in more detail below.

We are both a “business” and a “service provider” under the CCPA, depending on how you interact with us. This section applies only to personal information we collect in our role as a business. Where we act on a Merchant’s behalf to fulfil an order with regard to the Merchant’s customer, we are a Service Provider under the CCPA. Please read the Merchant’s privacy policy for further information on how to exercise your rights under the CCPA. The Merchant is your contact for any questions you have about how it handles your Personal Information.

In the chart below, we have described the categories of Personal Information that we have collected and shared over the past twelve (12) months, the purposes for such collection and the types of entities with whom we have shared such information.

Categories of Personal InformationSources of InformationUse of InformationSharing of Information
Identifiers, including your name, postal address, email address, and telephone number. These data types also include “personal information,” as the term is defined by Cal. Civ. Code 1798. We collect this information directly from you.We use this information to: provide, maintain, and improve our products and Services; provide customer support (including via chat, in the comment section of our blog, or other platforms, where you may reach us), operate your account with us and invoice you. We share this information with Service Providers and certain other individuals and entities as described in the section above entitled “Sharing Personal Data with Third Parties.” 
Commercial information.We collect this information directly from you.We use this information to process your transactions and deliver our products to you.We share this information Service Providers and certain other individuals and entities as described in the section above entitled “Sharing Personal Data with Third Parties.”
Internet or other electronic network activity information, such as IP addresses and cookies. We collect this information automatically from your computer or device.We use this information to provide, maintain, and improve our Services and to personalize your online experience.We share this information with Service Providers and certain other individuals and entities as described in the section above entitled “Sharing Personal Data with Third Parties.” 
Audio Information We collect this information directly from you.We use this information to ensure the quality of our customer support.Not applicable.
Professional and employment related information. We collect this information directly from you.We collect such information if you apply for a job via our careers page and use it in connection with processing your application.Not applicable.
Educational information, such as the information included in your resume. We collect this information directly from you.We collect such information if you apply for a job via our careers page and use it in connection with processing your application.Not applicable.

Rights under the CCPA 

If you are a California resident, the processing of certain personal information about you may be subject to the CCPA. Where the CCPA applies, this section provides additional privacy disclosures and informs you of key additional rights as a California resident. We will never discriminate against you for exercising your rights, including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

Right to Know Request

Under the CCPA, California residents have a right to request information about our collection, use, and disclosure of your personal information over the prior twelve (12) months, and ask that we provide you free of charge with the following information: 

  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.

Right to Delete Request

Under the CCPA, you also have a right to request that we delete personal information, subject to certain exceptions. 

Right to Opt-Out of the Sale of Personal Information 

You may request that we not sell your Personal Information. Please note, however, that CCPA defines “sale” very broadly, and includes “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California consumer’s Personal Information by the business to another business or third party for monetary or other valuable consideration.” We use services that help deliver interest-based ads to you and may transfer Personal Information to business partners for their use. Making Personal Information (such as online identifiers or browsing activity) available to these companies is considered a “sale” under the CCPA.

How to Exercise Your Rights

If you are a California resident to whom the CCPA applies, you may contact us to exercise your rights:

Click here to request or delete your data.Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth. You may make a verifiable consumer request to access your personal information twice per twelve (12) month period. We aim to fulfill all verified requests within 45 days pursuant to the CCPA.  If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

8. Privacy Policy changes

Any changes we make to this Privacy Policy in the future will be posted on this page. Therefore, we encourage you to check this page frequently from time to time.

9. Contact information

If you have any questions about your personal data or this Privacy Policy, or if you would like to file a complaint about how we process your personal data, please contact us by email at privacy@printful.com, or by using the contact details below:

Users outside of the European Economic Area:

Printful Inc.
Attn: Data Protection Officer
Address: 11025 Westlake Dr
Charlotte, NC 28273
United States

Users of the European Economic Area:

AS “Printful Latvia”
Attn: Data Protection Officer
Address: Ojara Vaciesa iela, 6B,
Riga, LV-1004,
Latvia

The version of this Policy is effective October 8, 2021.

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