Last Updated: May 8, 2025

INTRODUCTION

Your privacy is important to us at A Devil’s Kiss, Inc. and its subsidiaries and affiliates (collectively, “ADK,” “Company,” “we,” “us,” or “our”). We are committed to safeguarding, preserving, and respecting your privacy rights. As a California resident, you have specific rights regarding the collection, use, transfer, and processing of your personal information under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) and implementing regulations.

This California Privacy Policy (“Policy”) describes how we collect, use, share, disclose, retain, and secure the personal information we gather about you through our website, adevilskiss.com, our mobile applications, when you interact with us as a customer, or through other means (collectively, the “Services”).

We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.

WHAT INFORMATION DO WE COLLECT?

The below examples are illustrative and based on CCPA definitions. They do not necessarily reflect specific pieces of information we collect about you personally.

In the previous 12 months, we have collected the following categories of personal information:

Category*	Examples	Collected	Retention Period
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Yes	For the duration of the customer relationship plus 2 years, or as required by law
B. Personal Information	A name, signature, physical characteristics or description, address, telephone number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.	Yes	For the duration of the customer relationship plus 2 years, or as required by law
C. Protected Classification Characteristics	Age (40 years or older), gender, gender identity, gender expression.	Yes	For the duration of the customer relationship plus 2 years, or as required by law
D. Commercial Information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	For the duration of the customer relationship plus 2 years, or as required by law
E. Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information.	No	N/A
F. Internet or Other Similar Network Activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes	18 months
G. Geolocation Data	Physical location or movements.	Yes	18 months
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A
I. Professional or Employment-Related Information	Current or past job history or performance evaluations.	No	N/A
J. Non-Public Education Information	Education records directly related to a student maintained by an educational institution or party acting on its behalf.	No	N/A
K. Inferences Drawn of the Consumer	Inferences drawn from personal information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, predispositions, behavior, attitudes, and aptitudes.	Yes	18 months
L. Sensitive Personal Information	Personal information that reveals a consumer’s account log-in credentials, financial account details, precise geolocation, or contents of private communications; personal information concerning a consumer’s sex life or sexual orientation.	Yes	For the duration of the customer relationship plus 2 years, or as required by law

*Categories of personal information are as defined in Cal. Civ. Code. § 1798.140(v)

SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED

We collect your personal information from the following sources:

• Directly from you when you provide it to us (e.g., when creating an account, making a purchase, or contacting customer service)
• Automatically through your interaction with our website and mobile applications
• From third-party service providers and partners who collect information on our behalf
• From publicly available sources

BUSINESS OR COMMERCIAL PURPOSES FOR COLLECTING PERSONAL INFORMATION

Your personal information is used for the following purposes:

• To provide, maintain, and improve our Services
• To process your transactions and fulfill your orders
• To create and manage your account
• To personalize your experience and deliver content relevant to your interests
• To communicate with you about products, services, offers, and events
• To provide customer support and respond to your inquiries
• To analyze usage patterns and improve our website and applications
• To protect against fraudulent transactions and enhance security
• To comply with legal obligations
• To advertise and market our products and services to you

THIRD PARTIES WITH WHOM PERSONAL INFORMATION IS DISCLOSED, SHARED, OR SOLD

Disclosure for Business Purposes

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes:

• Category A (Identifiers) with service providers and affiliated companies
• Category B (Personal Information) with service providers and affiliated companies
• Category C (Protected Classification Characteristics) with service providers
• Category D (Commercial Information) with service providers and affiliated companies
• Category F (Internet Activity) with service providers
• Category G (Geolocation Data) with service providers
• Category K (Inferences) with service providers
• Category L (Sensitive Personal Information) with service providers (limited to what is necessary for service provision)

Sharing for Cross-Context Behavioral Advertising

In the preceding 12 months, we have shared the following categories of personal information for cross-contextual behavioral advertising:

• Category A (Identifiers)
• Category F (Internet Activity)
• Category G (Geolocation Data)
• Category K (Inferences)

Sale of Personal Information

In the preceding 12 months, we have not sold personal information for monetary consideration. However, our use of cookies and other tracking technologies may be considered a “sale” under the CCPA’s broad definition. Categories of personal information that may be sold under this definition include:

• Category A (Identifiers)
• Category F (Internet Activity)
• Category G (Geolocation Data)
• Category K (Inferences)

Categories of third parties to whom this information may be sold include:

• Data analytics providers
• Advertising networks
• Marketing partners
• Social media platforms

SENSITIVE PERSONAL INFORMATION

We limit our processing of sensitive personal information to purposes specifically authorized under California law, and in a manner that is necessary and proportionate for those purposes. We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027 of the CCPA regulations.

MINORS’ PERSONAL INFORMATION

We do not knowingly collect, process, sell, or share the personal information of consumers under 18 years of age. If we learn that we have collected personal information from a child under 18, we will promptly delete that information.

YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you have the following rights:

1. Right to Know About Personal Information Collected, Disclosed, Shared, or Sold

You can request that we disclose:

• Abbreviated Request: Categories of personal information collected, sold, or shared; categories of sources; categories of third parties; and business purposes.
• Specific Pieces Request: The specific pieces of personal information we have collected about you.

You may submit these requests twice in a 12-month period at no charge.

2. Right of Deletion

You can request that we delete personal information we have collected about you, subject to certain exceptions permitted by law.

3. Right to Correct Inaccurate Information

You can request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the information and the purposes of processing.

4. Right to Opt-Out of Sale or Sharing of Personal Information

You can direct us not to sell or share your personal information for cross-context behavioral advertising purposes.

5. Right to Limit Use and Disclosure of Sensitive Personal Information

When applicable, you can limit the use and disclosure of your sensitive personal information to purposes specified under California law.

6. Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your privacy rights. We will not:

• Deny goods or services to you
• Charge different prices or rates for goods or services
• Provide a different level of quality of goods or services
• Suggest that you will receive different treatment for exercising your rights

HOW TO EXERCISE YOUR RIGHTS

Submitting Requests

You can submit your privacy rights requests through any of these methods:

1. Email: Kellie@ADevilsKiss.com

Do Not Sell or Share My Personal Information

To opt out of the sale or sharing of your personal information, including for cross-context behavioral advertising, you can:

• Click on the “Your Privacy Choices” link found in the footer of our website
• Use the Global Privacy Control (GPC) signal through your browser or device settings

Please note that opt-out choices may be stored via cookies. If you clear cookies, block cookies, or visit our site from a different device or browser, you may need to renew your opt-out choices.

Verifying Your Identity

To protect your personal information, we must verify your identity before processing your requests. Depending on the type of request, we may:

• Ask you to provide 2-3 pieces of personal information to match against our records
• Require you to sign a declaration under penalty of perjury
• Use more stringent verification methods for requests for specific pieces of information

We will only use the information you provide for verification purposes and will delete it after processing your request.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. Authorized agents must:

1. Be registered with the California Secretary of State
2. Provide proof of your written permission to act on your behalf
3. Verify their own identity with us

We may deny requests from agents who do not meet these requirements.

RESPONSE TIMING AND FORMAT

We will respond to verifiable consumer requests within 45 calendar days. If we need more time (up to an additional 45 days), we will inform you in writing of the reason and extension period.

We will deliver our response to your verified request free of charge and in a readily usable format that allows you to transmit the information to another entity.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this California Privacy Policy at any time. Any changes will be effective immediately upon posting the updated Policy on our website. We encourage you to review this Policy periodically.

CONTACT INFORMATION

If you have any questions or concerns about this California Privacy Policy or our privacy practices, please contact us:

• Email: Kellie@ADevilsKiss.com
• Phone: 484-441-3213