California Consumer Privacy Act

Privacy Notice for California Residents

Last revised: Dec. 31, 2019

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who use the Site and reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Protecting your privacy is important to Spigen, Inc., and its subsidiaries and affiliates (“Spigen,” “CYRILL,” “Ciel by CYRILL,” “we,” “our,” or “us”) because we know how important it is to you. This Privacy Notice describes the information that we collect through websites that we operate (each, a “Site”) how we use, disclose, and protect your information; and the choices you can make regarding your information.

1. INFORMATION WE COLLECT

   We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, through your use of the Sites, wehave collected the following categories of personal information within the last twelve (12) months:

   Category	Examples	Collection		Disclosure		Sales
   		Does Spigen collect?	Collected in past 12 months	Disclosure for business purpose	Disclosure for business purpose in 12 months	Does Spigen sell?	Sold in past 12 months
   A. Identifiers	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	Does Spigen collect?YES	Collected in past 12 monthsYES	Disclosure for business purposeYES	Disclosure for business purpose in 12 monthsYES	Does Spigen sell?NO	Sold in past 12 monthsNO
   B. Personal information categories listed in Cal. Civ. Code § 1798.80(e)	A 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	Does Spigen collect?YES	Collected in past 12 monthsYES	Disclosure for business purposeYES	Disclosure for business purpose in 12 monthsYES	Does Spigen sell?NO	Sold in past 12 monthsNO
   C. Protected classification characteristics under California or federal law	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	Does Spigen collect?YES	Collected in past 12 monthsYES	Disclosure for business purposeYES	Disclosure for business purpose in 12 monthsYES	Does Spigen sell?NO	Sold in past 12 monthsNO
   D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Does Spigen collect?YES	Collected in past 12 monthsYES	Disclosure for business purposeYES	Disclosure for business purpose in 12 monthsYES	Does Spigen sell?NO	Sold in past 12 monthsNO
   E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	Does Spigen collect?NO	Collected in past 12 monthsNO	Disclosure for business purposeNO	Disclosure for business purpose in 12 monthsNO	Does Spigen sell?NO	Sold in past 12 monthsNO
   F. Internet or other electronic network activity information	Browsing history, search history, and information on a consumer’s interaction with an Internet Web site, application, or advertisement	Does Spigen collect?YES	Collected in past 12 monthsYES	Disclosure for business purposeYES	Disclosure for business purpose in 12 monthsYES	Does Spigen sell?NO	Sold in past 12 monthsNO
   G. Geolocation data	Physical location or movements	Does Spigen collect?YES	Collected in past 12 monthsYES	Disclosure for business purposeYES	Disclosure for business purpose in 12 monthsYES	Does Spigen sell?NO	Sold in past 12 monthsNO
   H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	Does Spigen collect?NO	Collected in past 12 monthsNO	Disclosure for business purposeNO	Disclosure for business purpose in 12 monthsNO	Does Spigen sell?NO	Sold in past 12 monthsNO
   I. Professional or employment-related information	Current or past job history or performance evaluations	Does Spigen collect?NO	Collected in past 12 monthsNO	Disclosure for business purposeNO	Disclosure for business purpose in 12 monthsNO	Does Spigen sell?NO	Sold in past 12 monthsNO
   J. Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	Does Spigen collect?NO	Collected in past 12 monthsNO	Disclosure for business purposeNO	Disclosure for business purpose in 12 monthsNO	Does Spigen sell?NO	Sold in past 12 monthsNO

   Personal information does not include:

   • Publicly available information from government records;
   • De-identified or aggregated consumer information;
   • Information excluded from CCPA’s scope, like personal information protected by othercertain sector-specific federal or California statutes.
2. HOW WE COLLECT PERSONAL INFORMATION

   We obtain the categories of personal information listed above from the following categories of sources:

   • Directly From You: The information you provide while using the Sites.
   • Indirectly From You: We collect certain technical information, like the Internet Protocoladdress, when you access and use our Sites.
   • Collected and/or Received From Third Parties: We may collect your data from third parties, such as from the third party platforms we use to help us improve the user experience or when processing your purchases.
3. HOW WE USE PERSONAL INFORMATION

   We may use the personal information we collect for one or more of the following purposes:

   • To fulfill or meet the reason you provided the information;
   • To provide, support, and personalize our products and services for and through our Sites;
   • To create, maintain, and service accounts;
   • To provide customer service;
   • To process your requests and payments, and fulfill orders and transactions;
   • To verify consumer information;
   • To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Sites and via mail or email (with your consent, where required by law);
   • To provide advertising and marketing services;
   • To provide analytic services;
   • To detect and respond to security incidents or policy violations;
   • To improve our Sites;
   • For testing, research, analysis, and product development;
   • For auditing related to a current interaction with the user and concurrent transactions, including but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
   • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
   • To establish, exercise, or defend legal claims or as otherwise permitted by law;
   • As described to you when collecting your personal information or as otherwise set forth in the CCPA;
   • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CYRILL’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CYRILL about our Sites’ users is among the assets transfers.

   CYRILL will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. SHARING PERSONAL INFORMATION

   CYRILL may disclose your personal information to a third party for a business purpose. When we disclose your personal information for a business purpose, we enter a contract thatdescribes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract.

   In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

   Category A:	Identifiers
   Category B:	Personal information categories listed in Cal. Civ. Code § 1798.80(e)
   Category C:	Protected classification characteristics under California or federal law
   Category D:	Commercial information
   Category F:	Internet or other electronic network activity information
   Category G:	Geolocation data
   Category K:	Inferences drawn from any of the information identified above

   We disclose your personal information for a business purpose to the following categories of third parties:

   • Our affiliates;
   • Our Partners
   • Service providers;
   • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

   In the preceding twelve (12) months, we have not sold any personal information.

5. DATA SECURITY

   We have implemented measures designed to secure and safeguard your personal information from accidental loss and from unauthorized access and disclosure. We maintain physical, electronic, and administrative procedures to limit access to your non-public personal information.

   Unfortunately, transmission of information via the internet is not completely secure. Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our Sites or other electronic means. Any electronic transmission of personal information is at your own risk.

6. YOUR RIGHTS AND CHOICES

   The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

   Access to Specific Information and Data Portability Rights
   You have the right to request that we disclose certain information to you about our collectionand use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

   • 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 specific pieces of personal information we collected about you (also called a dataportability request);
   • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
     • sales, identifying the personal information categories that each category of recipients purchased; and
     • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

   Deletion Request Rights
   You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirmyour verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

   We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

   • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
   • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
   • Debug products to identify and repair errors that impair existing intended functionality;
   • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
   • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
   • 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
   • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
   • Comply with a legal obligation;
   • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

   Exercising Access, Data Portability, and Deletion Rights
   To exercise the access, data portability, and deletion rights described above, please submit averifiable consumer request to us by either:

   • Visiting www.cyrillcase.com
   • Emailing us at support@cyrillcase.com

   Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

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

   • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
   • 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 the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will use only personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

   Response Timing and Format
   We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

   Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7. NON-DISCRIMINATION

   We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

   • Deny you goods or service;
   • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
   • Provide you a different level or quality of goods or services;
   • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

   However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

8. CHANGES TO OUR PRIVACY NOTICE

   CYRILL reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will update the Privacy Notice’s effective date, notify you via email at the last email address that you provided us, andpost the updated notice on the Sites. Your continued use of our Sites following the posting of changes constitutes your acceptance of such changes.

9. CONTACT INFORMATION

   If you have any questions or comments about this Privacy Notice, the ways in which CYRILL collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact usat: