PRIVACY POLICY

Last Updated: 11/15/2022

As set forth in our Terms of Use, the ImportCDs website, including all subpages and successor pages thereto (the "Website" or “Site”), the ImportCDs mobile application (the "Mobile App"), and other associated services (the “Service” or "Services") are owned and operated by DirectToU, LLC and/or one of its subsidiaries (hereinafter collectively referred as the "Company", "DirectToU, LLC" "ImportCDs", "ImportCDs Platform", "we", "our" or "us"). The Website, Mobile App and the Service are also collectively referred hereto as the “ImportCDs Platform” or the “Platform”.

By using, accessing or registering with the ImportCDs Platform, you signify your consent to this Privacy Policy and Terms of Use. If you do not agree to this Privacy Policy, delete all cookies from your browser cache after visiting or using the ImportCDs Platform and do not visit or use the Platform thereafter. Your continued use of the ImportCDs Platform will signify your acceptance of these terms.

CALIFORNIA RESIDENTS: CALIFORNIA CONSUMER PRIVACY ACT NOTICE

PRIVACY QUICK LOOK

1. Anyone may browse our Website, Services and/or App, but you must provide personal information in order to register with the us and take full advantage of the ImportCDs Platform and the features offered by the ImportCDs Website, Services and App. Learn more
2. We may contact you by email or SMS text, and by registering with us, you expressly consent to receiving email, or text messages from us.
3. When you visit or use the ImportCDs Platform, we set cookies on your Web browser so that we can recognize you and personalize our site to your preferences. Learn more
4. You can control the placement of cookies on your Web browser by your Web browser settings. Learn more

COMMITMENT TO YOUR PRIVACY

At ImportCDs, your privacy is important to us. We understand that you entrust us with the management of your data. Please know that we protect your privacy. ImportCDs may share or sell personal information about you to or with any person or organization as provided in this Privacy Policy or as may be required by law or court order. This Privacy Policy describes the standards that we adhere to in handling information about you.

The www.importcds.com website (the "Website") is provided to You by DirectToU, LLC and/or any of its related, affiliated and/or subsidiary companies (individually and collectively, "ImportCDs," "We," "Our" or "Us"), and the following Privacy Policy applies to all of the services offered by ImportCDs in connection with the Website as well as the ImportCDs pages on Facebook, Twitter and Google. For convenience, the words "user," "You" and "Your" as used in this Privacy Policy refer to users of the Website.

ImportCDs recognizes that Your privacy and the protection of Your personal information are important to You, and therefore, has adopted this Privacy Policy. This Privacy Policy describes ImportCDs's privacy practices and how ImportCDs treats the personal information that it collects from You when You use the use the Website, including any personal information You provide when You conduct business with ImportCDs on or through the Website or use ImportCDs's Media's services that are provided on or through the Website.

For the purposes of this Privacy Policy, "Personal Information" is information that (i) You provide to ImportCDs and (ii) personally identifies You. Personal Information includes Your name, email and postal address, billing, credit card and banking information, telephone numbers and other data that can be used to personally identify or contact You.

THE INFORMATION WE OBTAIN AND MANAGE

The Personal Information that the ImportCDs may collect from You and/or manage includes, but is not limited to:

• Contact information such as email and postal addresses and telephone numbers;
• Credit card and banking information; and
• Purchasing activities

Except as otherwise provided in this Privacy Policy, ImportCDs will store all information provided by You in its secure data servers during the time You use ImportCDs products and/or services. ImportCDs uses commercially reasonable efforts to ensure that such information is secure and to protect against its loss, misuses, and alteration of the information under ImportCDs's direct control. Notwithstanding the foregoing, ImportCDs cannot guarantee that its security measures will prevent its computers from illegal or otherwise unauthorized access. For the avoidance of doubt, ImportCDs will not retain Your credit card or other banking information without Your separate, prior written authorization.

