1. Introduction

This Privacy Policy describes the information and data collection, storage, and use practices and policies of ESTIVANA (“we,” “our,” “us”) on the website at estivana.com (along with all sub-domains, collectively, the “Website”). This Privacy Policy is only applicable to the Website and not to any other websites that you may be able to access from the Website, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy. When you leave the Website via a link to another website, you are subject to that site’s Privacy Policy, Terms of Use, and other policies (“Third Party website policies”) applicable to that site and you should review the Third Party website policies.

2. Information Collection and Use Practices

i. Types of Information Collected ESTIVANA may collect two different types of information, Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”). PII and Non-PII may be collected anytime you access or use an ESTIVANA website, including this Website. PII and Non-PII may also be collected by ESTIVANA during in-person discussions, telephone conversations, and electronic or other written communications.

Personally Identifiable Information Collected:

In order for you to access and use the services offered through the Websites, we may require you to provide information that identifies you as an individual ( i.e. , “PII”). PII may include the following categories of information: (1) Contact Data (such as your name, mailing address, email address, and phone number(s)); (2) Financial Data (such as your account or credit card number); and (3) Demographic Data (such as your zip code and age). If you communicate with us by email, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms or surveys, any information provided may be collected as PII.

Non-Personally Identifiable Information Collected : We may automatically track and collect the following categories of information when you visit our Website: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Website; and (4) types of web browsers used to access the Website (collectively “Non-PII”). Non-PII is anonymous information that does not personally identify you but is helpful for improving your experience on the Website.

ii. Uses of Information Collected

ESTIVANA uses PII to respond to your inquiries, provide you with services you have requested, keep you informed of services and products ESTIVANA thinks may be of interest to you, and otherwise personalize your experience with ESTIVANA, among other reasons. ESTIVANA does not sell or lease PII about you to others.

III. Technology We May Use: Cookies, Web Beacons, and Clear Gifs

Cookies and web beacons are small text files that are stored on your computer when you visit certain web pages. ESTIVANA collects information through cookies and web beacons about your web browsing activities such as the address of the page you are visiting, the address of the referrer page you previously visited, the time you are viewing the page, your browsing environment, and your display settings. We may use cookies and web beacons on our Website for the following purposes:

• Understanding traffic patterns and the number of visitors to the Website and other websites that we partner with;

• Understanding how you use and interact with the Website;

• Improving ESTIVANA’s services and products;

• Optimizing your experience on the Website;

• Providing anonymous individual or aggregate auditing, research, modeling, and reporting for our advertisers and other partners

• Storing your password so you do not have to re-enter it each time you visit the Website;

• Providing you with relevant advertising and content; and

• Managing our Website.

Clear Gifs are tiny graphics with a unique identifier, similar in function to cookies, used to track the online movements of Website visitors. Please note that cookies, web beacons and clear gifs may be placed by a third party service provider who performs these functions for us. These third parties may have their own privacy policies.

ESTIVANA does not use cookies, web beacons, or clear gifs to collect or store any PII.

IV. Sharing of Personal Information

ESTIVANA may share PII with ESTIVANA affiliates, advertisers, and third parties contracting with ESTIVANA to provide services to you. The other parties with whom we share PII may send information to you about other products or services. We do not share your Financial Data with these third parties. We may share Financial Data with business partners who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Website and provision of services. Those business partners agree to uphold the same standards of security and confidentiality described in this Privacy Policy, and they will only use your Financial Data to carry out their specific business obligations to ESTIVANA.

If you do not want us to share your PII with any third parties, please email us at support@Estivana.com

If we or some or all of our assets are acquired by another company, including through a sale in connection with a bankruptcy, that company will possess the information collected by us, and it will assume the rights and obligations regarding your PII as described in this Privacy Policy. We may disclose PII or other data to comply with the law or legal requirements, enforce or apply our Terms of Use and other agreements, or protect our rights, property, the safety of our users, or others.

Because Non-PII does not personally identify You, ESTIVANA reserves the right to use and disclose to third parties Non-PII for any purpose.

V. Interest-Based Ads

We may also share Non-PII with advertisers and other third parties who may use it for advertising purposes, including to serve targeted advertising on non-affiliated third party sites. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information about your online activities on the Website or other websites over time. For example, anonymous information collected across multiple sites may enable the ad network to predict your preferences and show you ads that are likely to be of interest to you. Please note that we do not share any information that identifies you personally with the third party service providers who serve ads on our behalf. To opt out of these types of ads, please visit the Network Advertising Initiative (“NAI”) for information about how to opt-out of interest-based advertising by their members. See https://www.networkadvertising.org for general information about the NAI and https://www.networkadvertising.org/managing/opt_out.asp for the opt-out page. You may also visit https://www.aboutads.info/consumers/ to learn about interest-based advertising and how to opt-out from online behavioral ads served by some or all participating companies.

vi. Email Marketing

By submitting your email address through the Website, you are expressly consenting to receive emails from ESTIVANA, including from ESTIVANA’s affiliates, and from third parties concerning offers and advertisements unrelated to ESTIVANA. To opt-out of receiving email messages from us, from our affiliates or from other third parties, click on the “Unsubscribe” link contained in each email. Please allow up to 10 business days for us to process your request. Please note that if you decide not to receive marketing emails from us, you may still receive transactional email messages regarding your account. If you have questions or concerns regarding this provision, please contact us at support@Estivana.com

3. Confidentiality and Security of Personal Information

i. User Ability to Access, Update, and Correct PII At any time you may contact ESTIVANA via email at support@Estivana.com to update your PII or request that your PII no longer be shared by Estivana. In the case that your user name or password is lost, stolen, or used without permission, promptly contact ESTIVANA at support@Estivana.com to update the PII we have on file for you.

II. Security

ESTIVANA maintains reasonable physical, administrative and technical safeguards to protect PII from loss, misuse, or unauthorized access, disclosure, alteration or destruction. However, no system is 100% secure. ESTIVANA enforces its Privacy Policy via self-assessment.

4. Third-Party Links and Public Information

Except where expressly stated by ESTIVANA, ESTIVANA is not affiliated or associated with operators of any third party websites that link to or are linked from any ESTIVANA maintained website, including this Website. Please review the Third Party website policies of each site you visit.

ESTIVANA disclaims any responsibility for the accuracy or content of information found on third party websites that link to or are linked from any ESTIVANA website, including this Website. ESTIVANA disclaims any responsibility for the security of any information (including without limitation PII and Financial Data) that you may provide to any third party. We may also may make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes accessible to the public. You should exercise caution when deciding to disclose your PII in a public forum.

5. Updates and Changes to Privacy Policy

We reserve the right, at any time and without notice, to update or modify this Privacy Policy, simply by posting such update or modification on the Website. Any such change, update, or modification will be effective immediately upon posting on the Website. You consent to such changes through your continued use of the Website. If you have questions about this Privacy Policy or want to contact us, please send an email to Edwin@estivana.com