LAST UPDATED: FEBRUARY 8, 2022

This Privacy Policy describes how Metroflor Corporation (“Metroflor®”, “us”, “our”, or “we”) handles collection of information in regard to our services on www.metroflor.com. By accessing our Web Site, you consent to the collection, storage, use, and disclosure of the electronic information we collect about users of our Web Site, as described below. You can also contact us if you have any questions about our privacy practices.

Please review this privacy policy carefully. If you do not agree with any part of this Privacy Policy, please do not use our Web Site.

INFORMATION WE COLLECT AUTOMATICALLY

We may automatically log generic information about your computer’s connection to the Internet. This data consists of things such as IP address, operating system and type of browser software being used, and the activities conducted by the user while on our Web Site. An IP address is a number that lets computers connected to the Internet, such as our web servers, know where to send data back to the user, such as the pages of the Web Site the user wishes to view. We collect session data because it helps us analyze such things as: what items visitors are likely to click on most, the way visitors are clicking through the Web Site, how many visitors are surfing to various pages on the Web Site, how long visitors to the Web Site are staying and how often they are visiting. It also helps us diagnose problems with our servers and lets us better administer our systems. It is possible to determine from an IP address a visitor’s Internet Service Provider (ISP) and the approximate geographic location of his or her point of connectivity.

INFORMATION WE MAY COLLECT AUTOMATICALLY INCLUDES INFORMATION ABOUT:

• your device, including MAC address, the IP address, log information, device model, hardware model, IMEI number, serial number, subscription information, device settings, connections to other devices, mobile network operator, web browser characteristics, app usage information, sales code, access code, current software version, MNC, subscription information, and randomized, non-persistent and resettable device identifiers, such as Personalized Service ID (or PSID), and advertising IDs, including Google Ad ID;
• your use of our Web Site, including clickstream data, your interactions with our Web Site (such as the web pages you visit, search terms, and the apps, services and features you use, download, or purchase), the pages that lead or refer you to our Web Site, how you use our Web Site, and dates and times of use of our Web Site; and

COOKIES

We may also set cookies for your web browser as you visit our Web Site or use our services. A cookie is a small piece of information that is stored on a computer for the purpose of identifying the browser used during interaction with Web Sites. Cookies may be used to store items such as identifiers and user preferences. We may also use similar technologies, such as flash cookies (local stored objects for storing user preferences and navigation) and web beacons (small electronic files for maintaining user counts and website statistics).

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or visiting www.allaboutcookies.org. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your device. Our Web Site is not designed to respond to “do not track” signals received from browsers. Please note that without cookies, you may not be able to use or benefit from all of the features of our Web Site, device or computer or internet service used to access our Web Site.

We may use cookies for a number of purposes, including but not limited to:

• Access your information when you "log in" so we can provide you with customized content or remember the last page you visited on our Web Site.
• Keep track of preferences you specify while you are using our Web Site or our services.
• Deliver advertisements and content relevant to your interests.
• Collect information for general, internal purposes and for customer analytics.
• Conduct research to improve our content and our services.
• Support security measures, such as requiring re-logging into our Web Site after a certain amount of time has elapsed.
• Assist in identifying possible, fraudulent activities.

OTHER INFORMATION WE COLLECT

Other than the electronic information we collect from you as identified above, and transactional information based on your activities on the Web Site, we do not intentionally collect any other personal, non-public information directly from you, except for a provided zip code and valid email address.

If you choose to access and/or log in to our Web Site, you consent to the transfer and storage of any information we collect (as identified above) and any other information that you choose to provide us. We may collect and store some or all of the information identified above, as well as other information you choose to provide us, such as contact information and correspondence through our Web Site.

THIRD-PARTY WEB ANALYTICS SERVICES

Through our Web Site, we may collect personal information about your online activities on Web Sites and connected devices over time and across third-party Web Sites, devices, apps, and other online features and services. We may use third-party analytics services on our Web Site, such as Google Analytics. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of our Web Site or help administer our Web Site. To learn more about Google Analytics, please visit https://www.google.com/policie...;

ONLINE TRACKING AND INTEREST-BASED ADVERTISING

Because Metroflor Corporation participates in various advertising networks, you may also see our ads on other Web Sites or mobile apps. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests, and browsing context. These networks can track users’ online activities over time by collecting information through automated means, including through the use of browser cookies, web beacons, pixels, device identifiers, server logs, and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple Web Sites and apps, and to build a profile of users’ online browsing and app usage activities.

You agree and acknowledge that we may provide your email address, without your further, explicit consent, to any third-party marketing agencies that might send you, via email, updates about the products we offer and/or news about Metroflor Corporation. We will only provide your email address for such purposes in a manner that is consistent with the requirements of applicable law. We may combine your information with information we collect from other companies and use it to improve and personalize our services, content, and advertising.

