Erno Laszlo Privacy Policy 

Erno Laszlo takes your privacy seriously. 
The following principles guide our treatment of your personal information: 
 

  1. We value the trust that you place in Erno Laszlo when sharing your personal information with us. 
  2. We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it. 
  3. We endeavor to work with you to address your concerns about how we use your personal information. 
  4. We strive to take steps designed to secure your personal information and reduce the risk that it will be misused. 

Overview of Scope 

We at Erno Laszlo, Inc. (“Erno Laszlo”) respect your privacy and recognize the need to protect and appropriately manage the personal information you share with us (the phrase “personal information” means any information by which you can be identified, such as your name, telephone number, payment information, or postal or email address as well as any other data determined to be personal information under any and all applicable U.S. privacy laws). This Erno Laszlo Privacy Policy (“Privacy Policy”) describes the types of personal information we may collect on the website located at www.ErnoLaszlo.com (the “Site” or “ErnoLaszlo.com”), how we use the information, with whom we may share it, and the choices you have regarding our use of the information.  
 
BY ACCESSING AND/OR USING THE SITE, YOU EXPRESSLY AGREE TO THE COLLECTION, USE, DISCLOSURE, RETENTION, AND DESTRUCTION OF YOUR PERSONAL INFORMATION SUBMITTED TO US IN ACCORDANCE WITH THIS PRIVACY POLICY. 
 
Please note, if you are a resident of a European Union Member State, you are not permitted to access and/or use the Site. 

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by emailing us at: advisor@ernolaszlo.com; calling us at: (888) 352-7956; or sending us U.S. mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. 

State Specific Privacy Rights 

Residents of the States of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia, businesses organized under the laws of the State of California, as well as California-based employees of, and California residents who submit job applicants to, Erno Laszlo (collectively, “Covered Users”), are afforded additional rights pursuant to applicable state law. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights as a Covered User. 

 

  1. Your California Privacy Rights

Shine the Light. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: advisor@ernolaszlo.com; call us at: (888) 352-7956; or send us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: advisor@ernolaszlo.com; call us at: (888) 352-7956; or send us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act of 2018 (“CCPA”). In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CCPA as a California State resident.

The California Privacy Rights Act (“CPRA”). In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CPRA, including the right to correct personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to know how long we retain your sensitive and non-sensitive personal information, the right to know what sensitive personal information about you we have collected, whether your sensitive personal information was shared with third-parties in the preceding year and, if so, what categories of sensitive personal information were shared, as well as the categories of third parties with whom we shared that sensitive personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CPRA as a California State resident.

Browser “Do Not Track” Signals. Most browsers contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want her/his personal information and online behavior to be tracked and used, for example, for interest-based advertising. As required by California Online Privacy Protection Act (“CalOPPA”), we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a Site user has activated the “do-not-track” setting on her/his browser; provided, however, that you may have certain rights with respect to the use of automated technologies to deliver targeted advertising to you, as well as to create profiles about you using your personal information. 

 

  1. Your Colorado Privacy Rights 

If you are a resident of the State of Colorado, certain privacy-related rights may apply to you in accordance with the Colorado Privacy Act (“CPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CPA as a Colorado State resident. 

 

  1. Your Connecticut Privacy Rights 

If you are a resident of the State of Connecticut, certain privacy-related rights may apply to you in accordance with the Connecticut Data Privacy Act (“CDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CDPA as a Connecticut State resident. 

 

  1. Your Delaware Privacy Rights 

If you are a resident of the State of Delaware, certain privacy-related rights may apply to you in accordance with the Delaware Personal Data Privacy Act (“DPDA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the DPDA as a Delaware State resident. 

 

  1. Your Florida Privacy Rights 

If you are a resident of the State of Florida, certain privacy-related rights may apply to you in accordance with the Florida Digital Bill of Rights ("FDBR"), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the FDBR as a Florida State resident. 

 

  1. Your Indiana Privacy Rights 

If you are a resident of the State of Indiana, certain privacy-related rights may apply to you in accordance with the Indiana Data Privacy Law (“IDPL”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the IDPL as an Indiana State resident. 

 

  1. Your Iowa Privacy Rights 

If you are a resident of the State of Iowa, certain privacy-related rights may apply to you in accordance with the Iowa Act Relating to Consumer Data Protection (“ICDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the ICDPA as an Iowa State resident. 

 

  1. Your Montana Privacy Rights 

If you are a resident of the State of Montana, certain privacy-related rights may apply to you in accordance with the Montana Consumer Data Privacy Act (“MDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the MDPA as a Montana State resident. 

 

  1. Your Nevada Privacy Rights

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any “covered information” that the website operators have collected about Nevada State residents to any third party data broker(s). Covered information includes a consumer’s name, postal and email address, telephone number and Social Security Number, and includes the Information described below in the “Personal Information Collected” section.

If you are a Nevada State resident and you wish to exercise your right to request that we to stop the sale of your Information to third party data brokers, please e-mail us at: advisor@ernolaszlo.com; call us at: (888) 352-7956; or send us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the website that you visited and the email address you registered with. Please allow thirty (30) days for a response. 

