Privacy Policy

This Privacy Policy (this “Policy”) describes the privacy practices of KLN Neat with respect to information collected when you sign up for, use, access, or otherwise interact with www.klnneat.com (the “Site”) and any online services and products of KLN Neat, including mobile applications and websites or applications operated by KLN Neat and connected products and services (collectively, including the Sites, the “Services”) that reference this Policy, and how we use and share that information. By using the Services (including the Sites), you consent to the terms of this Policy.

You can reach us at support@klnneat.com if you have further questions.

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE, AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY.

Personal Data we collect may be stored and processed in Canada, the United States, or any other country in which KLN Neat or its affiliates, subsidiaries, agents, or third-party service providers maintain facilities and/or infrastructure, and by using the Services and submitting information to us, you consent to the transfer, processing, and storage of such information outside of your country. Note that Canada is a jurisdiction in which the data protection regime may not provide the same level of security as those in the nation where you reside. Unless applicable law requires different security and protections to be applied in any given relevant jurisdiction, we apply the same principles in using, handling, and transmitting data as described in this Privacy Policy in all of our operations. If you do not agree with any part of this Privacy Policy or our Terms and Conditions, please do not access or continue to use any of the Services or otherwise provide your Personal Data.

This Policy covers the following areas:

Information We Collect How We Use Your Information III. How We Share Your Information

Data Security Data Retention Cookies and Other Data Collection Tools VII. How To Manage Your Privacy Settings

VIII. Children

Region-Specific Disclosures Third Parties We Don’t Own or Control How to Contact Us XII. Amendments

Information We Collect KLN Neat collects information from users in connection with the Services. We collect both Personal Data and Non-Personal Information. “Personal Data” means information that relates to you and identifies you personally, either alone or in combination with other information available to us. Examples of Personal Data are a name, an online identifier, a contact address, social media reviews and ratings, and precise Location Data. “Non-Personal Information” means information that is aggregate, anonymous, practicably de-identified, or otherwise does not reveal your identity. Some examples could include age, annual income, gender, browser, IP addresses, hardware model, operating system and version, time spent using our Services, web pages visited, and advertising identifiers (such as the Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID)).

We collect your Personal Data and Non-Personal Information as follows:

If you register for a KLN Neat account, install or use our mobile apps, or place an order, we collect directly or indirectly (such as through a third-party application) certain registration and demographic details (e.g., name, username and password, email address, phone number, date of birth, personal interests and location (e.g., country) and other similar details (“Account Information”).

When interacting with our Services, data is automatically collected by the technology platforms providing the experiences, including without limitation information about the Sites that you visit and how you use them and any GPS-based, Wi-Fi-based, or cell-based location information (“Location Information”), and any other identifier that permits direct identifying, locating, or contacting of the device or user. Your web browser or mobile device may share certain data with KLN Neat as those devices interact with KLN Neat’s Sites or mobile apps. This data includes: Device IDs, network access, storage information and battery information as well as cookies, IP addresses, referrer headers, data identifying your web browser and version, the date and time of the visit and how long you remained on our Sites, and web beacons and tags. Location Data may include the presence of the device, its signal strength and mobile network information, its manufacturer (Apple, Samsung, etc.) and model, and information about the device’s interaction with the Services or business services. KLN Neat may combine this information with other information collected in connection with your use of the Services. More information about these practices is included in the Cookies and Other Data Collection Tools section below.

If you engage with us through a social media account, we may collect account or profile information associated with that account. To the extent you connect an account managed by third parties such as social media sites (e.g., Facebook) with a KLN Neat account, you authorize KLN Neat to have access to information related to that account (as permitted by the terms of service of your account with that social media site) and agree that KLN Neat may collect, store, and use such information in accordance with this Policy.

If you are accessing third-party products and services that we have made available to you via the Services, we may collect your name, email address, city, payment information, and more, in connection with your registration for and access to those products and services.

When you purchase or browse KLN Neat products online, we collect purchase and browsing data. As you browse our products online or submit product inquiries, we may collect Personal Data such as your contact information and your specific requests. We also may collect information regarding a completed purchase (payment amounts and methods, billing and shipping information, returns and other transaction information). Non-Personal Information relating to your browsing of our products (such as browsing order and products removed from a shopping cart) may also be collected. We may associate purchase and browsing information with an account you have registered with us and combine it with information relating to all interactions with us.