HOW WE USE YOUR INFORMATION

We may use the information we collect for any of the following purposes:

• to provide our services to you;
• to operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• for customer service, security, to detect fraud or illegal activities, or for archival and backup purposes in connection with the provision of our services;
• to communicate with you;
• to better understand how users access and use our services, for the purposes of trying to improve the services and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users' usage of the services;
• to help us develop our new products and services and improve our existing products and services;
• to provide users with advertising and direct marketing that is more relevant to you;
• to enforce our Terms of Service or other applicable policies; and
• to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services. For example, personal information collected through our Web Site may be used to suggest particular content that can be made available to the user on another of our services or be used to try to present more relevant advertising in another of our services.

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We may share and disclose information as described at the time information is collected or as follows:

• to service providers that process payments, handle marketing communications, provide technical support, conduct surveys, or perform other services for us;
• to business partners when you have elected to receive communications from them;
• to business partners that engage in interest-based advertising;
• as required by law, such as to comply with a subpoena or other legal process, enforce our policies, or protect another person's rights or property. Such information will be disclosed in accordance with applicable laws and regulations;
• as necessary to process transactions and provide you with the services, products, or information you request or purchase;

• when we have a good faith belief that disclosure is necessary to protect the rights or property of our affiliates or us, or to protect the safety of you or others;
• to detect, prevent, or respond to potential fraud, intellectual property infringement, violations of our Terms of Service, violations of law, or other misuse of our services;
• to proceed with the negotiation or completion of a merger, acquisition, sale, or other transfer of all or part of our assets; or
• subject to your consent.

INFORMATION STORAGE AND SECURITY

We retain information as long as it is necessary and relevant for our operations. We also retain personal information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies.

We maintain safeguards designed to protect personal information we obtain through our Web Site. Appropriate controls such as restricted access are placed on our computer systems. We limit access to our computer systems to select employees that are required to access personal information to perform their job. We also use safeguards such as limiting IP and two-factor authentication to further control access. In relation to online payments made through our Web Site, we leverage a hosted PCI compliant solution through Braintree. We also perform regular testing and code reviews on our Web Site.

Please note, however, the security of information transmitted
through the internet can never be guaranteed. We are not
responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of our Web Site are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of our Web Site, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of our Web Site are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution. Whilst we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk.

YOUR RIGHTS

It is important to us that you are able to access and review the personal information we have about you and make corrections to it or delete it, as necessary. You can visit your account to manage and correct the information we have on file about you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us.

Our Web Site may offer choices related to the collection, deletion, and sharing of certain information and communications about products, services, and promotions that are unique to specific services. You can access the relevant settings of each service to learn about choices that may be available for that service. If you decline to allow our Web Site to collect, store, or share certain information, you may not be able to enjoy full use of all of the features available through our Web Site.

LINKS TO THIRD PARTY SERVICES

Our Web Site may contain links to third-party Web Sites and services (“Third Party Services”) with which we have no affiliation. A link to any Third Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to its privacy policy and practices and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

DISCLAIMER: NOT CHILD-DIRECTED

This Web Site is not intended for use by children. If you are under the age of majority in your place of residence, you may use the Web Site only with the consent of or under the supervision of your parent or legal guardian.

Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Web Site and subsequently we will delete that information.

We may amend this Privacy Policy at any time by posting the amended terms on this Web Site. All amended terms automatically take effect 30 days after they are initially posted on the Web Site, unless we state such terms take effect at an earlier date. By using our Web Site, you agree that you are responsible for checking back here regularly in order to determine whether changes have been made to this Privacy Policy which may impact you.

NOTICE TO CALIFORNIA RESIDENTS

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called California Consumer Privacy Notice below.

CALIFORNIA CONSUMER PRIVACY NOTICE

This California Consumer Privacy Notice supplements our Privacy Policy for the U.S. It applies solely to California consumers and addresses personal information we collect online and offline. This Notice does not apply to our personnel or job applicants.

This California Consumer Privacy Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, bank account number, credit card number, debit card number, and other financial information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as age and sex
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with Web Sites, applications, or advertisements

• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• We may use the categories of personal information listed above for certain business or commercial purposes, as described in this list:
• performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.
• auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
• short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• debugging to identify and repair errors that impair existing intended functionality; and
• undertaking internal research for technological development and demonstration

YOUR RIGHTS

As a California resident, you have certain choices regarding our use and disclosure of your personal information, as described below:

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

Statistics: Your have the right to request metrics relating to consumer privacy rights requests we received last year.

Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.

You can exercise any of these rights by contacting our legal team in writing by email or post using the details outlined below. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information. In all communications, please include the email address used for registration (if applicable), the Web Site address, mobile application, or the specific Metroflor Corporation program to which you provided personal information and a detailed explanation of your request. If you would like to delete, amend, or correct your personal information and are contacting us by email, please put “Deletion Request” or “Amendment/Correction Request” in the subject line of the email. We will respond to all reasonable requests in a timely manner and may need to further confirm your identity in order to process certain requests.

Our email is legalteam@hmtx.global

Our registered address is:
Legal Team
HMTX Industries LLC
29 Oakwood Avenue
Norwalk CT, 06850

VERIFYING REQUESTS

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.

Should you exercise any of your privacy rights as a California resident, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. Certain services, however, may require your consent to have your personal information shared with us to provide the service or to allow us to use and disclose your Personal Information to provide the service. When you exercise your rights, you may lose access to certain aspects of our services that require your personal information to perform the service.

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