HOW WE OBTAIN THE PERSONAL INFORMATION

ImportCDs may obtain, collect, retain, store or otherwise maintain Your Personal Information from the following sources:

• Information that You provide to Us when You initiate communications with Us, subscribe to Our newsletter, respond to a survey published by Us or purchase goods and services from Us;
• Your entries for sweepstakes and other promotions provided or sponsored by Us;
• Your responses to communications from ImportCDs. From time to time, ImportCDs may communicate with You through email, postal mail or other forms of electronic communications regarding Your purchases of goods and services from Us and the Website. If You respond to these communications, Your responses may contain Personal Information; and
• Third parties to whom You have provided Your Personal Information and have consented to those third parties sale, rental or transfer of such Personal Information.

You can decline to provide Your Personal Information to ImportCDs by not engaging in the activities described above. If You decline to submit Personal Information, ImportCDs may not be able to or may choose not to provide to You some or all of the features available on the Website.

ImportCDs also collects non-personally identifiable server-log information relating to users of the Website. This information, may include information such as, but not limited to Your web request, Internet Protocol address, browser type, browser language, the date and time of Your request, date and time of access, one or more cookies that may uniquely identify Your browser and referrer Uniform Resource Locator. None of this information enables ImportCDs to personally identify or contact You.

HOW WE USE YOUR INFORMATION

ImportCDs only uses Personal Information for the purposes and in the manner described in this Privacy Policy. Specifically, ImportCDs only uses Your Personal Information for:

• Doing business with You, including processing payments and communicating with You regarding Your purchases of goods and services from ImportCDs;
• Communicating with You regarding sweepstakes and other contests offered or sponsored by ImportCDs that You have entered;
• Processing, formatting and displaying customized content on the Website for You;
• Communicating with You regarding changes to: ImportCDs's Terms of Service, this Privacy Policy or any other policies or terms relating to the Website or the offering of goods and services on the Website;
• Auditing, research and analysis in order to maintain, protect and improve the Website and the other goods and services offered or provided by ImportCDs;
• Communicating with You, with Your consent, regarding new and additional ImportCDs services and changes to the Website; and/or
• Ensuring the technical functioning of the Website, including creating and maintaining back-ups or other archival copies of Personal Information and other related data.

ImportCDs restricts access to Personal Information to those service providers, employees, contractors and agents of ImportCDs who need to access Personal Information for the purposes specified above. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.

Except as otherwise set forth herein, ImportCDs does not share Your Personal Information with third parties without Your consent, and when We believe that it is reasonably necessary to do so in order to comply with a subpoena or other judicial order or process, as otherwise required by law or in order to enforce ImportCDs's Terms of Service. In such circumstances, Your Personal Information may also be disclosed to ImportCDs's attorneys.

If ImportCDs desires to use Your Personal Information for any purpose other than those described in this Privacy Policy, ImportCDs will request Your consent prior to such use and offer You an effective way to opt out of the use of Personal Information for those other purposes. If You opt out or otherwise decline to submit Personal Information in response to such a request, ImportCDs may not be able to provide to You some or all of the features available on the Website.

TECHNICAL INFORMATION

We may collect and track certain technical information to ensure that Your experiences on the Website and purchase of goods and services offered on the Website, including but not limited to the following:

• Cookies - A cookie is a small file stored on a user's computer that contains information about the user. We may use either session ID cookies (which terminate once a browser is closed) or persistent cookies (which are small text files stored on a user's hard drive for an extended period of time). Cookies allow Us to see how and when You use our sites, but they cannot be used to track personal information such as email address or phone number. Cookies also allow Us to store the personal preferences that You set during each visit to our sites which can speed up Your future visits. These cookies cannot damage a user's files and cannot read information from a user's hard drive.
• Log files - ImportCDs may use log files to track how our sites are being accesses and used. Log files track anonymous user information such as IP addresses, browser types, Internet service providers, referring and exit pages, platform type, date and time stamps, and number of clicks to, from, and within our sites.
• Information from Banner Ads - If You arrive at ImportCDs's website(s) through a banner ad or other Affiliate referral device, ImportCDs may track where You arrived from, as well as clicks that might have impacted our servers.
• We may use clear GIF Tracking Pixels to track user movement through our web sites for aggregated site traffic measuring. In addition, some Affiliates may set such tracking pixels on our web site pages to track completed forms and requests referred by their web sites.