 

  1. Your New Jersey Privacy Rights 

If you are a resident of the State of New Jersey, certain privacy-related rights may apply to you in accordance with the New Jersey Data Privacy Act (“NJDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the NJDPA as a New Jersey State resident. 

 

  1. Your Oregon Privacy Rights 

If you are a resident of the State of Oregon, certain privacy-related rights may apply to you in accordance with the Oregon Consumer Privacy Act (“OCPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the OCPA as an Oregon State resident. 

 

  1. Your Tennessee Privacy Rights 

If you are a resident of the State of Tennessee, certain privacy-related rights may apply to you in accordance with the Tennessee Information Protection Act (“TIPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the TIPA as a Tennessee State resident. 

 

  1. Your Texas Privacy Rights 

If you are a resident of the State of Texas, certain privacy-related rights may apply to you in accordance with the Texas Data Privacy and Security Act (“TDPSA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the TDPSA as a Texas State resident. 

 

  1. Your Virginia Privacy Rights 

If you are a resident of the State of Virginia, certain privacy-related rights may apply to you in accordance with the Virginia Consumer Data Protection Act (“VCDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the VCDPA as a Virginia State resident. 

 

  1. Your Utah Privacy Rights 

If you are a resident of the State of Utah, certain privacy-related rights may apply to you in accordance with the Utah Consumer Privacy Act (“UCPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the UCPA as a Utah State resident. 

 

Privacy Policy Quick Links 

Below are links to key sections of our Privacy Policy: 

 

Information We Collect 

Please see our Privacy Provisions for Covered Users below for additional details regarding the categories of personal information collected.  

Information Collected Directly. When you visit ErnoLaszlo.com, you may provide information such as your name, shipping and billing address, email address, telephone number, payment card information, age, skin characteristics, behaviors, and conditions, lifestyle, climate of where you live, how much water you drink and how often you consume caffeine and alcohol, and other information, such as product preferences. You may also provide contact information about your friends and family, for example if you purchase an eGift Card for a friend. We also maintain a record of your online product purchases. You may choose that you do not want to provide some or all of this information. Please note that, if you choose not to provide the information we request, you may be unable to purchase products, or access certain services, offers and content on our Site. For purposes of this Privacy Policy, payment card information shall be considered “Sensitive Information.” 

Cookies. In addition, when you visit our Site, we collect certain information by automated means, such as “cookies.” The information we collect in this manner may include IP address, browser type, operating system, referring URLs or Internet domain addresses from which you visit us, information on actions taken on the Site, and dates and times of your visits to the Site. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. To find out more about cookies, please visit www.cookiecentral.com. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of the Site’s features.  

IP Addresses/Browser Type. We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site and associated offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site and associated offerings. 

Interactive Services. The Site may provide you with the opportunity to post content publicly in various comments sections and other interactive features (collectively, “Community Forums”). You may choose to post or disseminate content on a Community Forum (or otherwise directly to Erno Laszlo), such as product reviews, product tips and tricks, photographs, writings, pictures, data, questions, comments, or suggestions (collectively, “User Content”). Where you submit User Content to Erno Laszlo, you irrevocably grant to Erno Laszlo the worldwide right and license to use, reuse and publish that User Content, in any and all forms of marketing and promotional material including, without limitation, print advertisements ("ads"), online ads, ads and other promotions appearing on Erno Laszlo’s social media pages and other social media websites, email ads, television ads, radio ads, interactive media, as well as printed extracts and reproductions of any portion thereof (collectively, “Ads”), and for any and all other uses as deemed appropriate by Erno Laszlo in its sole discretion. You understand and agree that: (a) the User Content, in whole or in part, may be edited and/or dramatized, and that any part of the User Content may be used without compensation to you; and (b) no ad or other material incorporating or making reference to the User Content need be submitted to you for approval and Erno Laszlo shall be without liability to you whatsoever for any distortion or illusionary effect resulting from the publication of the User Content. Please use caution and common sense when posting User Content. Any User Content and/or other information that you post to the Site using any such Community Forums or functionality, including any personal information that you choose to post, will be shared with other Site users and can be read by other users of the Site and by the public on the Internet. When you post User Content, your chosen display name is displayed along with your post. By posting User Content, you consent to allow other users to access what you have posted and to see your public profile. The contents of your User Content postings, and your linked profile, will be freely available to the public on the Internet. To request removal of your personal information and/or User Content from our Community Forums, please contact us at advisor@ernolaszlo.com. In some cases, subject to applicable law, we may not be able to remove your personal information and/or User Content, in which case we will let you know if we are unable to do so and why. For more information about such Community Forums and related functionality, please carefully review our Terms and Conditions.  

Social Media Websites. We may also provide social media features on the Site that enable you to share Erno Laszlo information with your social networks/social media websites (such as Facebook) (collectively, “Social Media Websites”) and to interact with Erno Laszlo on various Social Media Websites. Your use of these features/Social Media Websites may result in the collection or sharing of information about you. We consider information collected from or shared through any such Social Media Websites/features as public information because the third party Social Media Websites make it publicly available. We encourage you to review the privacy policies and settings on the social media sites with which you interact to help you understand those sites’ privacy practices. If you access the Site through Social Media Websites, we may access and store information through an interface provided by the applicable Social Media Website(s).  

We collect this information in accordance with the applicable Social Media Websites’ privacy policies and terms of use/terms of service. We are not responsible for the personal data that you choose to submit on, or link to, any Social Media Websites. The Social Media Websites operate independently from Erno Laszlo, and we are not responsible for the Social Media Websites’ interfaces and/or privacy or security practices. We encourage you to review the privacy policies and settings on the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of Social Media Websites that you use, please refer to their privacy notices or policies. 

 

How We Use the Information We Collect 

Please see our Privacy Provisions for Covered Users below for details regarding our use of personal information. We use the information we collect on ErnoLaszlo.com to: 

  • Process, validate, confirm, verify and track your product orders; 
  • Subscribe you (if you so choose) for email promotions and marketing from Erno Laszlo; 
  • Register you for membership at ErnoLaszlo.com (if you so choose) so that we can provide you with additional information regarding products, promotions and services that may be of interest to you; 
  • Facilitate participation in our eGift Card Program and The Institue Loyalty Program. Without limiting the foregoing, Erno Laszlo will communicate with members (“Members”) of The Institue Loyalty Program (the “Institute”) via mail, email, SMS and other channels, including communications regarding special Member promotions, offers and more. Erno Laszlo will also use these channels to communicate the Member’s Institute tier status, notify Member of eligibility for Institute benefits, communicate Institute changes and more. Please note that even if you opt out of receiving marketing or promotional communications, Erno Laszlo may continue to send you non-marketing or non-promotional Institute emails, such as those about your Institute account or our ongoing business relations; 
  • Contact you about your orders, including by telephone; 
  • Process payment card transactions; 
  • Maintain a record of the purchases you make on the Site; 
  • Create and manage online accounts that users may establish on the Site; 
  • Communicate with you about Erno Laszlo and our products, services, offers, events and promotions; 
  • Provide you with customized service and use of our Site (for example, we may suggest products or beauty regimens that would be of particular interest to you); 
  • Target relevant marketing messages from Erno Laszlo to you (on the Site and via email); 
  • Respond to questions and comments; 
  • Operate, evaluate and improve our business (including developing new products and services; analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions); 
  • Perform data analyses, including but not limited to analyzing trends and statistics regarding your use of the Site and the sites from which you visited us (referrers); and 
  • Comply with applicable legal requirements and our policies. 

By submitting your personal information by and through the Site, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations. 

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Erno Laszlo, including SMS text messages, delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide consent under the TCPA in order to obtain access to the Site Offerings, and your consent simply allows Erno Laszlo to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (i) have your telephone number reassigned to another person or entity; (ii) give up your telephone number so that it is no longer used by you; (iii) port your telephone number to a landline or vice versa; or (iv) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Erno Laszlo of the Phone Number Change via e-mail at: advisor@ernolaszlo.com, or by using one of the methods set forth in the “Contact Us” section below. 

By collecting information through cookies and other automated means on our Site, we learn how to best tailor the Site to our visitors. We use cookies to uniquely identify the electronic shopping basket you may create on the Site and enable users to retrieve shopping baskets they previously created. We also may use cookies to identify and authenticate users, tailor our products and services to suit your personal interests, process your order, and analyze your visiting patterns on our Site and other trends and statistics regarding your use of our Site and the sites from which you visited us (referrers). We do not use cookies to track your Internet browsing activities before or after you visit the Site. 

We may also combine information you give us on the Site with information you provide us in stores or through our catalogs. In addition, we may combine the information you give us at the Site with publicly available information and information we receive from third parties. We use that combined information to enhance and personalize your shopping experience with us, to communicate with you about our products and events that may be of interest to you, and for other promotional purposes. Any personal information that is aggregated with non-personal information will be treated as personally identifiable information under this Privacy Policy until it can no longer be used to identify you. 

 

Behavioral Tracking/Do-Not-Track 

Certain third parties, such as Google Inc. (“Google®”), including through Google's® Ads® service, Microsoft®, including through its Microsoft Ads® service, Facebook®, including through its Meta Ads® service, place cookies or other tracking technology on the Site that track users’ activities after they leave the Site

Google® may collect some or all of the following information by and through the Google® tracking technology: (a) email address; (b) telephone number; (c) first and last name; (d) zip code and country where the user is located; (e) device type (desktop, mobile, tablet, etc.); (f) device brand and model; (g) device operating system and browser type; (h) screen resolution; (i) referring website, search engine or social media platform; (i) Site pages visited; (k) time that the Site is accessed and spent on each page; (l) navigation path through the Site; (m) actions taken on the Site (clicks, downloads, form submissions, purchases, registrations, etc.); and (n) exit pages (collectively, “Google® Data”).  Google® shares the Google® Data with us. 