When you shop at KLN Neat pop-up stores, we may collect contact and purchase information. When you are shopping at a KLN Neat pop-up store we collect any contact and purchase information that is necessary to process your transaction. For example, we may collect payment information and email address (to provide e-receipts). In addition, if you consent and where permissible, we may collect your email and phone number(s) in order to send you information about products and Promotions.

If you participate in or utilize, as applicable, contests, sweepstakes, loyalty programs, surveys, discounts, or promotional sales (“Promotions”) being offered by KLN Neat, we may collect contact, demographic and eligibility information or other Personal Data. In such instances, Personal Data may be collected directly by and/or shared with KLN Neat, the service provider and/or business partner via print, website, mobile applications or other means. Personal Data associated with a Promotion may be shared with partners that sponsored or were involved with the Promotion.

We collect Personal Data relating to your interactions with advertising on the Services or KLN Neat online communities. We may collect your Personal Data when you click on advertisements, submit content, make reviews, interact with our social media pages, or otherwise contribute to message boards, comment fields, blogs, and other media forums sponsored by or affiliated with KLN Neat.

We allow our trusted ad partners to collect information about you when you use our Services. These companies may collect information from you (e.g. subject of advertisements clicked or scrolled over) during your visits to the Services in order to provide advertisements about goods and services likely to be of interest to you. Our ad partners may use the data they collect from you for a variety of other purposes, including (a) in conjunction with advertising that appears on other websites, (b) to determine the popularity of certain content and analyze and track website traffic, statistics, advertisement data and other interaction with ads and the websites on which they are served, and (c) to measure the effectiveness of web-based and email ads. The ad partners that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

How We Use Your Information We use the information we collect to:

Provide our products and services and customer support.

We use Personal Data and Non-Personal Data to process and deliver product orders and to notify you of the status of your order. Additionally, this data may be used to troubleshoot problems with your experience with the Services. If you contact our customer service (or vice versa), we will use Personal Data such as your order information and contact history to process your request and provide you with the best service possible.

Customize experiences on our Services and gain insights into our customers and communities.

We use Personal Data and Non-Personal Data to present products and content tailored to you, your interests and location. Our use of Personal Data may also help you engage with other users of our Services. We also use Personal Data to better understand our customers and other individuals who access our Services which helps us develop more interesting and relevant products and services and to improve our Services.

Promote KLN Neat’s business through direct mail and online advertising and marketing activities to you and others.

We use Personal Data and Non-Personal Information in connection with advertising and online and offline marketing campaigns, to provide you with information on the products and Services that we think are most relevant to or appropriate for you and to track the success of our marketing activities. We display ads on the online platforms that we own and operate. We also use third party ad partners to display ads for KLN Neat on third party websites and apps (“Retargeting”). Retargeting technologies analyze the information collected about your interactions with KLN Neat Sites as described in relation to marketing above and information about you obtained from reputable third party sources parties, including your cookies, and display advertisements matched to your interests, as inferred from your online activities. Ads may also be based on the content of the pages on which they appear and Location Data may be used to serve ads that are more relevant to you based on your particular location. For most devices, you can control the interest-based ads you see as a result of Retargeting by changing the privacy settings of the device itself or changing the privacy settings of your browser but note that our Sites generally are not configured to respond to web browser do-not-track signals.

Connect you with third-party products and services.

We use the data we collect to provide third parties with the information required to enable those third parties to fulfill products or services that a KLN Neat user has ordered.

Communicate with you.

If you have created an account with us, and consent to receiving messages from us via electronic communications, we may use Personal Data and Non-Personal Information to contact you about the KLN Neat products or Services you have purchased or used and to notify you of other products, promotions and Services we think may be of interest to you. We may use your information to respond to requests for support, online services, product information or to any other interaction you initiate. We also may use your Personal Data to notify you of promotions and other special offers. Irrespective of your privacy settings, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to products or Services you have purchased or use.

Administer Promotions.

In connection with Promotions we may use Personal Data to verify identity, communicate with you about the Promotion or about other offers, conduct market research, and ask you questions relating to the Promotion. If you participate in questions and surveys regarding the Promotion we may share your responses with business partners for their own market research and communication purposes. To opt-out of this kind of collection and sharing, you can decline to answer these kinds of questions or decline to participate in the challenge or survey altogether.

Operate and analyze our business.

We use Personal Data and Non-Personal Information to analyze trends and statistics and otherwise monitor usage and performance of the Services, engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving KLN Neat, comply with any applicable legal or regulatory requirements, and for sales, supply chain and financial analysis purposes.

Resolve security issues and disputes.

We use the data we collect from you to protect the integrity of our Services, employees and users, to identify and prevent error, negligence and fraud, to audit compliance with and enforce our agreements (such as terms of use, terms of sale and this Privacy Policy), and to resolve disputes.

We may augment Personal Data we collect from you with information provided by reputable third party sources.

We may combine Personal Data with information we receive from joint marketing partners, public databases, publicly available pages on social media platforms and other third parties, to give us better consumer insight into your needs, help us tailor our communications with you, deliver marketing messages to you and improve our business. For example, we may obtain updated email address information from email-change-of-address vendors or purchase third-party marketing data and address information and add it to our database to send you offline marketing materials, better direct our advertising and provide pertinent offers we think you are more likely to be interested in. You can opt-out of us combining your personal information with the information lawfully collected from third parties by contacting us using the contact details set out below.

How We Share Your Information KLN Neat will share your Personal Data and Non-Personal Information with third parties in the following ways:

To Partners and Suppliers.

KLN Neat may (a) coordinate the provision of services and products to you through third party service providers and (b) partner with third parties in order to promote, support, enable or expand KLN Neat’s business and products and services or enable those third parties to deliver content or advertise the products and services of KLN Neat. We may share Personal Data with those service providers and partners and they may have access to or process your Personal Data. For example, KLN Neat may use third-party providers to assist us with delivering, marketing and advertising our products and Services, processing payments you make to us, delivering customer service and support, and for e-commerce order fulfillment. In addition, with your knowledge and consent, our Services may gather and transfer information from other applications, functions and tools within your mobile device.

With Social Networks.

Our Sites and apps will, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network such as Facebook or Twitter (for example by registering an account), your activity on Sites or via our apps will also be made available to that social network.

For Joint Marketing.

From time to time, KLN Neat might establish joint marketing relationships with other persons or entities whom we believe trustworthy and have privacy practices that are consistent with ours. In such cases and where permitted by applicable law we might exchange, share and/or cross-reference information, including information about you that will enable such persons or entities to contact you regarding products and services that may be of interest to you. If you would like to opt out of our exchange of your information with other marketers, please let us know by writing to our Support Team.

In Discussion Forums.

Content you post through the Services such as reviews, commentary on discussion boards or blogs, and certain social networking preferences (e.g. pages you “Like” or “Recommend”) may be accessible by other users and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. KLN Neat cannot ensure the privacy of any Personal Data included in such user generated content. Please note that KLN Neat does not necessarily verify, endorse, or agree with any content posted in discussion forums.

In Business Transfers (country specific disclosures may apply).

In the event that KLN Neat sells certain of its assets or goes through a structural change, such as a merger, acquisition by another company, bankruptcy, insolvency, or dissolution, to the extent permitted by applicable law Personal Data may be transferred to a third party as part of such event and thereby become subject to the privacy practices of that third party, which may materially different than those of KLN Neat.

With Your Consent.

KLN Neat will share your Personal Data with other third parties (different from those described in this section) in certain limited circumstances. In these instances we will, to the extent required by applicable law, obtain your consent to share your Personal Data in this way.

For Legal Compliance and Special Circumstances.

We may be required, subject to applicable law, to disclose your Personal Data if: (i) it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority, (ii) such a disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) it is necessary to protect our legal rights or property (such as enforcing or applying applicable terms and conditions and other agreements, including the Services’ terms of service), or (iv) it is necessary to protect the legal rights or property or physical security of others, or for the prevention or detection of crime and such disclosure is lawful.

Data Security KLN Neat takes precautions to secure your personal information and protect it from loss, theft, unauthorized access, destruction, use, modification and disclosure. Such measures include technological, physical and organizational safeguards that are appropriate given the sensitivity of the personal information, including maintaining controlled access to electronic and paper documents and files, and using appropriate technology safeguards such as passwords firewalls and encryption as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your data. However, please note that KLN Neat’s security measures may change or be unavailable from time to time and no data transmission over the Internet or any wireless network is 100% secure.