Please be assured that no Personal Information is collected from or stored in these cookies, files or tracking devices.

"CONTACT US" INFORMATION

If You communicate with Us through the "Contact Us" , We may ask You for Personal Information such as Your name, email address, or phone number. If You are contacting Us with respect to a customer service issue, we may use the Personal Information that You provide to contact You in order to resolve that customer service issue. If necessary to resolve Your customer service issue, the Personal Information that You provide to Us may be shared with third parties in order to resolve the issue. Please understand that by providing such information in connection with a customer service issue, You are giving Your express consent for Us to use Your Personal Information to contact and communicate with You regarding that customer service issue.

THIRD PARTY INFORMATION

ImportCDs may collect or purchase information from third parties regarding persons who provided information to those third parties. Information provided to Us by the third party may include, but not limited to, individual names, email and postal addresses, telephone numbers, and any other information provided to the third party. ImportCDs uses its reasonable best efforts to ensure that (i) the third party possesses the right to transfer the information to ImportCDs and (ii) ImportCDs has received the right to communicate with the persons who provided the information.

EMAIL SOLICITATIONS

ImportCDs only sends email solicitation to users who have agreed, through this Privacy Policy, on third party websites or by other means, to receive emails from ImportCDs.

WIRELESS COMMUNICATIONS

If the email address You provide to ImportCDs is a wireless address, You agree to receive messages at such address from ImportCDs. You understand that Your wireless carrier's standard rates apply to these messages. You represent and warrant that You are the owner or authorized user of the wireless device on which messages will be received, and that You are authorized to approve the applicable charges associated therewith.

AFFILIATES

ImportCDs may share Your Personal Information with companies that are related to or affiliated with ImportCDs (collectively, “Affiliates”). Affiliates will use Your Personal Information in accordance with the terms of this Privacy Policy.

LINKS

This Privacy Policy only pertains to the Website. Other websites and portals, such as those to which the Website links to or link to the Website, including, without limitation, Facebook.com, Google.com and Twitter.com may have their own privacy policies. We encourage You to read the privacy policies and terms of use of the websites and portals that You visit through links placed on the Website as well as those for websites that provide links to the Website. You should contact these websites directly if You have any questions about their use of Your Personal Information. ImportCDs is not responsible for any use of Your Personal Information or any other type of Your information when You use such third party sites and services.

INFORMATION SHARING AND ONWARD TRANSFER

We may disclose your personal information to a third party for a commercial purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

• Service providers
• Analytics providers
• Data aggregators

In addition, ImportCDs reserves the right to share non-personally identifiable information relating to users of the Website or the ImportCDs services with our partners and advertisers. The information will not be linked to any personal identifiable information. When You sign up for any third party service, information may be shared with the third party and Your privacy will be maintained in accordance with the third party privacy policy.

RESTRICTED AREAS

Certain areas of the Website such as areas only available to our Affiliate and/or customer network, may have additional or different terms and conditions than those addressed in this policy. If You access any of these areas, You should consult the privacy policies posted in those areas.

CHANGES TO THIS PRIVACY POLICY

ImportCDs may, at its sole discretion, revise this Privacy Policy at any time in a manner consistent with applicable laws and regulations. When we revise this policy, including changes to ImportCDs's use of Your Personal Information, we will incorporate the revisions into this policy and will revise the "last revised" date at the top of this web page. We will notify you when any changes to this Privacy Policy are made. We recommend that You review those changes in order to remain informed about how ImportCDs uses Your Personal Information.