We may combine Google® Data with your personal information, and we and/or Google® may use Google® Data to serve you targeted ads after you leave the Site.  Google’s® ability to use and share the Google® Data and other information collected about your visits to (and use of) the Site is restricted by the Google® Privacy Policy, available here. Users may opt out of Google's® use of cookies by visiting the Google advertising opt-out pages, including here: https://tools.google.com/dlpage/gaoptout/ and here: https://support.google.com/adsense/answer/142293?hl=en.  

We may also use a web analysis tool called Meta Pixel®, as made available by Facebook, Inc. (“Facebook®”).  Facebook® may collect some or all of the following information by and through the Meta Pixel® tracking technology: (a) gender; (b) date of birth; (c) traffic data from Facebook® users who visit the Site; (d) demographic information of Facebook® users who visit the Site; (e) device type (desktop, mobile, tablet, etc.); (f) device brand and model; (g) device operating system and browser type; (h) screen resolution; (i) referring website, search engine or social media platform; (i) Site pages visited; (k) time that the Site is accessed and spent on each page; (l) navigation path through the Site; (m) actions taken on the Site (clicks, downloads, form submissions, purchases, registrations, etc.); and (n) exit pages (collectively, “Meta Pixel® Data”).  Facebook® shares the Meta Pixel® Data with us. 

We may combine the Meta Pixel® Data with your personal information, and we and/or Facebook® may use that Meta Pixel® Data to serve you targeted ads after you leave the Site.  Information pertaining to Facebook’s® use of Facebook’s® Meta Pixel® Data and Facebook’s® privacy policy can be found here. Users may opt out of Facebook's® use of cookies by visiting the settings of their respective Facebook® accounts and making the appropriate adjustments. 

We may also use a web analysis tool called Microsoft Ads®, as made available by Microsoft, Inc. (“Microsoft®”).  Microsoft® may collect some or all of the following information by and through the Microsoft Ads® tracking technology: (a) email address; (b) telephone number; (c) first and last name; (d) zip code and country where the user is located; (e) device type (desktop, mobile, tablet, etc.); (f) device brand and model; (g) device operating system and browser type; (h) screen resolution; (i) referring website, search engine or social media platform; (i) Site pages visited; (k) time that the Site is accessed and spent on each page; (l) navigation path through the Site; (m) actions taken on the Site (clicks, downloads, form submissions, purchases, registrations, etc.); and (n) exit pages (collectively, “Microsoft® Data”).  Microsoft® shares the Microsoft® Data with us. 

We may combine Microsoft® Data with your personal information, and we and/or Microsoft® may use that Microsoft® Data to serve you targeted ads after you leave the Site.  Users may opt out of Microsoft's® use of cookies by visiting the Microsoft® advertising opt-out pages, including here: https://account.microsoft.com/privacy/ad-settings

In addition, users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance. Further, visitors may be able to disable such tracking by utilizing the “Do-Not-Track” or similar options within most major Internet browsers; provided, however, that the effectiveness of the Do-Not-Track options depends on the policies of the applicable third party, such as Google®. 

 

Live Chat/Chat Bots 

Erno Laszlo utilizes third-party service providers to provide live chat and automated chat services (collectively, “Chat”) to Users on the Site.  These third party Chat service providers, including Gorgias Inc., may collect and store the content of these Chat conversations, and will share same with Erno Laszlo; provided, however, that these third-party Chat service providers are not permitted to utilize User personal information collected via Chat conversations for any purpose other than: (a) to provide the Chat services on the Site; and (b) to assist Erno Laszlo with the customer service functionality associated with the Chat services. Please see our Privacy Provisions for Covered Users below for details regarding our use and sharing of personal information.  

 

Information We Share 

Please see our Privacy Provisions for Covered Users below for details regarding our sharing of personal information. We may share personal information with service providers that perform services on our behalf (such as credit card processing, shipping, data management or promotional services). We also may provide your personal information (other than Sensitive Information) to our business partners, representatives, affiliates, or third parties to enable such persons or entities to communicate with you regarding Erno Laszlo products and services, offers, events and promotions that may be of interest to you. 

We share your information with third parties in order to facilitate your participation in our eGift Card Program and  The Institue Loyalty Program. Third parties with whom we share your personal information have agreed to be bound to maintain and use it securely and only in accordance with this Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third-party service providers. 

We reserve the right to release current or past personal information, including Sensitive Information: (a) in the event that we believe that the Site is being or have been used to commit unlawful acts; (b) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; (c) if we are sold, merge with a third-party or are acquired by a third-party (collectively, “M&A Transactions”) (including where we share your personal information, including Sensitive Information, in connection with the due diligence process associated with a potential M&A Transaction); or (d) if we are the subject of bankruptcy proceedings; provided, however, that if Erno Laszlo is involved in a bankruptcy proceeding or an M&A Transaction, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information. 

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be required by applicable law, including sharing your e-mail address with third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and other e-mail marketing laws. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission. By submitting your personal information to us, you expressly consent to our sharing your personal information, as set forth above.  

 

Opting-Out 

Please see our Privacy Provisions for Covered Users below for instructions on how California Residents can opt-out of the sale of their personal information to third parties. 

To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: advisor@ernolaszlo.com. 

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for our products, services, merchandise and other offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving those messages from us, you must cease requesting and/or utilizing our products, services, merchandise and other offerings and/or cease submitting inquiries to us, as applicable. 

 

Identifying, Deleting or Correcting Personal Information 

Please see our Privacy Provisions for Covered Users below for instructions on how California Residents can access and/or delete personal information that we have collected. At your request, we will inform you of what personal information we have on file for you. In addition, at your request, we will delete and/or modify the personal information that you have provided to us, or that we have collected. You may do so by making the change on our member information page, by e-mailing us at: advisor@ernolaszlo.com, or contacting us as specified below. We ask individuals to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or those that would be extremely impractical (for instance, requests concerning information residing on backup tapes). 

Please be advised that deleting your personal information will terminate your access to some or all of the features of the Site. 

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. In addition, this deletion will not change or delete personal information which may have already been shared with third parties, as provided above in this Privacy Policy. Subject to applicable law (including state laws that apply to Covered Users), you will need to contact the third parties directly to change your preferences regarding their use of your personal information. If you are a California State resident, we will contact third parties to request deletion of your personal information on your behalf. 

 

Children's Privacy 

Please see our Privacy Provisions for Covered Users below for more details regarding the personal information of minors. ErnoLaszlo.com is not intended for access or use by individuals under 16 years of age. We do not knowingly collect personal information regarding any individual under 16 years of age. Children aged 16 and 17 are allowed to visit the Site only with the express consent of their parents or legal guardians, but are not permitted to make purchases or provide personal information on the Site. We encourage parents to talk to their children about their use of the Internet and the information they disclose online. If you believe a child under 18 years of age may have provided personal information to us through the Site without consent, please contact us at advisor@ernolaszlo.com, and we will use reasonable efforts to delete it from the Site and our files. 

 

How We Protect Personal Information 

We endeavor to safeguard and protect our users’ personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts users to enter sensitive information (such as medical information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, social security number and credit card information), and when we store and transmit such Sensitive Information, that information is encrypted with advanced TLS (Transport Layer Security). 

Access to your personal information is strictly limited, and we take reasonable security measures to ensure that your personal information is not accessible to the public. All of our users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need user personal information to perform a specific job are granted access to user personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store user personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. 

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site or otherwise via the Internet or wireless networks, is done at your own risk. 

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures. 

 

Links to other Websites 

This Site may contain links or references to other websites (including Social Media Websites) for your convenience and information. This Privacy Policy does not apply to such linked websites. We are not responsible for the linked sites’ content, any use of the sites, or the privacy practices of the sites. We encourage you to read the privacy policy of every website you visit. 

 

International Data Transfers 

This is a U.S. website governed by applicable U.S. law. The data protection laws in the U.S. may differ from those of the country in which you are located. When you provide personal information on this Site, you consent to the collection, transfer and processing of your personal information outside of the country in which you are located, including in the U.S., and in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in your country, and while in the United States personal information may be subject to lawful access requests from governments, courts, or law enforcement in the U.S. according to laws of the U.S. 

 

Updates to this Privacy Policy 

This Privacy Policy may be updated periodically and, in some instances, without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Privacy Policy and indicate at the top of the policy when it was most recently updated. If we make a material change to this Policy, we will inform Site users and provide them an opportunity to review the new privacy policy and provide their consent to the new terms outlined in such an updated privacy policy. Where any update expands our ability to use your personal information, we will only use your information in this expanded manner where you opt-in to such use. 

 

Resolving a Privacy Dispute 

If you have a complaint about this Privacy Policy or our privacy practices, we will work with you in an attempt to resolve your complaint under the arbitration procedures described in the Dispute Resolution section of the Site’s Terms and Conditions. 

 

How to Contact Us 

If you have any questions, comments, requests or concerns related to this Privacy Policy or the information practices of this Site, or if you would like us to update information we have about you or your preferences, please contact us at:

Erno Laszlo, Inc.
Corporate Headquarters
151 West 19th Street, 6th Floor
New York, NY 10011
Tel: (212) 373-4700
Email: advisor@ernolaszlo.com

 

Privacy Provisions for Covered Users 

These Privacy Provisions for Covered Users (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to Covered Users who are residents of the states of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, New Jersey, Oregon, Texas, Tennessee, Virginia and Utah . We adopt these Provisions in compliance with the CCPA, CPRA, CPA, CDPA, DPDA, FDBR, IDPL, ICDPA, MDPA, NJDPA, OCPA, TIPA, TDPSA, VCDPA and UCPA (collectively, “Applicable State Laws”). Any terms defined in Applicable State Laws have the same meaning when used in these Provisions. Users with disabilities who wish to access these Provisions in an alternative format can contact us by emailing us at: advisor@ernolaszlo.com; calling us at: (888) 352-7956; or sending us U.S. mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. 

