NOLUMA PRIVACY STATEMENT

We know you are concerned about your privacy, and Noluma International, LLC and its affiliates (“Noluma”) are too, and we want you to be familiar with how we collect, use and disclose information. This Privacy Statement describes Noluma practices in connection with information that we collect through the website or mobile application owned and controlled by Noluma from which you are accessing this Privacy Statement (respectively, the “Site” and the “App”), as well as offline where notice is legally required. By providing Personal Information to Noluma, you agree to the terms and conditions of this Privacy Statement.

This Privacy Statement does not apply to personal information collected for employment-related purposes, which are addressed by a separate privacy notice.

Noluma is committed to working with you to obtain a fair and rapid resolution of any questions or concerns you might have regarding this Privacy Statement or our collection or use of your personal information Please contact us at info@noluma.com if you have questions.

WHAT WE MEAN BY “PERSONAL INFORMATION”

“Personal Information” is information that identifies you as an individual, or that can be used to identify you when combined with other available information about you. We collect Personal Information when you interact with us online and participate in various opportunities that we provide. We may combine Personal Information that we collect about you with Personal Information you provide to Noluma through other sources, such as product registrations, inquiries or marketing events. We will use the combined Personal Information in accordance with this Privacy Statement for as long as it is combined.

Information You Provide Voluntarily: • Name • Postal address (including billing and shipping addresses) • Telephone or fax number • Email address • Credit and debit card number • Vendor Tax ID numbers • National ID numbers such as Social Security Numbers • Financial information when you apply for credit • Purchase history • Biometric information when it is necessary for you to obtain access to a location (for example) • Demographic information and other information provided by you. Information we collect automatically: IP Address, Browser information Information collected through cookies: Pixel tags and other technologies

HOW WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU

Noluma collects Personal Information when you interact with us online or participate in various opportunities that we provide, for example:

HOW WE USE YOUR PERSONAL INFORMATION

Noluma uses your Personal Information for basic purposes:
To fulfil your requests;
To complete purchase or selling contracts;
To operate our business;
To improve your online experience; and
To comply with legal obligations.

PURPOSES WITHIN THE FRAMEWORK OF A LEGITIMATE INTEREST ON OUR PART OR OF THIRD PARTIES

Your data shall only be processed to the extent that you do not have any overriding interests against such processing such as in particular for the following purposes:

PURPOSES WITHIN THE FRAMEWORK OF YOUR CONSENT

PURPOSES WITHIN THE FRAMEWORK OF COMPLIANCE WITH A LEGAL OBLIGATION

• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce Noluma terms and conditions; (e) to protect Noluma operations; (f) to protect Noluma rights, privacy, safety or property, you or others; and (g) to allow Noluma to pursue available remedies or limit the damages that we may sustain; (h) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm our business or Visitors. • When processing is necessary to comply with a legal obligation.

If possible, we will use anonymized data for these purposes, but in the event we use or combine it with Personal Information we will treat it in accordance with this Privacy Statement for as long as it contains Personal Information.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH, AND WHY

Except to the extent necessary to fulfill our business obligations as described in this Privacy Statement, or to accomplish a disclosure requested or authorized by you based on your express advance consent, we do not sell, transfer, or otherwise disclose the personal information we collect from and about you. We share your personal information as necessary to complete any transaction that you have requested or authorized. In addition, we share Personal Information among Noluma affiliates and subsidiaries and with vendors or agents working on our behalf for the purposes described in this statement.

YOUR CHOICES REGARDING NOLUMA’S USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION

Noluma gives you choices regarding Noluma’s use and disclosure of your Personal Information for marketing purposes and we will only use your Personal Information for marketing purposes with your prior consent.

SUBJECT ACCESS REQUESTS

If you would like to review, correct, update, suppress, delete or otherwise limit Noluma’s use of your Personal Information that has been previously provided to Noluma, you may contact Noluma at info@Noluma.com

RAISING A COMPLAINT

Noluma is committed to resolving complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Statement are encouraged to first contact Noluma at info@noluma.com.

You may also contact the Data Protection Authority / Supervisory Authority in the country of your habitual residence or place of work. A list from the International Conference of Data Protection & Privacy Commissioners can be found here: https://icdppc.org/participation-in-the-conference/list-of-accredited-members/.

OTHER IMPORTANT PRIVACY INFORMATION

For your security Noluma uses reasonable organizational, technical and administrative measures to protect Personal Information under Noluma control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with Noluma is no longer secure (for example,if you feel that the security of any account you might have with Noluma has been compromised), please immediately notify Noluma of the problem by contacting Noluma in accordance with the “Contacting Noluma” section below.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Statement, to perform a service you have requested, or for which you have given consent, or such longer retention period as is required for our business purposes and applicable law.

CROSS BORDER TRANSFERS

Your Personal Information may be stored and processed in any country where we have facilities or where we have engaged a service provider, and by using Noluma’s Site or App you consent to the transfer of information to countries outside of your country of residence, including to the United States, which may have different data protection rules than in your country. Such transfers are governed by internal Controller to Controller contracts between Noluma legal entities, and through Data Transfer agreements with nonaffiliated third parties.

TRANSFERS OF EU PERSONAL DATA TO THE UNITED STATES

When required, transfers of EU personal data to the U.S. are also protected by Noluma through Privacy Shield certification, or by its use of EU Standard Contractual Clauses when transferring EU personal data to entities and individuals who do not have Privacy Shield certification or a similar EU-compliant data transfer mechanism already in place.

SENSITIVE INFORMATION

Unless legally required, we ask that you not send Noluma, and you not disclose, any sensitive Personal Information -- information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sex life or sexual orientation -- on or through the Site or App or otherwise to Noluma.

USE OF SITE BY CHILDREN

Noluma is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities. Noluma does not target the Site or the App to children less than thirteen (13) years of age or collect information from children for the purpose of selling products or services. Noluma may participate in select educational programs such as in science and environmental awareness in support of schools and communities.

IP ADDRESSES

Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in Noluma server log files whenever a user visits the Site.

Noluma uses IP Addresses to monitor site usage and enhance your online experience. When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device may send us data about your location. Most devices allow you to prevent location data from being sent to us and we honor your settings.

INTERNET-BASED ADVERTISING

Noluma and Noluma third party service providers use cookies, pixel tags, web beacons, clear GIFs or similar technologies to track the actions of Site users and email recipients across non-affiliate websites over time, in order to personalize your experience on the Site by presenting advertisements that are more relevant to you.

UPDATES TO THIS PRIVACY STATEMENT

We may change or update this Privacy Statement. Please take a look at the revision date on this page to see when this Privacy Statement was last revised. Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Site or App. Your use of the Site or App following these changes means that you accept the revised Privacy Statement.

CONTACTING NOLUMA

If you have any questions or requests about this Privacy Statement, please contact Noluma at info@noluma.com or please write to the following address: Noluma Inquiry Management Center 1007 N Market Street Wilmington, DE 19898 Toll-free: 800-441-9481 E-mail: info@noluma.com

When contacting, please include the name and the address to which you would like us to respond.

Last revised: June 22, 2018