Privacy policy

JudeConnally.com
Privacy Policy
Effective August 21, 2023
Last Updated on August 21, 2023

This Privacy Policy applies to the website JudeConnally.com, whether accessed directly or through mobile application, all of which are owned and operated by _ Jude Connally Clothing and Accessories dba Jude Connally Clothing and any of its affiliated entities. We take your privacy very seriously. We refer to the JudeConnally.com website and applicable mobile applications as the “Website” or the “Platform”, and, together with the goods and/or services made available to users of the Platform, the “Services”.

Please read this Privacy Policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

By accessing the Website or using our Services, you accept our Terms of Use, and this Privacy Policy.  We may change this Privacy Policy 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 this Privacy Policy periodically for updates.

Web Site Visits. In general, you can visit on the Website without disclosing or revealing any personal information. However, we do keep track of the domains from which people visit us, analyze the data gathered from Website visits for trends and statistics, and then discard the gathered data.

Personal Information That May Be Collected.

The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

Third Parties: We may collect personal information from third parties or other sources for direct mailing and marketing purposes.

Identifying Information. In order to make a purchase or access other available Website services, we will request a user to provide certain personal identifying information, which may include: the user’s name, postal address, e-mail address, screen name, password, telephone number, method of payment, and where applicable, payment card number (processed by a third-party payment processor). We may request additional information necessary to establish and maintain customer's account.

Service Quality Monitoring. Some Website transactions may require us to communicate with you. We will not contact you by telephone without your prior consent, except to confirm an order placed online and/or to inform a customer of the status of such order. Customers should be aware that it is our practice to monitor, and in some cases record such calls for staff training or quality assurance purposes.

Information from Children. We do not sell products or services for purchase by children and will not collect or post information from a child under the age of 18 without the involvement of a parent or guardian. We will notify the child's parent or guardian at the e-mail address provided by the prospective customer, alerting the parent or guardian to the child's use of the Website and providing instructions as to how the parent or guardian can delete the child's registration from the Website. We do not use personally identifying information collected from children for marketing or promotional purposes, and do not disclose such information to any third party for any purpose whatsoever.

Chat Rooms, Forums and Bulletin Boards. Where applicable and provided, if a Website user participates in a chat room, discussion forum, or posts messages to a Website bulletin board, that user should be aware that the information disclosed and shared will be broadly available to other persons, both inside of and/or outside of JudeConnally.com, who have access to that chat room, forum or bulletin board. Also, participant's expressed opinion is his or her own and should not be considered as reflecting the opinion of JudeConnally.com.

Links to Other Web Sites. The Website may contain links to other web sites. We are not responsible for the privacy practices or the content of those other Web sites.

Uses Made of the Information.

Limited Uses Identified. We use personal identifiable information to reply to inquiries, handle complaints, provide operational notices and in program record-keeping. We also process billing and business requests related to Website participation.

Marketing Uses. If you want to exercise any of your opt-out rights set forth in this Privacy Policy, please send your request by clicking this link or email us directly at privacy@judeconnally.com.

We reserve the right to provide you with information about the Website, our products and services, and related information in which you have indicated an interest

Stored Information Uses. We store and retain the information provided by you or otherwise entered on the Website. This information is used to compile a customer's purchase history in order to enable us to recommend products, services, or special offers that would be of interest to a customer, to support customer interaction with the Web site, to arrange for delivery of customer purchases; and to contact customer again about other JudeConnally.com services and products.

Online Advertising. Some companies that help us deliver interactive on-line advertising, such as banner ads, may collect and use information about our customers. This advertising helps us to better understand the types of advertising or promotions that are most appealing to our customers. After it is collected the information is aggregated so it is not identifiable to a specific individual. If, however, you would prefer that these companies not collect such information, please click on the "x" provided by that advertiser.

Disclosure and Sharing of the Information.

Within Our Organization. We may share your personal information within our organization and may transfer the information to countries in the world where We conduct business. Some countries may provide less legal protection for customer personal information.

Mergers and Acquisitions. Circumstances may arise where for business reasons, We decide to sell, buy, merge or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the sharing and disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is our practice to seek appropriate protection for information in these types of transactions.

Affiliated Businesses. We work closely with affiliated businesses operating web site stores, providing services or selling products on each other's Web sites. These businesses identify themselves to customers. Customer information related to a transaction with an affiliated business is shared with that affiliated business.

Marketing Analysis by Third Parties. We reserve the right to share and disclose to third parties’ personal information about Platform users for marketing analysis; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual customer. Personal information is shared with third party marketing partners for our commercial purposes.

Disclosure to Governmental Authorities. Under certain circumstances, personal information may be subject to disclosure pursuant to a judicial or other government subpoenas, warrants or orders. We endeavor to comply with all such legal requests.

