Erno Laszlo Privacy Policy

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.

Your Privacy Rights Last Updated: February 6, 2020

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, 129 W 29th Street, 7th Floor, New York, NY 10001.


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, 129 W 29th Street, 7th Floor, New York, NY 10001. 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, 129 W 29th Street, 7th Floor, New York, NY 10001. 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 California Residents” below for a more complete description of your rights under the CCPA as a California State resident.



Your Nevada Privacy Rights

If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third party data broker, 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, 129 W 29th Street, 7th Floor, New York, NY 10001.


Information We Collect

Please see our Provisions for California Residents 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.

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 Provisions for California Residents 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 our ME+ Rewards Loyalty Program;
  • 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 artificial voice calls, pre-recorded messages and/or calls (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 at 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® and AdWords®, place cookies or other tracking technology on the Site that track users’ activities after they leave the Site. Users may opt out of Google's® use of cookies by visiting the Google advertising opt-out page. 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® and AdWords®.


Information We Share

Please see our Provisions for California Residents 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 the 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 also share your information with stores to fulfill your orders.

We share your information with third parties in order to facilitate your participation in our eGift Card Program and our ME+ Rewards 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: (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; or (c) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Erno Laszlo is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, 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.


The Celebrate The Bold & The Brave (SKIN)CARE Package Giveaway Official Rules

NO PURCHASE NECESSARY TO ENTER OR WIN A CARE PACKAGE (AS DEFINED BELOW). A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. VOID WHERE PROHIBITED BY LAW.

Overview:

The Celebrate The Bold & The Brave (SKIN)CARE Package Giveaway ("Giveaway") is sponsored by Erno Laszlo, Inc. ("Sponsor"). The Giveaway is a promotional program intended to help recognize and reward individuals who are contributing to their communities in the effort to combat and mitigate the effects of the COVID-19 virus.

BY PARTICIPATING IN THE GIVEAWAY, YOU AGREE TO THESE CELEBRATE THE BOLD & THE BRAVE (SKIN)CARE PACKAGE GIVEAWAY OFFICIAL RULES ("RULES"). PLEASE REVIEW THE RULES CAREFULLY. IF YOU DO NOT AGREE TO THE RULES IN THEIR ENTIRETY, YOU ARE NOT PERMITTED TO ENTER THE GIVEAWAY. All federal, state and local laws, rules and regulations apply. By entering the Giveaway, you agree to the Giveaway winner selection and decisions of Sponsor, which are final and binding in all respects. By entering the Giveaway, you agree to receive telemarketing, e-mail and direct mail marketing messages from Sponsor and its corporate affiliates. Except as contemplated in these Rules, personal information collected in connection with the Giveaway will be used in accordance with the Erno Laszlo Privacy Policy ("Privacy Policy") featured on the Erno Laszlo website located at www.ernolaszlo.com (the "Site"). See the Privacy Policy for further details.

Giveaway Period:

The Giveaway begins at 12:00str a.m. Eastern Standard Time ("EST") on April 1, 2020 and ends on the earlier of: (a) 11:59:59 p.m. EST on September 1, 2020; or (b) the date that Sponsor awards two thousand seven hundred (2,700) Care Packages to Nominees (as defined below) ("Giveaway Period"). Sponsor is the official time-keeper for this Giveaway. Sponsor will stop accepting entries/Nominees upon the expiration of the Giveaway Period.

Eligibility:

This Giveaway is open to all residents of the fifty (50) United States and the District of Columbia (Washington D.C.) who are over the eighteen (18) years of age in their states of residence, excluding residents of Puerto Rico and where the Giveaway is otherwise prohibited by law. Employees, officers and directors of Sponsor, and its legal representatives, affiliates, parent, subsidiaries, advertising, promotional, fulfillment and marketing agencies and other contractors and their immediate families (and those living in their respective households), are not eligible to participate or claim a Care Package in the Giveaway.

How to Enter:

Individuals must enter the Giveaway by: (a) first, visiting Sponsor’s Giveaway page located at www.ernolaszlo.com/product-request and (b) then, nominating a potential Care Package winner by providing: (i) the nominee’s ("Nominee") name; (ii) the Nominee’s mailing address; (iii) the Nominee’s telephone number; and (iv) a brief description of why the Nominee is deserving of a Care Package, including the ways that the Nominee is contributing/has contributed to her/his community in connection with the effort to combat and mitigate the effects of the COVID-19 virus ("Giveaway Post"). You may only nominate each Nominee one (1) time during the Giveaway Period. Any entries submitted for the same Nominee in excess of the aforementioned limit will be discarded. Any attempt by any individual to obtain more than the permitted number of entries for a given Nominee by using multiple/different mobile devices, identities, registrations /or user-names, or any other method, will void all of that individual’s Nominees and that individual will be disqualified from participating in the Giveaway. Use of any automated system to participate in the Giveaway is prohibited and will result in disqualification. Sponsor reserves the right to reject any entry/nomination that it believes, in its sole discretion, is fraudulent, incomplete, illegible, damaged, invalid or otherwise fails to comply with any terms or conditions of these Rules. By entering the Giveaway, you agree to the Giveaway winner selection and decisions of Sponsor, which are final and binding in all respects.

SPONSOR IS NOT RESPONSIBLE FOR ANY NOMINATIONS OR ATTEMPTED NOMINATIONS THAT ARE LOST, LATE, ILLEGIBLE, MISDIRECTED, DAMAGED, INCOMPLETE OR INCORRECT. IF YOU FAIL TO SUBMIT A VALID NOMINATION DURING THE GIVEAWAY PERIOD FOR ANY REASON INCLUDING, BUT NOT LIMITED TO, WHERE YOU CANNOT ACCESS SPONSOR’S GIVEAWAY REGISTRATION PAGE, YOUR PROSPECTIVE NOMINEE(S) WILL NOT QUALIFY FOR A CARE PACKAGE.

Identification of Nominees:

Each Nominee will be identified by name and mailing address. Sponsor will stop accepting Nominees at the conclusion of the Giveaway Period.

How to Win a Care Package:

The first three thousand (3000) valid Nominees will be potential Care Package winners. Potential Care Package winners are subject to eligibility verification. Potential Care Package winners may, in Sponsor’s sole discretion, be required to execute a notarized Affidavit of Eligibility and Liability/Publicity Release ("Affidavit") and return such Affidavit within seven (7) days following attempted notification. Upon satisfactory eligibility verification and (where applicable) return of the Affidavit as required herein, potential Care Package winners shall be considered Care Package winners. Non-compliance within this time period may result in forfeiture of the Care Package. The return of a Care Package/Care Package notification as undeliverable may result in forfeiture of the underlying Care Package. In no case shall Sponsor be liable in any manner where a potential Care Package winner has not received notification sent from Sponsor or where Sponsor fails to receive a response from a potential Care Package winner within the required response period. See below for a detailed Care Package description.

Care Packages:

Each Care Package winner shall receive the following Sponsor product(s): an assortment of 5-6 deluxe and/or full-sized skincare items, with an approximate retail value ("ARV") between $150-$300 (collectively, the "Care Packages"). The Care Package winners will not receive the difference between the actual Care Package value and the ARV.

Odds of Winning:

The odds of winning a Care Package will vary according the number of eligible entrants received by Sponsor during the Giveaway Period.

Tax Information:

Federal, state and local taxes, and all similar fees and assessments, are the responsibility of the applicable Care Package winners.

No Substitution of Care Packages:

No substitution or transfer of Care Packages will be accommodated or permitted, other than in Sponsor’s sole discretion.