 

Categories of Information We Collect: 
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Covered User or device (“personal information”). In particular, we have collected the following categories of personal information from Covered Users within the last twelve (12) months: 

Category 

Examples 

Collected 

A. Identifiers. 

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers. 

YES 

B. Personal information categories listed in Applicable State Laws. 

A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. 

YES 

C. Protected classification characteristics under Applicable State Laws or federal law. 

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). 

YES 

D. Commercial information. 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

YES 

E. Biometric information. 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. 

YES 

F. Internet or other similar network activity. 

Browsing history, search history, information on a Covered User's interaction with a website, application or advertisement. 

YES 

K. Inferences drawn from other personal information. 

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

YES 

L. Sensitive Personal Information. 

A Social Security number, driver’s license number, state identification card number, or passport number. Account log-in information, financial account, or debit or credit card number used in combination with any required security code, access code, password, or log-in credentials necessary to access an account. Precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s U.S. mail, electronic mail, or text messages unless the business is the intended recipient, and a consumer’s genetic data.  

YES 

 

Personal information does not include: 

  • Publicly available information from government records. 
  • De-identified or aggregated Covered User information. 
  • Information excluded from the scope of Applicable State Laws, such as: 
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and 
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. 

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis): 

  • Directly from our Covered Users. For example, from online registration forms that our Covered Users submit to us in connection with the products and/or services that we offer by and through the Site. (Category A, B, C, D, E, F, K and L) 
  • Indirectly from our Covered Users. For example, through information we collect from our Covered Users in the course of providing our products and/or services to them. (Category A, B, C, D, E, F, K and L) 
  • Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners. (Category F) 
  • When our Covered Users interact with us on our social media accounts, including commenting on and/or liking our posts. (Category A and F) 
  • From third-parties that interact with us in connection with the products and/or services that we offer to our Covered Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from Covered User lists, analyzing data and providing marketing analysis. (Category A, B, C, D, E, F, K and L) 

 

Notice of Financial Incentive 

The Institute, Erno Laszlo’s loyalty program, is offered by Erno Laszlo to customers that make purchases on the Site, as well as to potential customers. Erno Laszlo offers certain perks and privileges to users who join the Institute loyalty program ("Members”).  As Members spend money on Erno Laszlo products, they earn points for each eligible dollar spent (“Points”), and attain various tiers of Institute membership based on Points earned (“Tiers”). Points can be exchanged for eligible Erno Laszlo products and/or services. 

In order to become a Member of the Institute, you must submit the following information on the registration form made available on the Institute page of the Site: (a) first name; (b) last name; and (c) email address.  Upon registering for an account, you may also add your date of birth in exchange for additional Points.  Erno Laszlo uses this personal information to improve its products, services and customer experiences.  Institute Membership is optional.  Once you obtain a Membership, you may cancel your Membership at any time by emailing us at advisor@ernolaszlo.com.  Members may continue to use their Points after canceling their Memberships. 

The value of the consumer personal information provided in order to become a Member of the Institute is based upon our reasonable, but sole, determination of the estimated value of such information.  We calculate this value by considering, without limitation, estimates regarding anticipated revenue that we may generate from such information, anticipated expenses which may be incurred in the collection, storage, use and sharing of such information in the operation of our business, and other relevant factors, as permitted by the CCPA (“Valuation Criteria”).  Using the Valuation Criteria, we estimate the value of personal information we request from Institute Members, in part, by comparing the amount spent by Institute Members to similarly situated customers who do not participate in the Institute over a twelve (12) month period. 

Erno Laszlo also offers users a discount that can be applied to future purchases on the Site where users join Erno Laszlo’s SMS Program.  In order to users join Erno Laszlo’s SMS Program, you must submit your mobile telephone number.  Erno Laszlo uses this personal information to contact you regarding your use of the Site and related offerings.  Joining the SMS Program is optional.  Once you join the SMS Program, you may opt out at any time by texting “STOP” to 1 (844) 298-0620, or by sending an email to advisor@ernolaszlo.com.  Members may continue to use their discount after opting out of the SMS Program. 

The value of the consumer personal information provided in order to join the SMS Program is based upon our reasonable, but sole, determination of the estimated value of such information.  We calculate this value by considering, without limitation, the relevant Valuation Criteria.  Using the Valuation Criteria, we estimate the value of personal information we request to join the SMS Program by multiplying the discount by the average purchase price of Erno Laszlo products. 

Retention of Personal Information and Sensitive Personal Information 

We retain all categories of your personal information and Sensitive Personal Information that we collect for the maximum period permitted by applicable law. We may also use certain criteria to determine whether and when to delete certain categories of collected personal and sensitive personal information including: 

  • Date of collection. 
  • Frequency of consumer interaction with us. 
  • Last interaction the consumer had with us. 
  • Whether the purpose of collection has been completed. 