Personal Information from Third Parties. We collect personal information from certain third parties for direct mailing purposes.

Third Party Marketing Partners. We disclose personal information with third party marketing partners for commercial purposes. These persons are provided with personal identifying information required to perform their functions but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, fulfilling orders, delivering packages, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments and providing customer services.

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

Use of Computer Tracking Technologies.

No Tracking of Personal Information. The Website is not set up to track, collect or distribute personal information not entered by visitors. Through Website access logs We do collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.

Use of Cookies. We, or where applicable, our third-party vendors, collect non-identifiable and personal information through the use of various technologies, including "cookies". A cookie is an alphanumeric identifier that a Web site can transfer to customer's hard drive through customer's browser. The cookie is then stored on customer's computer as an anonymous tag that identifies the customer's computer, but not the customer. Cookies may be sent by us or our third-party vendors. You can set your browser to notify you before a cookie is received, providing an opportunity to decide whether to accept the cookie. You may also set its browser to turn off cookies; however, some web sites may not then work properly.

Use of Web Beacon Technologies. We may also use Web beacons or other technologies to better tailor our Website or to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Web site, a non-identifiable notice of that visit is generated which may be processed by us or by our service provider. Web beacons usually work in conjunction with cookies. If you do not want cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

Collection of Non-Identifiable Information. We may collect non-identifiable information from user visits to the Website in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on our Website; Website and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." We or our contractors may use this data to analyze trends and statistics.

Collection of Personal Information. We collect personal identifying information from customers during a transaction. We may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help us understand trends and patterns. This information is not reviewed at an individual level.

Information Security.

Commitment to Online Security. We employ commercially reasonable security to protect your privacy, including physical, technical and administrative controls to safeguard the security and integrity of your personal information. Billing and payment data is encrypted whenever transmitted or received online. Personal information is accessible only by staff designated to handle online requests or complaints.

No Liability for Acts of Third Parties. We will exercise all reasonable efforts to safeguard the confidentiality of customer personal information. However, transmissions protected even by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, We shall not be liable for unauthorized disclosure of personal information due to no fault of ours including, but not limited to, errors in transmission and unauthorized acts of JudeConnally.com staff and or other third parties.

Privacy Policy Changes and Opt-Out Rights.

Changes to Privacy Policy. This privacy notice was last updated on August 21, 2023. We reserve the right to change or update its privacy policy statement at any time. A notice of any material change will be posted on the JudeConnally.com website home page for thirty (30) days prior to the implementation of such change.  Your continued use of the site will be  considered your acceptance of these changes.

Opt-Out Right. Anyone visiting or using the website or Platform has the right at any time.

• to delete, erase or remove their personal information
• to cease their permitting personal information to be collected, used, shared or disclosed by us and by any third parties with whom We contract to share and/or transfer such personal information.  
  
• If you want to exercise any of your opt-out rights set forth in this Privacy Policy, please send your request by clicking this link or email us directly at
  privacy@judeconnally.com.
  
• After processing your verified request, and except for records of user website transactions, we will comply with your request

Access Rights to Data.

Information Maintained by Us. Upon request, we will provide a reasonable description of customer's personally identifiable information that We maintain. We can be contacted by e-mail at privacy@JudeConnally.com or certified postal mail at

   Jude Connally

   320 S Michigan Avenue

   Kenilworth, New Jersey 07033

Corrections and Changes to Personal Information. Help us to keep customer personal information accurate. If your personal information changes, or if you note an error upon review of customer information that We have on file, please promptly e-mail us at privacy@JudeConnally.com and provide the new or correct information.

• Your California Privacy Rights. Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers of JudeConnally.com who are California residents to request certain information regarding our disclosure of personal information for their direct marketing purposes. To make such a request, please write to Jude Connally, 320 S Michigan Avenue, Kenilworth, New Jersey 07033. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the address specified in this paragraph.

Web Site Transactions. At times, we will need personal information regarding a customer. For example, to process an order or provide a subscription, we may need to know your name, mailing address, e-mail address and credit card details. It is our intent to inform you that we will collect personal information, such as user's name and/or address on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, we will respect your wishes.

• California Consumer Privacy Act Of 2018 (CCPA), California Privacy Rights Act Of 2020 (CPRA), and the General Data Protection Regulation (GDPR).