Limitation of Liability/Release/Disclaimers:

EACH ENTRANT/NOMINEE agreeS TO RELEASE, HOLD HARMLESS AND INDEMNIFY SPONSOR, its corporate partners, parent, subsidiaries, affiliates, successors in interest, advertising, promotion and public relations agencies and theIR respective officers, directors, MEMBERS, employees, representatives and agenTs (collectively "RELEASED PARTIES") FROM/FOR ANY liability whatsoever for injuries or damages of any kind sustained in connection with the acceptance, possession, USE, MISUSE or awarding of ANY Care Package including, without limitation, any injury, damage, death, loss OR accident to person or property. EACH CARE PACKAGE WINNER AGREES THAT THe CARE PACKAGE IS PROVIDED AS-IS WITHOUT ANY warranty, representation or guarantee, express or implied, in fact or in law, WHETHER NOW KNOWN OR HEREINAFTER ENACTED, relative to the use or enjoyment of the Care Package including, without limitation, ITS quality, merchantability or fitness for a particular purpose. Further, THE RELEASED PARTIES ARE NOT RESPONSIBLE IN ANY WAY for any additional expenses, omissions, delays or re-routing resulting from any acts of any government or authority.

Additional Disclaimers:

The Released Parties are not responsible and/or liable for any of the following, whether caused by a Released Party, the entrant or by human error: (a) entries/nominations that are submitted by illegitimate means (such as, without limitation, by an automated computer program) or entries/nominations in excess of the stated limit; (b) any lost, late, incomplete, illegible, mutilated or misdirected entries, e-mail, mail or Giveaway-related correspondence or materials or postage-due mail; (c) any error, omission, interruption, defect or delay in transmission or communication; (d) viruses or technical or mechanical malfunctions; interrupted or unavailable cable or satellite systems; (e) errors, typos or misprints in these Rules, in any Giveaway-related advertisements or other materials; (f) failures of electronic equipment, computer hardware or software; and/or (g) lost or unavailable network connections, or failed, incorrect, incomplete, inaccurate, garbled or delayed electronic communications or entry information. The Released Parties are not responsible for electronic communications that are undeliverable as a result of any form of active or passive filtering in connection with any means of communication, including insufficient space in an entrant’s/Nominee’s e-mail account to receive e-mail messages. The Released Parties are not responsible, and may disqualify an entrant/Nominee, if her/his mailing address, telephone or other contact information does not work or is changed without entrant giving prior written notice to Sponsor. Without limiting any other provision in these Rules, the Released Parties are not responsible or liable to any entrant or winner, or any person claiming through such entrant or winner for failure to supply the Care Package or any part thereof in the event that any of the Giveaway activities or the Released Parties’ operations or activities are affected, as determined by the Sponsor in its sole discretion, including, without limitation, by reason of any acts of God, any action, regulation, order or request by any governmental or quasi-governmental entity (whether or not the action, regulations, order or request proves to be invalid), equipment failure, threatened terrorist acts, terrorist acts, air raid, blackout, act of public enemy, earthquake, war (declared or undeclared), fire, flood, epidemic, pandemic (including, without limitation, COVID-19 and/or any governmental response to same), explosion, unusually severe weather, hurricane, embargo, labor dispute or strike (whether legal or illegal) labor or material shortage, transportation interruption of any kind, work slow-down, civil disturbance, insurrection, riot or any law, rule, regulation, order or other action adopted or taken by any governmental, federal, state or local government authority, or any other cause, whether or not specifically mentioned above.

Indemnification:

You agree to indemnify and hold the Released Parties harmless from and against any and all claims, expenses (including reasonable attorneys' fees, costs and settlement costs), damages, suits, costs, demands and/or judgments whatsoever, made by any third party due to or arising out of: (a) your use of the Giveaway and/or Care Package(s); (b) your breach of these Rules; and/or (c) your violation of any rights of another individual and/or entity. The provisions of this paragraph are for the benefit of the Released Parties. Each of these individuals and entities shall have the right to assert and enforce these provisions directly against you on its own behalf.

Publicity:

By entering the Giveaway (except for residents of Tennessee and where otherwise prohibited by law), each entrant grants the Release Parties the irrevocable, sublicensable, absolute right and permission to use, publish, post or display the Giveaway Post and any other indicia of persona (regardless of whether altered, changed, modified, edited, used alone, or used with other material in the Released Parties’ sole discretion) for advertising, trade, promotional and publicity purposes without further obligation or compensation of any kind to him or her, anywhere, in any medium now known or hereafter discovered or devised (including, without limitation, on the Internet), world-wide, without any limitation of time and without notice, review or approval and each entrant releases all Released Parties from any and all liability related thereto. Nothing contained in these Rules obligates Sponsor to make use of any of the rights granted herein and winner waives any right to inspect or approve any such use.