Data Retention KLN Neat will retain Personal Data for so long as it continues to be useful in connection with providing or improving KLN Neat’s Services and product offerings and this Policy, except if required otherwise by applicable law. We may further retain and use data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Cookies and Other Data Collection Tools KLN Neat and its partners use various technologies to collect information when you use our Services, including sending cookies to your device and using web beacons. By using the Services you consent to the use of such technologies, including cookies and pixel tags, to collect information about you. These technologies help us personalize your use of our Sites and mobile applications, customize the Services, and mitigate risks and the potential for fraud. These technologies are also used by KLN Neat and its advertising partners to deliver ads to you based on your interests and online activities.

How We Use Cookies. When you access or use the Services, our web server may send a cookie to your device. “Cookies” are small data files placed on a device’s hard drive or memory when you interact with a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may use cookies to:

Remember that you have visited us or used the Services before and personalize our content for you and remember your preferences (for example, your choice of language or region).

Ensure we have enough capacity to accommodate all of our users and that users are finding what they are looking for easily and do not encounter technical errors.

Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users

Helps us and our ad partners to deliver ads or messages that are relevant to you and your interests. We may also share this information with third parties for this purpose. For example, these cookies allow us to identify and send you messages about items you have left in your cart and make other purchasing recommendations.

We Use Third-Party Cookies. We may allow third parties to collect information via the Services through cookies, third party plug-ins and widgets. Third party cookies enable third party features or functionality to be provided on or through the Sites (e.g., advertising, interactive content and analytics). These third parties may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. We do not provide any Personal Data to these third parties, but they may collect information about where you, or others who are using your device, saw and/or clicked on the advertisements they deliver, and possibly associate this information with your subsequent visits to the advertised websites.

How to Manage Cookies. Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers. By blocking or deleting cookies used on our Services, you may not be able to take full advantage of our Services. You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com).

How We Use Web Beacons. Some of our web pages and electronic communications may contain images called “web beacons” (also known as clear gifs) that allow us to count users who have visited those pages and to deliver co-branded services. Web beacons collect limited, non-personally identifying information (such as IP address, browser type, time of visit, and page visited) and cannot be used to access personal information. We use web beacons to compile aggregated statistics and analyze how our Services are used, and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

How To Manage Your Privacy Settings If you wish to opt-out of receiving marketing communications from us, modify your information or change your privacy preferences, please contact us using the contact details below. You can unsubscribe from our marketing emails by clicking on the unsubscribe link which we include in all our marketing emails. If you have created an online account or registered for an online service, you can usually update your account settings online. You also have choices about cookies, as described above. By changing your settings, you can also review, modify or request deletion of the Personal Data that we hold about you.

Children Our Services are not directed at children under the age of 13 and we do not knowingly collect Personal Data from children under the age of 13. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us using the information provided below and we will take steps to delete such Personal Data from our systems.

Region-Specific Disclosures EU/EEA and UK Residents. If you are a resident of the European Union (EU), European Economic Area (EEA) or the United Kingdom (UK), you have certain rights and protections under applicable law regarding the processing of your Personal Data.

Legal Basis for Processing. When we process your Personal Data, we will do so in reliance on the following lawful bases:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you requested).

When we have a legitimate interest in processing your Personal Data (e.g., to improve our Services, for audits, fraud prevention and security, enhancing, modifying or personalizing our services and communications, analyzing the effectiveness of our marketing and advertising, and operating and expanding our business activities).

To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).

With your consent (e.g., for certain direct marketing communications or for the collection of certain location information).

Data Subject Requests. You have the right to access Personal Data we hold about you and to ask that your Personal Data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.

Questions or Complaints. If you are a resident of the EU, EEA or UK and have a concern about our processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Third Parties We Don’t Own or Control This Policy applies to the Services offered by KLN Neat, but excludes services that have separate privacy policies that do not incorporate this Policy.

Please note that the Services may link to other websites and services operated by third parties, and that we are not responsible for the content or privacy practices of those services. We encourage users to be aware when they leave the Services and to read the privacy policies of each website and service with which they interact. This Policy applies solely to information collected by us through the Services and does not apply to these third-party websites and services.

How to Contact Us If you have any questions about this Policy, or if you would like to exercise any of your rights as described in this Policy, you may contact us at support@klnneat.com.

Amendments KLN Neat reserves the right to modify this Policy from time to time. If we make any changes to this Policy, we will change the “Last Revision” date below and will post the updated Policy on this page. If you object to any changes, you may close your account. Continuing to use the Services after we publish changes to this Policy means that you are consenting to the changes.

Last Revision: February 28, 2024