Thank you for visiting Gary Loks, LLC, an online service (e.g., website or mobile app), that posts a link to this Privacy Policy (“Service”) that is owned and operated by Gary Loks, LLC, Inc. (referred to herein as “Company”, “We” or “Our”). This Privacy Policy will provide you with information as to how Company collects, uses, and shares information about you, including choice Company offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to Company’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you. By visiting or otherwise using the Service, you agree to the Service’s and consent to Company’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.

1. INFORMATION WE COLLECT.

2. Information About You that You Provide.

Company, and/or its Service Providers (defined below), may collect information you provide directly to Company and/or its Service Providers via the Service. For example, Company collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices. For more information on Service Provider data collection and practices. Information that Company, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personal Information”); and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases (“Demographic Information”). Except to the extent required by applicable law, Demographic Information is “non-Personal Information” (i.e., data that is not Personal Information under this Privacy Policy). In addition, Personal Information, including, without limitation, Company-Collected PI (defined below), once “de-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) is also non-Personal Information and may be used and shared without obligation to you, except as prohibited by applicable law. To the extent any non-Personal Information is combined by or on behalf of Company with Personal Information Company itself collects directly from you on the Service (“Company-Collected PI”), Company will treat the combined data as Company-Collected PI under this Privacy Policy.

1. Information Collected Automatically.

Company, and/or its Service Providers (defined below), may collect information you provide directly to Company and/or its Service Providers via the Service. For example, Company collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices. For more information on Service Provider data collection and practices.

Company, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Company with Company-Collected PI, Company does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Company-Collected PI. For more information on Third-Party Services’ data collection and practices. For more information on Service Provider data collection and practices click. For information on choices some of these third parties may offer you regarding automated data collection. The methods that may be used on the Service to collect Usage Information include:

Log Information:

Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.

Information Collected by Cookies and Other Tracking Technologies:

Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior. Here is more detail of types of Tracking Technologies:

Cookies:

A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings.

Web Beacons (“Tracking Pixels”):

Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.

Embedded Scripts:

An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Company’s web server, or from a third-party with which Company works, and is active only while you are connected to the Service, and deleted or deactivated thereafter.

Location-identifying Technologies:

GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

Fingerprinting:

Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification and/or tracking.

Device Recognition Technologies:

Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).

In-App Tracking Methods:

There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices. Some information about your use of the Service and certain Third-Party Services may be collected using Tracking Technologies across time and services, and used by Company and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third-Party Services. Company is giving you notice of the Tracking Technologies and your choices regarding them so that your consent to encountering them is meaningfully informed.

1. Information Company Collects From Other

   Sources.

Company may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Company-Collected PI. Notwithstanding anything to the contrary, except to the extent such data combined by or on behalf of Company with Company-Collected PI, this Privacy Policy is not intended to limit Company’s activities regarding such third-party sourced, or non-Service-sourced, information (including Personal Information), and such data will only be treated as Company-Collected PI to the extend it is combined with Company-Collected PI. Company is not responsible or liable for the accuracy of the information provided by third parties or for third-party policies or practices.

2. HOW WE USE THE INFORMATION WE OBTAIN.

 Company may use information about you, including Company-Collected PI and other Personal Information, for any purposes not inconsistent with Company’s statements under this Privacy Policy, or otherwise made at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

Allow you to participate in the features we offer on the Service;

Facilitate, manage, personalize, and improve your online experience;

Process your registration, manage your account and/or upload your User Generated Content (“UGC”).

Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;

Company’s and Affiliates’ marketing and other purposes;

Improve the Service and for any other internal business purposes;

Tailor our content, advertisements, and offers;

Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so;

Determine your location and manage digital content rights (e.g., territory restrictions);

Prevent and address fraud, breach of policies or terms, and threats or harm; and

To comply with legal process such as a search warrant, subpoena or court order, or if requested by regulatory agencies with authority over the tobacco industry such as the Food and Drug Administration.

2. INFORMATION WE SHARE WITH THIRD PARTIES.

Company may share non-Personal Information, and Personal Information that is not deemed Company-Collected PI hereunder (provided that Company is aware of no restrictions of Company’s use, if any), with third parties, or Company and their affiliates (“Affiliates”) for any purpose. Company’s sharing of Company-Collected PI is, however, subject to the following:

Marketing: Subject to your communications choices and the rights of California residents. We may use your Personal Information to send you marketing communications. Absent your consent (which may be by means of opt-in, or a third-party interaction described in the next bullet point), however, Company will not share your Company-Collected PI with third parties, other than Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).

Your Disclosure or Consent: Information You Disclose Publicly or to Others and Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics, your activities on the Service may, by their nature, result in the sharing of your Company-Collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third-party, not Company. Company may also share any information about you (including, without limitation, Company-Collected PI) for any purposes not inconsistent with this Privacy Policy, or otherwise not prohibited by applicable law, including, without limitation:

Company’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including, without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on Company’s behalf, provided however, Company does not authorize its Service Providers to use Company-Collected PI provided by Company to the Service Providers to send you direct marketing messages other than related to Company and Company Affiliates absent your consent.

To comply with the law, law enforcement or other legal process, and in response to a government request (including, without limitation, Food and Drug Administration and other regulatory agency inquiries and requests); and

If Company believes your actions are inconsistent with Company’s terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Company, the Service or its users, or any third-party.

In addition, Company may share your Company-Collected PI (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Company assets, or transfer of all or a portion of Company’s business to another company (“Corporate Transactions”).

3. SWEEPSTAKES, CONTENTS, AND PROMOTIONS.

Company may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to Company, Company Affiliates, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.

4. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.

Company may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Company-Collected PI, and potentially certain other information about you (e.g., account information). For instance, you can make changes to your account information by updating or modifying your online account information via the “My Account” link provided at the top of each page. Company will make good faith efforts to make requested changes in Company’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Company’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

10. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.

11. Tracking Technologies Generally.

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. Some app-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Company currently does not alter Company’s practices when Company receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Company is not responsible for the completeness or accuracy of this third-party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our Site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Company is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third-party analytics and advertising providers, see the next section.

1. Analytics and Advertising Tracking Technologies.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.abouta ds.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use of a different device or web browsers or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Company supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf) and expects that ad networks Company directly engages to serve you Interest-based Advertising will do so as well, though Company cannot guaranty their compliance. Company is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

1. Communications.

You can opt out of receiving certain promotional communications from Company at any time for promotional e-mails by following the instructions provided in e-mails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Company may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Company’s ongoing business relations.

11. YOUR CALIFORNIA PRIVACY RIGHTS.

Company provides California residents with the option to opt-in to sharing of “personal information” as defined by California Civil Code Section 1798.83 (“Shine the Light law”) with third parties, other than Company Affiliates, for such third parties own direct marketing purposes. We do not share personal information with non-Affiliate third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law and/or withdraw previously given consent to sharing with non-Affiliate third parties for their direct marketing purposes by contacting us by e-mail at [email protected]. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one information request per customer each year, but you can withdraw a previously given consent at any time. We are not required to respond to requests made by means other than through this e-mail address or mail address. Although users are required to be twenty-one (21) years of age of older to use the Service, as required by California law, if any California residents under the age of eighteen (18) have improperly registered to use the Service, and posted content or information on the Service, they can request removal by contacting us by e-mail at [email protected] detailing where the content or information is posted and attesting that they posted it. Company will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law and to terminate the unauthorized account. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that Company does not control.

12. CHANGES TO THIS PRIVACY POLICY.

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Company-Collected PI, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.