General Rules:

Sponsor’s decisions will be final in all matters relating to the Giveaway, including interpretation of these Rules and awarding of the Care Packages. All participants, as a condition of entry, agree to be bound by these Rules and the decisions of Sponsor. Failure to comply with these Rules may result in disqualification from the Giveaway. Participants further agree to not damage or cause interruption of the Giveaway and/or prevent others from entering the Giveaway. Sponsor reserves the right to restrict or void online entries or participation from any IP address if any suspicious entry and/or participation is detected. Sponsor reserves the right, in its sole discretion, to void entries of any entrants who Sponsor believes have attempted to tamper with or impair the administration, security, fairness or proper operation of the Giveaway. Sponsor’s failure to, or decision not to, enforce any provision in these Rules will not constitute a waiver of that or any other provision. In the event there is an alleged or actual ambiguity, discrepancy or inconsistency between disclosures or other statements contained in any Giveaway-related materials and/or these Rules (including any alleged discrepancy or inconsistency in these Rules), it will be resolved in Sponsor’s sole discretion. Entrants waive any right to claim ambiguity with resect ot the Giveaway or these Rules. If Sponsor determines at any time, in its sole discretion, that a Care Package winner or potential winner is disqualified, ineligible, in violation of these Rules, or engaging in behavior that Sponsor deems obnoxious, inappropriate, threatening, illegal or that is intended to annoy, abuse, threaten or harass any other person, Sponsor reserves the right to disqualify that winner or potential winner, even if the disqualified winner or potential winner may have been notified or displayed or announced anywhere. The invalidity or unenforceability of any provision of these Rules will not affect the validity or enforceability of any other provision. In the event that any provision is determined to be invalid or otherwise unenforceable or illegal, these Rules will otherwise remain in effect and will be construed in accordance with their terms as if the invalid or illegal provision were not contained herein. If the Giveaway is not capable of running as planned for any reason, Sponsor reserves the right, in its sole discretion, to cancel, modify or suspend the Giveaway and award the Care Packages from eligible entries received prior to cancellation, modification, or suspension or as otherwise deemed fair and appropriate by Sponsor. If any person supplies false information, obtains entries by fraudulent means or is otherwise determined to be in violation of these Rules in an attempt to obtain any Care Package, Sponsor may disqualify that person and seek damages from him or her and that person may be prosecuted to the full extent of the law.

Dispute Resolution Provisions:

These Rules shall be treated as though they were executed and performed in New York, NY and shall be governed by and construed in accordance with the laws of the State of New York (without regard to conflict of law principles). The parties hereby agree to arbitrate all claims that may arise under and/or relate to the Giveaway and/or these Rules. Without limiting the foregoing, should a dispute arise between the parties including, without limitation, any matter concerning the Giveaway, the Care Packages, the terms and conditions of these Rules or the breach of same by any party hereto: (a) the parties agree to submit their dispute for resolution by arbitration before the American Arbitration Association ("AAA") in New York, NY, in accordance with the then current Commercial Arbitration rules of the AAA; and (b) you agree to first commence a formal dispute proceeding by completing and submitting an Initial Dispute Notice which can be found here. The Released Party(ies) named in your Initial Dispute Notice (collectively, the "Named Parties") may choose to provide you with a final written settlement offer after receiving your Initial Dispute Notice ("Final Settlement Offer"). If the applicable Named Party(ies) provide(s) you with a Final Settlement Offer and you do not accept it, or such Named Party(ies) cannot otherwise satisfactorily resolve your dispute and you wish to proceed, you must submit your dispute for resolution by arbitration before the AAA, in your county of residence, by filing a separate Demand for Arbitration, which is available here. For claims of Ten Thousand Dollars ($10,000.00) or less, you can choose whether the arbitration proceeds in person, by telephone or based only on submissions. If the arbitrator awards you relief that is greater than the applicable Final Settlement Offer, then the Named Party(ies) will pay all filing, administration and arbitrator fees associated with the arbitration and, if you retained an attorney to represent you in connection with the arbitration, the Named Party(ies) will reimburse any reasonable attorneys' fees that your attorney accrued for investigating, preparing and pursuing the claim in arbitration. Any award rendered shall be final and conclusive to the parties and a judgment thereon may be entered in any court of competent jurisdiction. Although the Named Party(ies) may have a right to an award of attorneys' fees and expenses if Named Party(ies) prevail(s) in arbitration, the Named Party(ies) will not seek such an award from you unless the arbitrator determines that your claim was frivolous.