 

Use of Personal Information 
We may use or disclose the personal information that we collect for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis): 

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your purchase of products and/or services, we will use that information to process your order. (Category A, B, C, D, E, K and L) 
  • To provide your information to third parties that provide you with e-mail, direct mail and telemarketing messages concerning certain third-party products and/or services that they believe may be of interest to you. (Categories A, B, C, D, E and F)  
  • To provide you with information, products or services that you request from us. (Category A, B, C, D, E, F, K and L) 
  • To create, maintain, customize and secure your account with us. (Category A, B, C, D, E, F, K and L) 
  • To provide you with e-mail, direct mail and telemarketing messages concerning certain Erno Laszlo® products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Category A, B, C, D, E, F, K and L) 
  • To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, C, D, E, F and K) 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms of Use. (Category A, B, C, D, E, F, K and L) 
  • To improve the Site and better present its contents to you. (Category A, B, C, D, E, F, K and L) 
  • For customer service purposes and to respond to inquiries from you. (Category A, B, C, D, E, K and L) 
  • For testing, research, analysis and product development. (Category A, B, C, D, E, F, K and L) 
  • As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, C, D, E, F, K and L) 
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, D, E, F, K and L) 
  • As described to you when collecting your personal information or as otherwise set forth in Applicable State Laws. (Category A, B, C, D, E, F, K and L) 
  • 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 information held by us is among the assets transferred. (Category A, B, C, D, E, F, K and L 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice. 

 

Sharing Personal Information 

Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information from Categories A, B, C, D, E, F, K and L: (a) with/to third parties for marketing purposes, but not Sensitive Personal Information; and (b) for the other business purposes set forth above. 

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from Covered Users that we actually know are less than sixteen (16) years of age and we do not share or sell the personal information of Covered Users that we actually know are less than sixteen (16) years of age. Without limiting the foregoing, we have not shared or sold the personal information of Covered Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months. 

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: 
Category A     Identifiers. 
Category B     Personal information categories listed in Applicable State Laws. 
Category C     Protected classification characteristics under Applicable State Laws or federal law. 
Category D     Commercial information. 
Category E     Biometric information. 
Category F     Internet or other similar network activity. 
Category K     Inferences drawn from other personal information. 
Category L     Sensitive Personal Information. 

We disclose your personal information for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis): 

  • Our affiliates. (Category A, B, C, D, E, F, K and L) 
  • Service providers. (Category A, B, C, D, E, F, K and L) 
  • Third parties who purchase and/or license your personal information (but not Sensitive Personal Information) for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers (Category A, B, C, D, E, F and K). If a third party purchaser of your personal information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales, unless the right to resell it was secured by us at the point of collection. 
  • Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Category A, B, C, D, E, F, K and L) 

In the preceding twelve (12) months, we have sold the following categories of personal information to third parties: 
Category A     Identifiers. 
Category B     California Customer Records personal information categories. 
Category C     Protected classification characteristics under California or federal law. 
Category D     Commercial information. 
Category E     Biometric information 
Category F     Internet or other similar network activity. 
Category K     Inferences drawn from other personal information 

In the preceding twelve (12) months, we have sold the above referenced categories of personal information to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site. 

 

Your Rights and Choices 
Applicable State Laws provide Covered Users (residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia) with specific rights regarding their personal information. This section describes your rights under Applicable State Laws and explains how to exercise those rights. 

 

Opt-Out from the Sale of Your Personal Information 
You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable Covered User request to us by either: 

  • Clicking here 
  • Calling us at: (888) 352-7956 
  • Emailing us at: advisor@ernolaszlo.com; or 
  • Sending us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. 

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request. 

 

Opt-Out from the Sharing of Your Personal Information 

You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable Covered User request to us by either: 

  • Clicking here 
  • Calling us at: (888) 352-7956; 
  • Emailing us at: advisor@ernolaszlo.com; or 
  • Sending us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. 

 

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request. Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease sharing your Personal Information with third parties. 

 

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information 

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (Personal information categories established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws), Category D (Commercial Information), Category E (Biometric Information) and Category L (Sensitive Personal Information) to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Erno Laszlo, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Erno Laszlo; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned by, manufactured by, manufactured for, or controlled by, Erno Laszlo, and to improve, upgrade, or enhance the service or device that is owned by, manufactured by, manufactured for, or controlled by, Erno Laszlo. 

You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (Personal information categories established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws), Category D (Commercial Information), Category E (Biometric Information) and Category L (Sensitive Personal Information). 

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable Covered User request to us by either: 

  • Clicking here 
  • Calling us at: (888) 352-7956; 
  • Emailing us at: advisor@ernolaszlo.com; or 
  • Sending us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. 

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.  Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease using your Sensitive Personal Information/sharing your Sensitive Personal Information with third parties (and direct our service providers and contractors to do the same). 

