MARCO BICEGO USA, INC. - PRIVACY POLICY

Effective Date September 17,2015

We at Marco Bicego USA, Inc. (“Marco Bicego” or “we”) respect your concerns about privacy. This policy describes the types of information we collect from you when you visit the United States section of www.marcobicego.com (our “Website”), how we use the information, with whom we share it and the choices available to users of our Site regarding our use of the information. We also describe our practices for protecting that information and how you can contact us about our privacy practices. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This policy may change from time to time (see Changes to our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information by which you may be personally identified, such as name, postal address, e-mail address, and telephone numbers; and about your Internet connection, the equipment you use to access our Website and usage details. We collect this information directly from you when you provide it to us, or automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies. Information You Provide to Us. The information we collect on or through our Website may include:

• Contact information (such as name, postal address, telephone number and email address);

• Payment information (such as payment card details);

• Login credentials for the Site;

• Purchase and transaction information; and

• Other personal information found in content that users may provide.

Information We Collect through Automatic Data Collection Technologies. When you use our Site, we may collect certain information by automated means, using technologies such as cookies, web server logs, and web beacons. The information we collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Website, and dates and times of Website visits. A cookie is a small file placed on the hard drive of your computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A Web beacon (also known as Internet tags, clear gifs, pixel tags and single-pixel gifs) links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website

Through these automated collection methods, we obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website and permits us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We may use third-party analytics services on our websites and apps, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze your use of our websites and apps. The information collected through these means (including IP address) may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the website or app. You may be able to opt out of customized ads by visiting the Ads Preferences Manager at http://www.google.com/ads/preferences/, and the Google Analytics Opt-out Browser Add-on at https://www.google.com/settings/ads/plugin. If you use our website without opting out, this means that you understand and agree to data collection for the purpose of providing you with remarketing ads. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. The providers of third-party apps, widgets, tools, and plug-ins on our Website and apps, such as “Like it” or “share” buttons, also may use automated means to collect information. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, Marco Bicego is not responsible for these providers’ information practices.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS

You have the right, subject to certain exceptions defined in the California Consumer Protection Act (“CCPA”) and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your personal information over the past 12 months. This right of access includes information about:

• 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 that personal information;

• The categories of third parties with whom we share that personal information;

• The categories of personal information that each recipient received; and

• The specific pieces of personal information we collected about you.

DELETION REQUEST RIGHTS

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your personal information that it has collected from you and retained, subject to certain exceptions.

EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Emailing us at contact@marcobicego.com or

Calling us at 1.866.4BICEGO

The verifiable consumer request must:

Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected personal information.  This may include requesting that you provide us with at least two or more pieces of personal information to match against personal information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.

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 consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

DO NOT SELL RIGHTS

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies stop selling your personal information and refrain from doing so in the future.  You may exercise this right by:

Emailing us at contact@marcobicego.com or

Calling us at 1.866.4BICEGO

We may deny a Do Not Sell request if we have a good-faith, reasonable, and documented belief that the request is fraudulent.

AUTHORIZED AGENT

Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, (“Authorized Agent”), may make a verifiable consumer request or do not sell request related to your personal information. You may also make a verifiable consumer request or do not sell request on behalf of your minor child.

If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

NON-DISCRIMINATION

You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you services;

• Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of services; or

• Suggest that you may receive a different price or rate for services or a different level or quality of services.

To the extent required by applicable law, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the How to Contact Us section of this Online Privacy Notice.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with information, products or services that you request from us;

• To process your payments and to create and manage your account;

• To send you catalogues and other promotional materials and to communicate with you about, and administer your participation in, special events, programs, offers, surveys and market research;

• To respond to your inquiries;

• To perform data analyses (including anonymization and aggregation of personal information);

• To operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services; managing our communications; analyzing our products and customer base; performing data analytics; and performing accounting, auditing and other internal functions);

• To protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;

• To comply with and enforce applicable legal requirements, relevant industry standards and our policies.

If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. In addition, we use information collected through cookies and other automated means for purposes such as (i) customizing our users’ visits to our Website, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Website, and (iii) managing our Website, apps and other aspects of our business.

Interest-Based Advertising

Through interest-based advertising we can tailor ads to your interests and activities. Either Marco Bicego or third-party advertising companies we work with may look at your browsing activity, such as the types of content you access, ads you click on, and searches you conduct. We can then infer certain interests you have and place ads and offer you deals that meet your needs. Our goal for interest-based advertising is to show ads to people likely to be interested in the products we offer at Marco Bicego. To learn how to opt out of this ad network interest-based advertising, click here. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.

Disclosure of Your Information

We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice. We may share personal information with service providers who perform services on our behalf based on our instructions. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share certain personal information with our affiliates for the purposes described in this Privacy Notice. In addition, we may share personal information with third parties whose products or services may interest you. We also may share personal information with third-party database providers that other companies may use for their own purposes, including marketing. You have the right to prevent disclosure of your information in connection with a marketing database. Accordingly, you may object at any time free of charge to the use of your personal information in connection with a marketing database or withdraw any consent you previously provided to us and we will apply your preferences going forward.

How to Opt-Out

If you do not wish for your personal information to be used in connection with a marketing database for direct marketing purposes, you may opt-out by contacting us as indicated in the “Contact Us” section of this Privacy Notice, with your request to be removed.In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Essential Cookies

These cookies are essential to use and navigate our Site. Essential cookies help us collect information, such as your session ID and other server information, that enables us to authenticate users.

Functionality Cookies

These cookies collect information about your choices or remember your preferences so we can show you relevant content. They allow us to identify your location and remember your language during a browsing session.

Analytics Cookies

We use analytics cookies to collect information on how users navigate and use our Site, such as the pages they view, how long they stay on a page, and whether the page is displayed correctly or whether errors occur. Some of these cookies are provided by third-party analytics providers, including Google Analytics. For more information about these third-party providers’ cookies, please click on the links below:

• Google Analytics

• Qubit

For further information, please see below a list of the specific cookies that we use on our Site. We will not set any non-essential cookies on your device without your consent.