To the extent permitted by law, you agree that you will not bring, join or participate in any class action lawsuit as to any claim, dispute or controversy that you may have against any of the Released Parties. You agree to the entry of injunctive relief to stop such a lawsuit or to remove you as a participant in the suit. You agree to pay the attorney's fees and court costs that any Released Party incurs in seeking such relief. This provision preventing you from bringing, joining or participating in class action lawsuits: (i) does not constitute a waiver of any of your rights or remedies to pursue a claim individually and not as a class action in binding arbitration as provided above; and (ii) is an independent agreement. You may opt-out of these dispute resolution provisions by providing written notice of your decision within thirty (30) days of the date that you first enter the Giveaway.

Winners’ List/Copy of these Rules:

For a list of Care Package winners and/or a copy of these Rules, please send a self-addressed stamped envelope to the following address within three (3) months of the end of the Giveaway Period: Erno Laszlo, Inc., 129 West 29th Street, 8th Floor, New York, NY 10001, Winner List Request, Attn: Ecommerce.


Opting-Out

Please see our Provisions for California Residents 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 Provisions for California Residents 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 the CCPA as it applies to California State residents), 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 Provisions for California Residents 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.


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
129 W 29th Street, 7th Floor
New York, NY 10001
Tel: (212) 373-4700
Email:  advisor@ernolaszlo.com


Privacy Provisions for California Residents

These Privacy Provisions for California Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the State of California (“CA Users”). We adopt these Provisions in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA 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.comadvisor@ernolaszlo.com; calling us at: (888) 352-7956; or sending us U.S. mail to: ERNO LASZLO, Inc., Corporate Headquarters, 129 W 29th Street, 7th Floor, New York, NY 10001.

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 CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA 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 the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 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 California 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 CA 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

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated CA User information.
  • Information excluded from the CCPA's scope, 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 CA Users. For example, from online registration forms that our CA 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 and K)
  • Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, C, D, E, F and K)
  • 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 nameof 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 CA 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 CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Category A, B, C, D, E, F and K)

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 and K)
  • To provide you with information, products or services that you request from us. (Category A, B, C, D, E, F and K)
  • To create, maintain, customize and secure your account with us. (Category A, B, C, D, E, F and K)
  • 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 and K)
  • 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 and K)
  • To improve the Site and better present its contents to you. (Category A, B, C, D, E, F and K)
  • For customer service purposes and to respond to inquiries from you. (Category A, B, C, D, E and K)
  • For testing, research, analysis and product development. (Category A, B, C, D, E, F and K)
  • 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 and K)
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, D, E, F and K)
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Category A, B, C, D, E, F and K)
  • 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 and K)

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 and K: (a) with/to third parties for marketing purposes; 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 CA Users that we actually know are less than sixteen (16) years of age and we do not share or sell the personal information of CA 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 CA 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      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

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 and K)
  • Service providers. (Category A, B, C, D, E, F and K)
  • Third parties who purchase and/or license your 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 and K)

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
The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights 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 CA 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, 129 W 29th Street, 7th Floor, New York, NY 10001.

 

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.

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 CA 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 CA 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 CA 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 CA 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.

Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA 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, 129 W 29th Street, 7th Floor, New York, NY 10001.

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

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA 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 CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format
We endeavor to respond to all verifiable CA 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 CA 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.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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; 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 California law, please do not hesitate to contact 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, 129 W 29th Street, 7th Floor, New York, NY 10001.

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