Access to Specific Information and Data Portability Rights 
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable Covered User request, we will disclose to you: 

  • The categories of personal information we collected about you. 
  • The categories of sources for the personal information we collected about you. 
  • Our business or commercial purpose for collecting or selling that personal information. 
  • The categories of third parties with whom we have shared that personal information. 
  • The specific pieces of personal information we collected about you (also called a data portability request). 
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

 

Deletion Request Rights 
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Covered User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you. 
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities. 
  3. Debug products to identify and repair errors that impair existing intended functionality. 
  4. Exercise free speech rights, ensure the right of another Covered User to exercise her/his free speech rights or exercise another right provided for by law. 
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). 
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, but only if you previously provided informed consent. 
  7. Enable solely internal uses that are reasonably aligned with Covered User expectations based on your relationship with us. 
  8. Comply with a legal obligation. 
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

 

                  Right to Request Correction of Inaccurate Personal or Sensitive Personal Information 

                  You have the right to request correction of inaccurate personal and/or sensitive personal information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate.  Where we correct inaccurate personal and/or sensitive personal information, we shall instruct all service providers and/or contractors that maintain such personal and/or sensitive personal information in the course of providing services to us to make the necessary corrections in their respective systems. 

                   

                  Exercising Access, Data Portability, Right to Correct and Deletion Rights 
                  To exercise your access, data portability, right to correct and/or deletion rights described above, please submit a verifiable Covered User request to us by either: 

                  • Clicking here 
                  • Calling us at: (888) 352-7956 
                  • Emailing us at: advisor@ernolaszlo.com; or 
                  • Sending us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. 

                  You may only make a verifiable Covered User request for access or data portability twice within a 12-month period. The verifiable Covered User request must: 

                  • Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative. 
                  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

                  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable Covered User request does not require that you create an account with us. We will only use personal information provided in a verifiable Covered User request to verify the requestor's identity or authority to make the request. 

                  Response Timing and Format; Appealing A Denial 
                  We endeavor to respond to all verifiable Covered User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

                  We do not charge a fee to process or respond to your verifiable Covered User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

                  If we deny any Covered User access/right to know, data portability, right to correct and/or deletion rights request, you may submit an appeal of our decision within thirty (30) days of your receipt of our notice of denial by e-mailing us at: advisor@ernolaszlo.com; or sending us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011. 

                   

                  Right to Opt-Out of Profiling  

                  You have the right to opt-out from any Profiling that may be conducted by Erno Laszlo.  For purposes of these Provisions, "Profiling" means any form of automated processing performed on your personal data to evaluate, analyze or predict personal aspects related to you or your economic situation, health, personal preferences, interests, reliability, behavior, location or movements. You have the right to opt-out of our Profiling you. To exercise your right to opt-out of our Profiling you, please submit a verifiable Covered User request to us by either: 

                  • Clicking here
                  • Emailing us at: advisor@ernolaszlo.com; or
                  • Calling us at: (888) 352-7956;
                  • Sending us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011.

                  We endeavor to act on all Profiling opt-out requests as soon as practicable, but in all cases within forty-five (45) days of the receipt of your request. 

                   

                  Right to Opt-Out of Targeted Advertising 

                  You have the right to opt-out from Targeted Advertising conducted by Erno Laszlo.  For purposes of these Provisions, "Targeted Advertising” means displaying advertisements to you where the advertisements are selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests.  You have the right to opt-out from Targeted Advertising. To exercise your right to opt-out of our Targeted Advertising, please submit a verifiable Covered User request to us by either: 

                  • Clicking here
                  • Emailing us at: advisor@ernolaszlo.com; or
                  • Calling us at: (888) 352-7956;
                  • Sending us U.S. Mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011.

                  We endeavor to act on all Targeted Advertising opt-out requests as soon as practicable, but in all cases within forty-five (45) days of the receipt of your request. 

                   

                  Authorized Agents 

                  Covered Users may permit an Authorized Agent to exercise any rights granted under Applicable State Laws as set forth above.   In order to utilize an Authorized Agent, you must provide the Authorized Agent with written permission from you to act on your behalf for these purposes.  When you use an Authorized Agent to submit a request to delete, request to correct or a request to know, we may require the Authorized Agent to provide proof that you gave the agent signed permission to submit the subject request.  We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the Authorized Agent permission to submit the request.   

                  For California residents, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Covered User request related to your personal information. 

                   

                  Non-Discrimination 
                  We will not discriminate against you for exercising any of your rights under Applicable State Laws. Unless permitted by Applicable State Laws, we will not: 

                  • Deny you goods or services; 
                  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; 
                  • Provide you a different level or quality of goods or services;  
                  • Retaliate against any employee, job applicant or independent contractor; and/or 
                  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

                  Changes to these Privacy Provisions 
                  We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage. 

                  Contact Information 
                  If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under Applicable State Laws, please do not hesitate to contact us by either: 

                  • Calling us at: (888) 352-7956 
                  • Emailing us at: advisor@ernolaszlo.com; or 
                  • Sending us U.S. mail to: ERNO LASZLO, Inc., Corporate Headquarters, 151 West 19th Street, 6th Floor, New York, NY 10011.