CALIFORNIA USER CONSUMER RIGHTS

In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by telephone at (916) 445-1254 or (800) 952-5210; or by email to dca@dca.ca.gov. For more information about protecting Your privacy, You may wish to visit: www.ftc.gov.

CHILDREN'S/MINOR'S USE OF THE WEBSITE

Consistent with the Federal Children's Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without requesting parental consent.

USE OF THE WEBSITE

You acknowledge that the personal information You provide to ImportCDs is collected and stored in the United States and therefore consent to the transfer of information to and storage of the information in the United States, regardless of Your country of domicile.

SEVERABILITY

If any provision of this Privacy Policy is found to be illegal, void, or unenforceable, that provision will be deemed severed from the balance of the agreement and will not affect the validity and enforceability of the remaining provisions, which will continue in full force and effect.

ACKNOWLEDGEMENT

By completing forms provided by ImportCDs and providing personal information through the Website, through any means, and by using the Website and services contained therein, You hereby represent and warrant that:

• You have read, understand and agree to ImportCDs's Privacy Policy;
• You are an actual person of at least 18 years of age, You have the right to provide the information that You submit to ImportCDs, and the information You submit is accurate, complete and truthful; and
• If You do not agree to the terms of this Privacy Policy, then do not provide Your information to ImportCDs through any means. In such case, ImportCDs is relieved of any of its obligations to You as set forth in this Privacy Policy.

OPT OUT RIGHTS GENERALLY

You have the right to opt out of the sale of Your Covered Information, as such term is defined under Nevada law. You may submit a request to opt out of future sales by us by writing to us at optout@importcds.com. We will maintain your request in the event our practices change in the future. Should your email address change, please submit a new request to optout@importcds.com with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.

NOTICE TO CALIFORNIA RESIDENTS / YOUR CALIFORNIA PRIVACY RIGHTS

California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year (e.g., responses to requests made in 2022 will contain information about 2021 sharing activities).

We do not share personally identifiable information about you to third party direct marketers, what we do share with third party direct marketers is a cryptographic hash value derived from your information. That hash value cannot be reasonably associated with your personal information.

California residents may request further information about our compliance with this law by sending a request to the address set forth in the Contact Us section below. You must include “California Privacy Rights” in the subject line, and your full name, email address, and postal address in your request. Please note that under California law, businesses are only required to respond to a customer request once during any calendar year, and we are not required to respond to requests made by means other than through this physical mailing address.

CALIFORNIA CONSUMER PRIVACY ACT OF 2018

This Privacy Notice for California Residents supplements the information contained in the Notice to California Residents/Your California Privacy Rights and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

You understand and agree that this CCPA supplemental notice incorporates the arbitration agreement provisions set forth in ImportCDs’s Terms of Service, including a waiver of any rights to class-wide arbitration.

INFORMATION WE COLLECT

The ImportCDs Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"), but does not include in particular,

Publicly available information from government records,

Deidentified or aggregated consumer information,

• Information excluded from the CCPA's scope, like: 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;
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the California Financial Information Privacy Act (FIPA); and Driver's Privacy Protection Act of 1994.

ImportCDs has collected the following categories of personal information from its consumers 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, and email address.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, physical characteristics or description, address, telephone number, and payment card 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).	NO
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.	NO
F. Internet or other similar Platform activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
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;
• Deidentified or aggregated consumer information;
• Digital images or photographs not used for identification;
• Information excluded from the CCPA's scope, for example: 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;
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

ImportCDs obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete, products you purchase, or information you choose to post or share.
• Indirectly from you. For example, from observing your actions on the ImportCDs Platform.

ImportCDs intends to retain above categories of personal information for 36 months from date received.

USE OF PERSONAL INFORMATION

We may use, or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;
• To provide, support, personalize, and develop our Platform, products, and services;
• To create, maintain, customize, and secure your account with us;
• To process your requests, purchases, transactions, and payments and prevent transactional fraud;
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• To personalize your ImportCDs Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law);
• To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business;
• For testing, research, analysis, and product development, including to develop and improve our Platform, products, and services;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ImportCDs’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ImportCDs about ImportCDs users is among the assets transferred.

