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Privacy Policy

16th June 2023

Thank you for using NakedDelta. Tharwa Produce P/L (“Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the privacy of individuals who access, use, and/or interact with our products, services, websites, platforms, software, and applications which relate to NakedDelta (collectively, the “Services”). Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.

This Privacy Policy applies to information we collect through your use of the Services. If you are entering into this agreement on behalf of a legal entity, you hereby represent that you have the requisite authority to bind such entity by the terms of this Privacy Policy; and, in such case, the terms “you” or “your” shall refer to such entity where the context requires. By continuing to interact with our Services, you are hereby consenting to the practices described in this Privacy Policy. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services. This Privacy Policy may change from time to time without notice to you.

Our Services are not intended for children under thirteen (13) years of age. No one under age thirteen (13) may provide any information to or on the Services. We do not knowingly collect personal information from children under thirteen (13). If you are under thirteen (13), do not use or provide any information on our Services or on or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under thirteen (13) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under thirteen (13), please contact us at support@nakeddelta.com . California residents under sixteen (16) years of age may have additional rights regarding the collection and sale of their personal information.

This Privacy Policy does not apply to information collected by:

• us offline or through any other means, including, without limitation, on any other website or software operated by the Company or any third-party (including our affiliates and subsidiaries); or
• any third-party (including our affiliates and subsidiaries), including, without limitation, through any application or content that may link to or be accessible from or on the Services.

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We may revise and update this Privacy Policy from time to time in our sole discretion and without notice to you. All changes are effective immediately when we post them and apply to all access to and use of the Services thereafter.
Your continued use of the Services following the posting of any revised Privacy Policy means that you accept and agree to the changes. You are expected to check this page from time to time so you are aware of any changes, as they are binding on you.

We collect several types of information from and about users of our Services, including, without limitation:
We collect this information:

• directly from you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases, submit information to, or otherwise provide personal information to us;
• automatically as you navigate through the Services through the use of automatic data collection technologies, cookies, web beacons, and other tracking technologies; and
• from third-parties, for example, our business partners.

We use information that we collect about you or that you provide to us for purposes such as:

• to present our Services and personalize its contents to you;
• to verify accounts and activity;
• to monitor suspicious, fraudulent or unlawful activity and to identify violations of our policies;
• to comply with applicable laws, regulations, legal claims, and audit functions;
• to provide you with information or services that you request from us;
• to enforce, apply, or carry out our obligations and rights arising from any contracts and other agreements entered into between you and us, including our Terms of Use (https://nakeddelta.com/?p=terms) and other agreements, including for billing and collection;
• to protect the rights, property, or safety of the Company, our customers, or others.
• to notify you about changes to our Services or any other products or services we offer or provide through it;
• to contact you in relation to surveys or other research activities, and to analyze the data collected for market research purposes, including, without limitation, related to improving our Services;
• to allow you to participate in interactive features on our Services;
• to follow up with you after correspondence (live chat, email or phone inquiries) or to provide claim support;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

If you register or access the Services using an email address with a domain that is owned by your employer or organization, certain information about you, including your name, profile picture, contact info, content, and account use, may become accessible to that organization's administrator and other Company service users, as permitted by your employer's administrator, to provide you additional products and services or to integrate our Services with other products and services.

We may disclose aggregated information about our users and information that does not identify any individual, without restriction, in each case in accordance with applicable law and otherwise described in this Privacy Policy. Our third-party service providers are not permitted to share or use information we make available to them for any purpose other than to provide services to us. In connection with the sharing of any personal information, additional notice may be provided, and consent obtained, as required under applicable law. We may disclose personal information that we collect or you provide to us as described in this Privacy Policy to certain individuals and legal entities, including, but not limited to:

• your employer;
• our subsidiaries and affiliates;
• contractors, service providers, hosting partners, and other third parties we use to support our business and the Services, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Service users is among the assets transferred; and
• courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence.

We take the security of your personal information seriously, and we use technologies, security controls, and procedures which we believe are appropriate to protect your personal information (including administrative, technical, and physical safeguards) against accidental loss and unauthorized access, use, alteration, and disclosure. However, please remember that we cannot guarantee that our safeguards will be 100% secure. Although we use reasonable means and will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. The safety and security of your personal information also depend on you, and as such, you should only access the Services within a secure environment. We are not responsible for the circumvention of any privacy settings or security measures with respect to our Services.

Account Information We retain your account information for the length of time necessary to fulfill the purposes for which we collected it or when you cease to use our Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Services improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services.

Managed Accounts If the Services are made available to you through an organization (i.e., your employer), we retain your information as long as required by the administrator of your account.

Marketing Information

If you have chosen to receive marketing emails from us, we retain information about your marketing preferences unless you specifically request us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

If you are a resident of California, you may have additional rights regarding our use of your personal information under California law.

The California Online Privacy Protection Act ("CalOPPA") is the first state law in the United States to require commercial websites and online services to post a privacy policy. The law's scope extends beyond California, requiring any person or company in the United States (and potentially worldwide) operating websites that collect personally identifiable information from California consumers to prominently display a privacy policy on their website, disclosing the information being collected and the individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

Once this Privacy Policy is created, we will include a link to it on our home page or at least on the first significant page after accessing our services.

California's "Shine the Light" law (Civil Code Section § 1798.83) allows California resident users of our services to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at support@nakeddelta.com .

When it comes to collecting personal information from children under the age of thirteen (13) years old, the Children's Online Privacy Protection Act ("COPPA") puts parents in control. The Federal Trade Commission's Bureau of Consumer Protection enforces the provisions of COPPA, which outline what website and online service operators must do to protect children's privacy and safety online.

The Fair Information Practices Principles form the foundation of privacy law in the United States, and the concepts they include have played a significant role in shaping data protection laws worldwide. Understanding and implementing the Fair Information Practice Principles is crucial for compliance with various privacy laws that safeguard personal information.

To align with the Fair Information Practices, we commit to notifying users within seven (7) business days via in-services notification in the event of a data breach.

We also adhere to the "Individual Redress Principle," which grants individuals the right to pursue enforceable rights against data collectors and processors who fail to comply with the law. This principle not only ensures that individuals have enforceable rights against data users but also provides them with avenues to seek recourse through courts or government agencies to investigate and prosecute non-compliance by data processors.

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and imposes penalties for violations. We collect your email address to send information, respond to inquiries, and fulfill other requests or questions. To comply with CAN-SPAM, we agree to:

• Not use false or misleading subjects or email addresses.
• Clearly identify the message as an advertisement.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if used.
• Honor opt-out/unsubscribe requests promptly.

European Union data subjects have legal rights under the GDPR concerning their personal information. To learn more about each right you may have or to exercise any of your rights, please contact us by sending an email to support@nakeddelta.com. You may request that we:

• Confirm whether we have and are using your personal information.
• Correct any incorrect information about you.
• Ask us to restrict the use of your personal information in certain circumstances.
• Stop using your data for direct marketing purposes.
• Erase your personal information if we no longer need it for the purpose for which we collected it from you, if you have withdrawn your consent, if you have objected to further legitimate use, if we have used it unlawfully, or if we are subject to a legal obligation to erase it. We may continue to use your personal information following a request for restriction if we (a) have your consent, (b) need to use it to establish, exercise, or defend legal claims, or (c) need to use it to protect the rights of another individual or company.

Contact Us If you have any questions regarding this Privacy Policy, you may contact us at support@nakeddelta.com