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	JudeConnally.com
Our representative	TomC@judeconnally.com
Our data protection officer	Tom Connally TomC@judeconnally.com
Personal information	Any information relating to an identified or identifiable individual.
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information	Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information.
Biometric Information	An individual's physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

 

Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	Real name, postal address, online identifier, Internet Protocol Address, email address.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, 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.	Physical address, telephone number.
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	Account log-in and password reset.
Characteristics of protected classifications under California or federal law.	N/A
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	Records of purchasing history and related services.
Biometric information	None
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	Cookies and beacons.
Geolocation data	N/A
Audio, electronic, visual, thermal, olfactory, or similar information	N/A
Professional or employment-related information	N/A
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	N/A
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Browsing and purchasing history
Racial or ethnic origin, religious or philosophical beliefs, or union membership	N/A
Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication	N/A
Genetic data	N/A
Processing of biometric information for the purpose of uniquely identifying a consumer	N/A
Health information	N/A
Sex life or sexual orientation	N/A

If you do not provide personal information required to provide products or services to you, it may delay or prevent us from providing such products or services to you.

How Your Personal Information is Collected. We collect personal information from the following categories of sources:

• You, by telephone, text, or email or via our website and, where available, our apps
• Third party with your consent (e.g., your bank)
• Advertising networks
• Internet service providers
• Data analytics providers
• Operating systems and platforms
• Cookies on our website
• Our IT and security systems, including:

• Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.

• How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

• To comply with our legal and regulatory obligations
• For the performance of our contract with you or to take steps at your request before entering into a contract
• For our legitimate interests or those of a third party –or–
• Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products or services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or judeconnally.com	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: Existing and former customers Third parties who have previously expressed an interest in our services Third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

EEA Data Subjects: Promotional Communications. We may use your personal information to send you updates (by email, text message, or post) about our products or services, including exclusive offers, promotions or new products or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at
• Our Email address
• Our Physical address
• Using the “unsubscribe” link in emails or “STOP” number in texts (where applicable) or

Who We Share Your Personal Information With. We routinely share personal information with:

• Our affiliates, including companies within JudeConnally.com
• Service providers we use to help deliver our products or services to you, such as payment service providers, warehouses, and delivery companies
• Other third parties we use to help us run our business, such as marketing agencies or website hosts, or catalog printing companies
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Personal Information We Sold or Shared. In the preceding 12 months, we have sold or shared the following categories of personal information:

• Identifiers (e.g., a real name, postal address, online identifier, Internet Protocol address, email address, account name)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, address, telephone number;
• Commercial information (e.g., records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, or behavior.

Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers (e.g., a real name, postal address, online identifier, Internet Protocol address, email address, account name;
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, address, telephone number;
• Commercial information (e.g., records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, or behavior.

How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf
• To show that we treated you fairly –or–
• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When we determine that it is no longer necessary to retain your personal information, we will delete or anonymize it.

Deletion, Correction and Removal of Personal Information: You have the right to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know, and request disclosure of: The categories of personal information we have collected about you, including sensitive personal information The categories of sources from which the personal information is collected The categories of third parties to whom we disclose personal information, if any –and– The specific pieces of personal information we have collected about you Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or– Provide the personal information to you more than twice in a 12-month period
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose	In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and– The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. To opt-out of the sale or sharing of your personal information please send your request by clicking this link or emailing us at privacy@judeconnally.com.
Right to Limit Use of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and– As authorized by further regulations You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, visit our homepage and click Cookiebot link in lower left corner and withdraw or change your consent.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records –and– Delete your personal information from our records –and– Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort Please note that we may not delete your personal information if it is reasonably necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes Debug to identify and repair errors that impair existing intended functionality Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law Comply with the California Electronic Communications Privacy Act 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us Comply with an existing legal obligation –or– Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation	You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: Deny goods or services to you Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties Provide a different level or quality of goods or services to you –or– Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

EEA Data Subjects: Your Rights Under the EU GDPR.

Right to Be Informed	The right to know or be notified about the collection and use of your personal information.
Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: At any time to your personal information being processed for direct marketing (including profiling) In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you may contact us by email at privacy@judeconnally.com or write to us as 320 S Michigan Avenue Kenilworth, New Jersey 07033 United States.

• Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
• If you choose to contact us directly by website, email, phone, or in writing, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
• A description of what right you want to exercise and the information to which your request relates.

• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
• Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

EEA Data Subjects: Where Your Personal Information is Held. Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

EEA Data Subjects: Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• With our offices outside the EEA
• With your and our service providers located outside the EEA
• If you are based outside the EEA –or–

These transfers are subject to special rules under European and UK data protection law.

Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

EEA Data Subjects: How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

• The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Changes to This Privacy Notice. This privacy notice was published on September21, 2023 and last updated on September 21, 2023.

We may change this privacy notice from time to time–when we do, we will inform you via our website.

How to Contact Us. Please contact us by post or email if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Jude Connally
320 S Michigan Avenue
Kenilworth, New Jersey 07033 United States
shopus@judeconnally.com

Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please see “How to contact us” above.