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 notice.

SHARING PERSONAL INFORMATION

We may disclose your personal information to a third party for a commercial purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Service providers, including customer service, payment processing, marketing and analytical services; and
• Data aggregators.

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial information.
• Category F: Internet or other similar Platform activity.
• Category G: Geolocation data.
• Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers, including customer service, payment processing, marketing and analytical services; and
• Data aggregators.

SALES OR SHARING OF PERSONAL INFORMATION

In the preceding twelve (12) months, the Company has not sold or shared the following categories of personal information:

1. Identifiers.
2. California Customer Records personal information categories.
3. Protected classification characteristics under California or federal law.
4. Commercial information.
5. Biometric information.
6. Internet or other similar Platform activity.
7. Geolocation data.
8. Sensory data.
9. Professional or employment-related information.
10. Non-public education information.
11. Inferences drawn from other personal information.

YOUR RIGHTS AND CHOICES

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS

You have the right to request that ImportCDs disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see consumer request form), 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 share that personal information;
• The specific pieces of personal information we collected about you (also called a data portability request); and
• 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 AND CORRECTION REQUEST RIGHTS

You have the right to request that ImportCDs delete or correct any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your verifiable consumer request (see consumer request form), we will delete or correct and direct our service providers to delete or correct your personal information from our records, unless an exception applies.

Even if verifiable, we may nonetheless deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 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, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. 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, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
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, DELETION RIGHTS, AND CORRECTION RIGHTS

You may exercise the access, data portability, deletion rights, and correction rights described above by submitting a verifiable consumer request to us using one of the following options:

• Call us at 855-258-9650
• Sending an email to privacy@importcds.com
• Use the online CCPA request form

ONLINE CCPA REQUEST FORMS

To exercise the right to access your personal information stored by ImportCDs, you may submit a request to us by visiting our online consumer request form.

PERSONAL INFORMATION SALES OR SHARING OPT-OUT AND OPT-IN RIGHTS

If you are 16 years of age or older, you have the right to direct us to not sell or share your personal information in the event our practices change in the future (the "right to opt-out"). For consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age, we will not sell or share your information in the event our practices change in the future.

In order to exercise the right to opt-out of personal information sales or sharing by ImportCDs, you (or someone legally authorized) may submit a request to us by visiting:

In order to exercise the right to limit personal information shared by ImportCDs, you (or someone legally authorized) may submit a request to us by visiting our online consumer request form.

We will retain your opt-out request in the event our practices change in the future. Should your email address change, please submit a new request with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

VERIFICATION REQUIREMENT FOR REQUESTS

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access, data portability, deletion, or correction twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or 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 the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

RESPONSE TIMING AND FORMAT

We will acknowledge receipt of your request no later than 10 business days and will endeavor to respond to a verifiable consumer request no later than forty-five (45) business days of its receipt. If we require more time (up to 90 days), we will notify and inform you of the reason and extension period in writing.

If we receive a request to opt-out from you, we will act upon that request no later than 15 business days from the date we receive that request.

If you have an account with us, we will deliver our written response to that account electronically. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons 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 (e.g., an excel spreadsheet that has been converted into a changed-locked pdf).

We do not charge a fee to process or respond to your verifiable consumer 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

OTHER CALIFORNIA PRIVACY RIGHTS

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. ImportCDs does not disclose personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@importcds.com or write us at:

CHANGES TO OUR PRIVACY NOTICE

ImportCDs reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the ImportCDs Platform and update the notice's effective date. Your continued use of our Platform following the posting of changes signifies and constitutes your acceptance of such changes.

CONTACT US

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection, storage, disclosure and use practices, please email us at: privacy@importcds.com

Any personal information you provide to the above email addresses will not be used to send you promotional materials, unless you request it.